Part 4: Nutritional analysis – the what, how and where of sampling

When you include nutritional information on your product label, whether voluntary or mandatory, there are a number of considerations regarding the testing that you do. It is important to understand that the sampling of your product must be done correctly. If it is not, it could negatively impact the results and in turn increase your cost, due to the extra testing that becomes necessary. FACTS has put together a handy infographic to help.

Do the regulations cover sampling?

Guideline 5 of the regulations relating to the labelling and advertising of foodstuffs (R. 146/2010) goes into great detail regarding how sampling should be conducted to ensure the accuracy of the nutritional information to be included on the label or any other advertising.

What does the guideline cover?

The guideline includes details on the various types of sampling that can be conducted, how many samples are required, where sampling should take place and where samples should be stored. In addition, it covers aspects such as permissible tolerances for testing variances, and there are a number of helpful definitions.

Sample types

The type of sample appropriate for submission to laboratories for testing is the one that will provide the most accurate results for the product in question. The types to consider are random, stratified and representative samples. Selective or convenience sampling is not acceptable.

A random sample is a sample that has no bias present in its selection; all products have an equal chance of selection.

Representative samples are expected to adequately reflect the characteristics of the ‘parent’ population. This is a sample that is made up exactly to the formulation; therefore, it reflects the ideal contributions made by each ingredient. A disadvantage of this form of sampling is that variances in the quantities of each ingredient added into the final product during production are likely.

Stratified samples are samples taken from identical subparts of the parent population. Within each subpart, the samples are randomly selected. For example, in order to determine the effect of seasonal variation on oats’ protein fraction, random samples are taken from each season over the year, to obtain an average protein value that is accurate for the oats.

Number of samples to submit for nutritional analysis

The number of samples submitted for nutritional analysis is dependent on the matrix of the product sampled. For products of a homogenous nature, such as polony or pasta, a minimum of three samples from different batches of product must be submitted.

For heterogeneous samples, produce or prepared foodstuffs, a minimum of 12 samples from various batches must be submitted. This must be made into one composite sample, or three composite samples of four individual samples each.

Where multiple samples from different batches cannot be collected over a period of time (e.g. if appropriate storage is not possible) – as is the case with fresh produce or ready-to-eat or -drink products – individual samples may be submitted and an average value of the results calculated.

Samples sent for nutritional analysis must be sampled in accordance with a relevant sampling plan – i.e. random, representative or stratified sampling.

The testing laboratory will make the submitted samples into a composite sample to execute the analyses.

Sample handling

The concept of ‘all due care’ is expected to be employed during sample handling, to ensure the protection of samples from the elements, microbial spoilage, moisture loss or gain, or cross-contamination of any kind. This is done to ensure the stability of nutrients during the process of sampling and sending the sample to a laboratory for analysis.

Do I need to record my sampling procedure?

The regulation requires you to keep records of a number of documents and processes; on request, these must be made available within two working days (see What to keep on file, according to R. 146). Your sampling procedure is one of these requirements.

Do I even need to include nutritional information?

While the growing interest from consumers results in most products including nutritional information, it is not part of your mandatory minimum labelling requirements. They are only mandatory when you include a nutrition claim on your label. But if you do include nutritional information, it is important to ensure you are including the right type of information.

Please see our handy infographic illustrating The What, How and Where of Nutritional Testing.

Using the guideline to ensure you are following correct sampling procedures may result in a reduction in testing costs, as the likelihood of needing to retest is significantly reduced. It will also ensure improved accuracy of the information you present to consumers, in turn reducing any risk of misleading the consumer through the presentation of incorrect information.

Contact FACTS for any questions relating to the declaration of your nutritional information table and/or the testing requirements. Our Regulatory and Nutrition Team is standing by.

Other articles and resources you may be interested in:
Minimum labelling infographic
What to keep on file, according to R. 146
FACTS Nutritional Information
Part 1: Nutritional Analysis – A complete guide
Part 2: Nutritional Analysis – Include the table on the label or not?
Part 3: Nutritional Analysis – Needed or can it be calculated?
Part 5: Nutritional Analysis – What serving size to label
Part 6: Nutritional Analysis – Red flags to look out for