Carob Health Claims: EU and Turkish Legislation
As the number of scientific studies on carob increases, expressions such as "lowers cholesterol", "balances blood sugar", "strengthens immunity" are more common on product labels and advertisements. However, both in the European Union and in Turkey, the use of health claims in foods is subject to strict rules, and the existence of a scientific study does not mean that the expression can be used on the label.
In this article, we discuss an example of a health claim evaluated in the EU regarding carob, the regulations that came into force in Turkey in 2023, and the key points to consider when labeling carob products.
Difference Between Nutrition Declaration and Health Declaration
Two different types of declarations are distinguished from each other in food legislation. Nutritional declarationare statements about the energy or nutrient content of a food; such as "fiber source", "no added sugar". Health declaration are statements that establish a relationship between a food or its component and health; for example, saying that an ingredient contributes to the maintenance of normal blood cholesterol levels is a health claim.
This distinction is crucial in practice, as the two types of declarations are subject to different rules. With the regulation made in Turkey in 2023, these two areas were divided into separate regulations. The Turkish Food Codex Regulation on Nutrition and Health Claims, which was previously a single text (Official Gazette dated 26.01.2017 and numbered 29960), was repealed; it was replaced by the Turkish Food Codex Regulation on Nutritional Claims published in the Official Gazette dated 20.04.2023 and numbered 32169 (KPMG, 2023). On the same day, a separate regulation regulating health claims was published in the same Official Gazette (Regulation on the Use of Health Claims in Food and Supplementary Foods, 2023).
Health Claims in Turkey: 2023 Regulation
The Regulation on the Use of Health Claims in Food and Supplementary Foods is carried out by the Turkish Medicines and Medical Devices Agency (TİTCK). The purpose of the Regulation is to determine the procedures and principles for the use of health claims in food and supplementary foods for the highest level of consumer protection. The prominent provisions in terms of carob products can be summarized as follows:
- The health claim cannot be vague, false or misleading.
- Statements cannot cause anxiety in the consumer by referring to changes in body functions.
- Statements referring to the amount of weight loss and statements containing testimonies, advice or approval cannot be used.
- Statements regarding disease risk reduction must include a statement stating that the disease has more than one risk factor.
- Enterprises registered with the Ministry of Agriculture and Forestry can use the declarations in the Authority's guide without applying for a separate permit or notification.
- The list of permitted health claims is included in the annexes of the guideline published by the Agency.
- The food operator is obliged to comply with the conditions of the declaration and must keep the relevant documents.
(Regulation on the Use of Health Claims in Food and Supplementary Foods, 2023)
This structure means that if a carob product is to use a health claim, the statement must be one of the statements listed in the TİTCK's guideline and the conditions of use defined for that claim must be met by the product. The regulation was later updated with an amendment published in the Official Gazette dated 23.08.2023 and numbered 32288 (KPMG, 2023b). Businesses planning to use a declaration on the label should check the current version of the guideline and regulation from official sources.
Prohibition of Disease-Related Claims on the Label
Regardless of the health claim regulation, the Turkish Food Codex Regulation on Food Labeling and Informing Consumers also draws a basic limit on what cannot be said on the label. According to Article 7 of the Regulation, information about food cannot be misleading and it cannot be stated that a food has the ability to prevent, treat or cure a disease, without prejudice to the legislation on foods for special nutritional purposes. These rules also apply to advertising, promotion, the shape and appearance of packaging (Turkish Food Codex Regulation on Food Labeling and Informing Consumers, 2017; with 2024 amendments).
In terms of carob products, the practical equivalent of this is as follows: Expressions such as "good for diabetes", "treats cholesterol", "relieves anemia", "stops diarrhea" cannot be used on food labels and promotions, no matter how much scientific attention the product itself receives.
An Example of a Declaration Regarding Carob in the European Union
In the European Union, health claims are assessed under Regulation (EC) No 1924/2006; the European Food Safety Authority (EFSA) examines the scientific basis of the declaration, and the European Commission and member states decide whether to allow it. A concrete example directly related to carob is contained in the Commission's Regulation (EU) 2016/1411.
According to this regulation, a Spanish company applied for a health claim for FRUIT UP®, a carbohydrate extract derived from locust bean pods, stating that it reduced the postprandial blood glucose response compared to high-glycemic carbohydrates. EFSA concluded that no cause-and-effect relationship could be established between the consumption of the product and the reduction of postprandial glycemic response beyond the well-known effect of fructose when used as a substitute for glucose. It was also stated that no effect was observed when the product was compared to sucrose. As a result of this evaluation, it was decided that the declaration did not meet the requirements of Regulation 1924/2006 and should not be allowed (Commission Regulation (EU) 2016/1411; EFSA Journal 2015; 13(5):4098).
This example carries an instructive message for the carob industry: the presence of human studies with a carob product does not automatically confirm the health claim. Regulators expect the impact to be clearly demonstrated according to the appropriate comparison group and in the target population.
Research Finding and Label Statement Are Not the Same Thing
The effect of carob fiber on blood lipids has been studied in several randomized controlled trials. For example, in a 6-week study with 58 volunteers with hypercholesterolemia, a carob fiber preparation of 15 g per day was associated with a 10.5 percent decrease in LDL cholesterol (Zunft et al., 2003). Such findings are scientifically valuable; however, they are not enough for a product label to say "lowers cholesterol".
There are several reasons for this:
- The material used in the studies is usually a specially prepared preparation; not every carob product on the market has the same composition.
- In order for the declaration to be used, the product must meet the conditions defined in the certified declaration (component quantity, daily consumption amount, etc.).
- The statement must be a formally listed and approved statement; it cannot be created by the company's own interpretation.
Declarations Regarding Immunity and Digestion
Another area of claim frequently seen in carob products is the immune and digestive system. According to the guide published by the Ministry of Agriculture and Forestry, General Directorate of Food and Control in 2018 and based on the EFSA guideline, the general statements regarding the immune system that are evaluated positively are related to essential nutrients such as vitamins C, D, A, B6, B12, zinc, copper, folate, iron and selenium. All evaluations regarding defense against pathogens and reducing the risk of infection were negative; applications regarding general gastrointestinal disorders also received negative opinions (Republic of Turkey Ministry of Agriculture and Forestry GKGM, 2018).
In this context, the use of general expressions such as "carob strengthens immunity" without relying on a specific approved declaration and conditions is not in accordance with the legislation.
Nutritional Statements: Fiber, Sugar, and Naturalness Statements
What can be used more frequently instead of health claims in carob products are nutritional claims regarding nutritional content. The repealed 2017 regulation also regulated that nutritional claims could only be used when they comply with the declarations and conditions in the annex of the regulation (Turkish Food Codex Regulation on Nutrition and Health Claims, 2017). This principle was moved to a separate text with the Regulation on Nutritional Claims dated 2023 (KPMG, 2023).
Therefore, expressions such as "fiber source", "high fiber", "no added sugar" cannot be used freely; each of them has threshold values and conditions defined in the regulation. For example, carob powder may have a high fiber content; however, before making a fiber declaration on the product label, it should be verified that the conditions in the regulation are met with the analysis results of the product.
Practical Notes for Exporting Businesses
Businesses exporting carob products to the European Union or other markets must comply with the declaration legislation of the target country. An expression that can be used in Turkey may be subject to different conditions in the target market or may not be used at all. Therefore:
- Export labels should be checked separately according to the legislation of the target market.
- B2B technical documents (specification, certificate of analysis) and consumer-oriented marketing texts should be separated from each other.
- Website, social media and catalog texts should be prepared with the same care as the label, as they can be considered within the scope of "promotion".
- When citing scientific studies, the result of the study should not be presented as if it belongs to the product itself.
Frequently Asked Questions
Is there an approved health claim in the EU for carob? In the official texts we examined within the scope of this article, we did not find any approved health claims specific to carob; on the other hand, there is Regulation 2016/1411, which shows that an application for carob extract FRUIT UP® was rejected. For the current situation, the EU health claims register should be checked.
Which institution issues health declarations in Turkey? With the 2023 regulation, the use of health claims in food and supplementary foods is regulated by the regulation carried out by the TİTCK.
Are expressions such as "natural" and "additive-free" on the label a health claim? These statements are not health claims; however, they must be true and provable within the scope of the prohibition of misleading information.
Is it considered a statement to mention carob research in a blog post? Promotional texts directly associated with product sales may be subject to evaluation. It is important to use measured language when conveying scientific findings and not to associate the product with the treatment.
Regulatory Compliance Procurement with Carob Türkiye
Accurate labeling of carob products is critical for both consumer trust and export processes. At Carob Türkiye, we supply carob fruit, granules, flour/powder, seeds, and extracts; for your wholesale and export demands Contact Now You can contact us on our page.
Related articles and products: What is Carob Extract?, What is D-Pinitol in Carob?, Our Products.
This content is for general informational purposes; it is not a substitute for legal advice or medical advice. The current version of the legislation should be checked from official sources.
Domestic resources
Regulation on the Use of Health Claims in Food and Supplementary Foods, Official Gazette, 20.04.2023, Number: 32169 (Turkish Medicines and Medical Devices Agency). faolex.
FAO. org/ docs/ pdf/ tur224261. KPMG Turkey, "Turkish Food Codex Regulation on Nutrition Claims has been published", Financial Bulletin, 2023. kpmgtax.
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gov. en/ GKGM/ Documents/ DB_Risk_Degerlendirme/ Know... Foreign sources
European Commission, "Commission Regulation (EU) 2016/1411 of 24 August 2016 refusing to authorise certain health claims made on foods, other than those referring to the reduction of disease risk and to children's development and health", Official Journal of the European Union, 2016 (FRUIT UP® review: EFSA Journal 2015; 13(5):4098). legislation.
gov. uk/ eur/ 2016/ 1411/ introduction Zunft, H. J., Lüder, W., Harde, A., Haber, B., Graubaum, H. J., Koebnick, C. et al. "Carob pulp preparation rich in insoluble fibre lowers total and LDL cholesterol in hypercholesterolemic patients", European Journal of Nutrition, 2003; 42(5): 235–242. doi.
Scientific Resourcesorg/ 10. 1007/ S00394- 003- 0438- y
