South Africa's front-of-pack warning labels are still coming

Draft Regulation R3337, published for comment in late 2023, is intended to replace R146 of 2010 as South Africa's food labelling law. As things stand it is still a draft — R146 remains the regulation you comply with today — but the direction of travel has been clear for long enough that manufacturers have started moving without waiting for it.

What it would require

A mandatory front-of-pack warning label on products that exceed thresholds for sugar, salt or saturated fat. Reporting on the draft also indicates the label would apply to anything containing a non-sugar sweetener, with a grace period for compliance once it is finalised.

Why it lands on a flavour house

Two reasons, and they pull in opposite directions.

The obvious one: if a warning label is triggered by sugar, the way to avoid it is to take sugar out. That is a reformulation, and reformulating without losing the product is the hard part — sugar carries body, mouthfeel and the top of the flavour, and sweetener alone does not put those back.

The less obvious one: if the label is also triggered by a non-sugar sweetener, then swapping sugar for an intense sweetener does not necessarily get you out of it. That changes the calculation, and it is worth understanding properly before committing to a reformulation programme.

Nothing here is settled, and the thresholds and transition period may move before it is. If it is likely to affect a product you make, the useful thing is to know now what your options actually are.

Reporting: goLegal · Daily Maverick · Food For Mzansi