Total diet replacement for weight control

Total diet replacement for weight control refer in particular to foods prepared for use in energy-restricted diets for weight reduction and which are used in accordance with the manufacturer’s instructions to replace all daily meals.

The products are sold pre-packaged under the label Total diet replacement for weight control.

Meal replacements for weight control intended to replace one or two daily meals are considered as being fortified foods.

Legislation

Total diet replacement for weight control products are included in foods for special groups and regulated by Regulation (EU) No 609/2013 of the European Parliament and of the Council. 

In addition, more detailed composition and labelling requirements are provided for these products in Commission Delegated Regulation (EU) 2017/1798, which applies from 27 October 2022.

Composition

Total diet replacement for weight control shall comply with the compositional requirements set out in Annex I to Regulation (EU) 2017/1798. The products may contain other ingredients than the substances listed in Annex I only if their suitability has been established by generally accepted scientific data.

The vitamin and mineral compounds permitted in total diet replacement for weight control products are listed in Annex I to Regulation (EU) No 609/2013.

Specific requirements concerning food information

Mandatory particulars in accordance with Regulation (EU) No 1169/2011 Article 9(1) shall be provided for total diet replacement for weight control. In addition, the following particulars shall be provided about the products:

  • a statement that the product is only intended for healthy overweight or obese adults who intend to achieve weight reduction;
  • a statement that the product should be not used by pregnant or lactating women, adolescents or by individuals suffering from a medical condition without the advice of a healthcare professional;
  • a statement on the importance of maintaining an adequate daily fluid intake;
  • a statement that the product provides adequate daily amounts of all essential nutrients when used in accordance with the instructions for use;
  • a statement that the product should not be used for more than 8 weeks, or repeatedly for shorter periods than this, by healthy overweight or obese adults without the advice of a healthcare professional;
  • instructions for appropriate preparation, where necessary, and a statement as to the importance of following those instructions;
  • if a product, when used as instructed by the manufacturer, provides a daily intake of polyols in excess of 20 g per day, a statement that the food may have a laxative effect;
  • if dietary fibre is not added to the product, a statement that the advice of a healthcare professional must be sought regarding the possibility of supplementing the product with dietary fibre

The statement ‘very low calorie diet’ (VLCD) may be used for total diet replacement for weight control provided that the energy content of the product is below 3 360 kJ/day (800 kcal/ day). The statement ‘low calorie diet’ (LCD) may be used for total diet replacement for weight control provided that the energy content of the product is between 3 360 kJ/day (800 kcal/day) and 5 040 kJ/day (1 200 kcal/day).

Nutrition labelling

Mandatory nutrition labelling information

Nutrition information shall always be provided for total diet replacement for weight control products, irrespective of the size of the largest surface of the packaging. The information included in the nutrition declaration shall not be repeated elsewhere on the labelling.

The following nutrition information shall always be provided:

  • the amounts of energy, fat, saturates, carbohydrates, sugars, protein and salt,
  • the amount of each mineral substance and of each vitamin listed in Annex I to Delegated Regulation (EU) No 2017/1798,
  • the amount of any choline present, and if added, of dietary fibre.

The energy value and amounts of nutrients of total diet replacement for weight control products shall be expressed per total daily ration as well as per portion and/or consumption unit. Where appropriate, information may in addition refer to 100 g or 100 ml of the food as sold.

The energy value and amount of nutrients for total diet replacement for weight control products shall not be expressed as a percentage of reference intakes set out in Annex XIII to Regulation (EU) No 1169/2011.

The indication of the amount of sodium shall appear together with the other minerals and may be repeated next to the indication of the salt content as follows: ‘Salt: X g (of which sodium: Y mg).

Voluntary nutrition labelling information

Nutrition labelling may be supplemented with the information referred to in Article 30(2) (a) to (e) of Regulation (EU) No 1169/2011, i.e. with:

  • mono-unsaturates,
  • polyols, starch,
  • fibre.

In addition to these, it is allowed to supplement nutrition information with the particulars referred to in Article 5(2) (a) to (c) of Delegated Regulation (EU) 2017/1798, which are

  • the amounts of components of fat and carbohydrates,
  • the amounts of substances listed in the Annex to Regulation (EU) N:o 609/2013,
  • if, in accordance with Article 3 of Regulation (EU) 2017/1798, other ingredients than the substances listed in Annex I have been added to a total diet replacement for weight control product, the amounts of these substances may be indicated in the nutrition labelling.

Nutrition and health claims

The nutrition claim ‘added fibre’ may be used for total diet replacement for weight control products provided that the dietary fibre content of the product is not less than 10 g. No other nutrition and health claims shall be made.

The labelling, presentation and advertising of total diet replacement for weight control products shall not make any reference to the rate or amount of weight reduction which may result from its use. 

Notification of placing on the market

Under Article 7 of Delegated Regulation (EU) 2017/1798, the Finnish Food Authority shall be notified of all new total diet replacement for weight control placed on the market.

The notification is made through the Finnish Food Authority’s e-service or using the form found on this webpage. A model of the product labelling on the packaging and where necessary a power of attorney are mandatory appendixes.

The Finnish Food Authority does not assess product compliance when receiving notifications. This is the responsibility of the food business operator who places the product on the market. The Food Authority forwards the notifications to municipal food control authorities for monitoring.

A fee is charged for the receipt of notifications pursuant to the Decree of the Ministry of Agriculture and Forestry on the fees charged for services produced by the Finnish Food Authority.

Page last updated 12/15/2022