G/TBT/W/677  
23 July 2019 
(19-4888) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
URUGUAY - LABELLING OF PACKAGED FOODS  
STATEMENT BY URUGUAY TO THE COMMITTEE ON TECHNICAL BARRIERS TO TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 2 2 July 2019, is being circulated at the request of the delegation 
of Uruguay . 
 
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1.  Uruguay wishes to thank the United States, the European Union (EU) , Colombia, Costa Rica and 
Guatemala for their ongoing interest in the draft law and Executive Decree  No. 272/2018 on the 
labelling of packaged foods , which were duly notified to the WTO  and published 
on 15 November  2018. 
2.  In this regard, we firstly wish to refer to the statements made by Uruguay at the last 
TBT Committee meeting and the timely additional information submitted , which were published 
together on 25 March  2019 as  document G/TBT/W/614 , in which we refer extens ively to a number 
of the points that have been  raised again on th is occasion . 
3.  Uruguay reco gnize s the Codex Alimentarius  as the main international regulatory reference point 
for foods, and understands  that there is currently no Codex reference standard  for the specific type 
of fron t-of-pack labelling  to which the measure refers . However, under the CAC/GL -2-1985 
Guidelines , nutrition  labelling has two components : the nutrient declaration  and supplementary  
nutrition  information . The purpose of supplementary  nutrition  information  is to increase the 
consumer 's understanding of the nutritional  value  of the food and to assist in interpret ing the 
nutrient declaration . The Codex  therefore provides fo r the inclusion  of supplementary nutrition 
information , as set out in the regulations in Uruguay.  
4.  It should also be recalled that at the 44th Session  of the Codex Committee on Food Labelling it 
was agreed to establish a n Electronic  Working  Group for incorporat ing guidance on front-of-pack 
nutrition  labelling, and a preliminary draft set of guidelines  for front-of-pack nutrition labelling was 
drawn  up, establishing  the latter's purpose, scope, definition and general principles . The preliminary  
draft guidelines stipulate that the system must be in line with  global principles  but be implemented  
on the basis of local research, and also monitor  consumer understanding at the start and end of 
implementation . The recommendations established  in the prelim inary draft were followed during the 
process for the development of the Decree and draft law concerning  front-of-pack labelling  in 
Uruguay.  
5.  The Codex standards on nutrition label ling were also taken into account in the drafting of Decree 
No. 272/18, resulting i n exceptions to the use of front -of-pack labelling for the products  indicated  in 
Article  3, namely : foods for medicinal use ; foods for partial meal replacement weight -control  diets; 
dietary supplements  and supplements  for athletes ; infant milk formula and formula for children  up 
to the age of 36 months ; and table -top sweeteners.  
6.  For the above reasons, the scientific  basis considered for the measure is the one p rovided by the 
regional  health authority , PAHO /WHO, whose authority  in this regard sho uld not be called  into 
question . The criteria  selected  for defining foods with an excess of sugars, fats, saturated fats or 
sodium  were those  established  by the re gional health  body, and the nutrient profile  model 
established  by WHO was chosen, the limits  of which are based on WHO guidelines  on intake of 
sugars, fats and sodium . In this regard , we consider that the OPS nutrient  profile  has been developed G/TBT/W/677  
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  on the basis of international standards, guidelines and  recommendations draw n up by the competent 
international organizations.  
7.  At the global  level various front -of-pack labelling systems have been developed, in order to 
provid e the public with nutrition al information that is simple , easy to find and easy to understand ; 
to promote informed  food choice s; and to promote  changes in food habits by reducing the 
consumption of products containing an excess of critical nutrients linked to obesity and 
non-communicable diseases  (NCDs) . However, there is no consensus  on which is the best syst em. 
Consequently, the choice  of front -of-pack food labelling system in Uruguay was based  on a large 
number  of national  studies  conducted  with participants from various age groups and socio -economic  
levels . Various quantitative  methodologies  were used to study  the effect  of different  systems on 
people's capacity to find and interpret nutrition al information , and also their  potential effects on the 
intention to purchas e. Studies  showed that the proposed nutrition  labelling system  increases  
people's ability to find nutrition al information on food labels and enable s them to rapidly identify 
products containing excessive amounts of critical nutrients . Moreover, the pro posed system achieved 
results that were superior to those of other  front-of-pack food labelling systems implemented  in 
other countries, such as the "guideline daily amount " (GDA ) system , the "traffic light " system, the 
French "five-colour " system  and the Australian "health  star rating " system.  
8.  Specifically , the system chosen  by Uruguay contains the following advantages : 
a. It conveys the idea, in a simple form, that foods contain an exces s of sugars, fats and 
sodium; 
b. It avoids poten tial confusion  in the evaluation of products containing an excess of one 
nutrient and low amounts  of others; 
c. It does not promote  consumption  of foods  that do not have nutritional advantages by not 
emphasizing a low nutrient  content ; 
d. It facilita tes the  interpreta tion of n utritional information , since it describes nutrients 
associated with NCDs  in the light of nutritional recommendations , something that people 
need in order to understand nutrition  labelling and take informed decisions ; and, 
e. It entails  lower implementation  costs than the GDA system or the "traffic light " system , in 
being incorpor ated solely in foods that  have excess ive levels  of nutrients.  
9.  Front-of-pack labelling will enable people to make informed  food choices  for a healthy, balanced 
diet; it seeks to complement  rather than replace  the nutritional labelling regulations in force, and so  
the nutri ent declaration  will remain mandatory . A description  of nutrient c ontent will never give rise 
to doubts regarding product  safety , nor is there any evidence  of it causing consumer anxiety . The 
policy  seeks  to provide the public  with clear information and make it easier to identif y foods with  
excess critical nutrients, so that people  can take informed decisions regarding  consumption . 
10.  As regards the use of nutrition  claims , it should be emphasized that the measure does not 
interfe re with the voluntary  highlighting  of positive  qualities of foods, such as addition  of fibre  or 
vitamins , presence of probiotics , etc. I n this regard, studie s undertaken  in the country show that 
such highlighting has a positive  impact  on food choices  even after implementation  of the  
front-of-pack labelling system.  
11.  As regards implementa tion of the measure, the Decree provides for the possibility of us ing 
stickers  in the case of imported products.  
12.  Uruguay remains open to continu ing to exchange informa tion with interested Members through 
suitable channels, while reaffirming  its right to implement  appropriate policies , in line with WTO 
standards, to protect  the lives and health  of its population and to combat the scourge of obesity 
and NCDs , in line with S DG 3.4 of the United Nations 2030 Agenda  for Sustainable Development , 
which seeks  "to reduce by one third premature mortality from non -communicable diseases through 
prevention and treatment and promote mental health and well -being " by 2030.  
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