G/TBT/W/614  
25 March  2019 
(19-1848) Page: 1/17 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
URUGUAY – LABELLING OF PACKAGED FOODS  
STATEMENT BY URUGUAY TO THE COMMITTEE ON TECHNICAL BARRIERS TO TRADE  
6 AND 7 MARCH 2019  
The following communication, dated 2 2 March  2019, is being circulated at the request of the 
delegation of Uruguay . 
_______________  
 
 
1.  Uruguay thanks the delegations of Colombia, Costa Rica, the United States, the European Union 
and Guatemala for the interest they have shown in the draft law on the lab elling of packaged foods, 
which was timely notified to the WTO on 1 5 November  2018 in document G/TBT/N/URY/25 . Uruguay 
also thanks Colombia for the prior bilateral meeting and the initial withdrawal of this concern.  
2.  First, with respect to the notification mentioned above, Uruguay wishes to inform you that the 
period for submitting comments on the draft law has been extended by 45 days (that is, until 
30 March  2019). This will be duly notified to the WTO during the day today.  
3.  With respect to the comments and  questions raised with respect to both the draft law and on 
Decree No. 272/018, which was notified to the WTO in its final form in document G/TBT/N/URY/26 
and Corrigendum No. 2 thereto, Uruguay wishes to make the following reply:  
4.  Noncommunicable diseases ( NCDs) are the primary cause of death and disease in Uruguay and 
generate high social and economic costs . Common behavioural risk factors include unhealthy diets 
and physical inactivity, which also contribute to overweight and obesity, conditions that are c urrently 
a cause for concern in Uruguay, with averages higher than the regional and global ones and 
considerable related economic costs.  
5.  In recent years, significant changes have been observed in the public's eating patterns, with 
increases in the energy d ensity of diets and in the consumption of fats and saturated fats, sugars 
and sodium, particularly in processed food stuffs, at the expense of healthier foods.  
6.  There is convincing scientific evidence associating excessive consumption of these nutrients wit h 
the development of a wide range of NCDs . To halt this epidemic, we must change the obesogenic 
environment and promote healthy surroundings that allow for the selection and consumption of 
natural foods that are low in sugars, fats and sodium.  
7.  This is why Uruguay, following the recommendations of the WHO, has set itself the goal of 
reducing overweight and obesity through a cross -cutting plan of healthy diets and physical activity, 
and has been working on a series of interventions that includes the developme nt of regulations on 
front-of-pack labelling for packaged foods.  
8.  Various international organizations have prepared guidelines to support States' efforts in 
developing or strengthening policies aimed at reducing the impact of the consumption of food stuffs 
with excess fats, sugars and sodium.  
9.  PAHO's Plan of Action for the Prevention of Obesity in Children and Adolescents, unanimously 
adopted at its 53rd Directing Council in 2014, calls for the implementation of effective regulatory 
interventions, such as fro nt-of-pack labelling systems for processed foods with high sodium, sugar, G/TBT/W/614  
 
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  fat and saturated fat content . To support implementation by countries, PAHO defined criteria for 
evaluating excesses of those nutrients in beverages and food stuffs.  
10.  In 2016, the WHO  issued the Report of the Commission on Ending Childhood Obesity, which 
assessed a package of recommendations for addressing childhood obesity and called on 
governments to take leadership . Specifically, Recommendation 1.7 points to the need to implement 
interpretive front -of-pack labelling, supported by public education, in order to promote the selection 
of foods with healthy nutritional profiles.  
11.  Furthermore, in 2017, the WHO released a list of "best buys" and other recommended 
interventions for the preven tion and control of NCDs . The most cost -effective interventions for 
reducing unhealthy eating include, notably, reducing salt intake through the implementation of 
front-of-pack labelling and nutrition labelling to reduce total intake of energy, sugars, sod ium and 
fats. 
12.  Including nutritional information on the front of packages is one of the strategies being 
implemented around the world to improve access to nutritional information and to allow consumers 
to make informed decisions . At the 44th Session of the Codex Committee on Food Labelling (CCFL44), 
it was agreed to establish an Electronic Working Group (EWG) to study and prepare guidelines on 
this issue.  
13.  Under Decree No. 117/006, which incorporates the "MERCOSUR Technical Regulation on 
Nutrition Labelling f or Packaged Foods" into Uruguayan law, all packaged foods marketed in Uruguay 
must have a nutrition label.  
14.  Although the purpose of the label is to provide citizens with information on the nutritional 
characteristics of foods and contribute to an appropriat e consumption of those foods, a large portion 
of the public feels the label is difficult to find and understand . In many cases, the information is 
placed on the back of the package or in an area with little visibility, in a small font size . The 
complexity of the information provided makes it difficult for our citizens to interpret it correctly and 
discourages them from using it when making decisions . Along these lines, several studies conducted 
in a large number of countries have shown the need for simplifi ed nutritional information in order to 
promote informed decisions by citizens.  
15.  Through the front -of-pack labelling legislation, consumers are given access to information that 
is easy to understand and useful in making decisions . Today, a wide range of prod ucts is available 
on the market ; however, most consumers spend fewer than ten seconds choosing each item, an 
amount of time that is insufficient for reviewing the complex nutrition label currently used . The 
front-of-pack label is designed to help them inte rpret the nutrient declarations that provide 
quantitative information, generally on the back of the package . It could also encourage 
manufacturers to improve the nutritional quality of their products in order to meet the standards.  
16.  In Uruguay, the main obj ectives pursued by front -of-pack nutrition labelling are:  
• to provide the public with simple information that is easy to find and understand and that 
will promote informed food choices, and  
• to encourage the consumption of foods with favourable nutrient prof iles. 
17.  There are several front -of-pack nutrition labelling formats, and they differ in the degree to which 
they educate consumers on how healthy a product is . Non-directive systems, such as the "guideline 
daily amounts" (or "GDA") system, only provide infor mation on a food's per -portion nutrient content 
and do not contribute to a better understanding of nutritional information among the public . 
Semi-directive systems, such as the "traffic light" system, inform the consumer of the per -portion 
nutrient content  and classify it as high, medium or low through colour coding and an explanatory 
text. These systems do not make a value judgement as to how healthy a food is and require 
consumers to make their own overall assessments on the basis of the levels of each of  the nutrients 
presented . Lastly, directive systems, such as the "warnings" system, identify unhealthy products 
without presenting detailed information on the quantity of each nutrient.  G/TBT/W/614  
 
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  18.  Uruguay's selection of a front -of-pack nutrition labelling system was based on 14 studies in 
which a total of 3,499 Uruguayans of different age groups and socio -economic levels participated . 
Various quantitative methods were used to study the effects of different front -of-pack nutrition 
labelling systems on perceptions of healthfulness and purchase intent . The results of the studies 
indicated that the "warnings" system had a number of advantages over the "GDA" and "traffic light" 
systems.  
19.  To begin with, the system adopted by Uruguay had the best results in terms of informat ion 
processing time . It also allows for products with unfavourable nutritional profiles to be identified 
more clearly and effectively and helps reduce the public's perception of the healthfulness of products 
generally not thought to be high in critical nut rients, without this entailing scaring consumers or 
inducing them not to eat certain foods.  
20.  When an opinion survey was conducted on the system adopted, 95 % of the 1,416  participants 
said they had a positive view of the policy and 94 % agreed that it would a llow them to clearly identify 
unhealthy products, indicating that they would take it into account in selecting foods.  
21.  Given the considerable influence that the design of the symbols has on their effectiveness, 
five studies were conducted to select the desi gn, with an emphasis on the colour, shape and textual 
information included . These resulted in the selection of an octagonal shape with black symbols with 
a white border and the phrase "excess", as these are the easiest to spot and have the strongest 
associ ation with an unhealthy product.  
22.  Studies were conducted to assess the effect that implementation of the front -of-pack nutrition 
labelling system was expected to have on the buying behaviour of Uruguayans, and the results 
suggested that Uruguayans would pre fer foods without symbols indicating that they have an "excess" 
of the nutrients in question . The most likely effect, however, is substitution ; that is, within a 
category, consumers will substitute the products they habitually buy that have an "excess" of 
nutrients with products that do not have an "excess" of them . Consequently, for the industry, the 
reformulation of products is a strategy for remaining competitive in the market . The results also 
showed that product characteristics and consumers' motivatio n to eat healthily will also play a role 
in the effect that the front -of-pack nutrition labelling system will have.  
23.  The first results of the study assessing the effects of Law No. 20.606 on the nutritional 
composition of foods and food advertising, which e ntered into force in Chile in June 2016, suggest 
that implementation of the labelling law was initially associated with positive changes in food 
environments and people's behaviour.  
24.  Under Decree No. 272/018, adopted in August  2018, foods packaged in the ab sence of the 
customer and legally required to have a nutrition label must have a label on the front of the package 
if the amount of sodium, sugars, fats or saturated fats in the final composition of those foods exceeds 
the established values.  
25.  Recognizing t hat nutrient profile models enable clear criteria to be established for front -of-pack 
labelling regulations, the WHO has formulated general principles and a methodological approach for 
the development of such models.  
26.  In response to a mandate from their mem ber States, the WHO regional offices prepared their 
own models on the basis of the 2010 WHO report . The PAHO model was prepared and reviewed by 
a committee of external experts and is based on independent evidence . The limits that are set in it 
are based on  WHO recommendations for intake of sugars, fats and sodium.  
27.  Notable among the advantages of this model are that:  
• it does not assume a daily energy intake of 2,000 kcal, as the current nutrition label does;  
• it is based on the proportion of energy in a food that comes from critical nutrients;  
• it always uses the same basis for comparison : the proportion of energy provided by the 
various critical nutrients;  G/TBT/W/614  
 
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  • it allows for comparison with any product, regardless of portion, package size or category;  
• it can be app lied to different age groups ; and 
• it rectifies the disadvantages of expressing nutrients based on energy needs (which vary 
according to individual requirements) or the amount of food.  
28.  The criteria under the nutrient profile model are thereby made independent of individual 
variations and the amount of food consumed, and focus on its nutritional composition.  
29.  The use of different limits for each category would allow for the comparison of products within 
the same category, but it would not allow for an  overall assessment of foods . Uruguay is not the 
first country to use a single set of criteria for all product categories : Chile, Ecuador and the 
United  Kingdom have used the same approach in designing their front -of-pack labelling systems.  
30.  Since PAHO's nutrient profile was developed on the basis of international standards, guidelines 
and recommendations prepared by the competent organizations, it is consistent with Article 3.1 of 
the WTO SPS Agreement.  
31.  It is to be noted that, as a result of the public co nsultation held on the draft decree in 2017, the 
criteria for determining that there was an "excess" of critical nutrients were relaxed, and this was 
reflected in the final wording of Decree No. 272/018.  
32.  The Decree applies solely to packaged foods with add ed sugars, fats and sodium . It focuses on 
the addition of nutrients rather than on processing, it being recognized that processed foods are not 
in and of themselves responsible for obesity and NCDs . The decision to consider only foods with 
added sugars, fa ts, saturated fats and sodium is rooted in the lack of substantive scientific evidence 
showing that the consumption of natural foods without added nutrients has adverse health effects . 
For each one of the critical nutrients considered, the scientific evide nce shows differences between 
the foods in which they are present naturally and those to which they have been added . In this 
regard, it should be noted that according to the PAHO recommendations, natural foods should not 
bear front -of-pack labels indicatin g that they have "excess" sugars, fats and sodium.  
33.  The evidence mentioned above has prompted several countries to recommend consuming less 
food with added sugars and salt in their dietary guidelines . It should be noted that the vast majority 
of packaged fo ods marketed in Uruguay contain added sugars, fats and sodium.  
34.  The conformity assessment procedures will be in line with the guidelines established by the 
Ministry of Public Health in Decree No. 272/018 and Ministerial Ordinance No. 160 of 
11 February  2019. The procedure used by the competent bodies to authorize the marketing of 
packaged foods will be adapted to those guidelines, without distinction as to whether the products 
are domestic or imported.  
35.  The regulation does not distinguish between domestic and  foreign products, nor does it take 
into account the origin of the raw materials used or the place of their processing . It is purely a health 
measure that aims to improve eating habits on the basis of better decision -making by consumers 
and, therefore, cov ers all products falling within its scope, regardless of whether they are of domestic 
origin or imported.  
36.  The draft law does not establish the criteria for or the design of the front -of-pack label, as it is 
expected that, if it is adopted, those will be es tablished in the regulation implementing the law, 
which will, a priori , be aligned along the same principles as Decree No. 272/018 . The criteria for 
applying a front -of-pack label are set forth in Annex II to the Decree ; the criteria in Annex III were 
included for informational purposes and provide the reference values under the PAHO nutrient profile 
model.  
37.  In short, the measure adopted under Decree No. 272/018 on front -of-pack labelling of packaged 
foods is justified and non -discriminatory, given that:  
• Uruguay is experiencing an epidemic of overweight, obesity and NCDs;  G/TBT/W/614  
 
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  • there is sufficient evidence supporting the relationship between the consumption of foods 
excessive in fats, saturated fats, sugars and sodium and the development of the health 
problems targ eted;  
• front-of-pack labelling is one of the public policy measures recommended by PAHO/WHO to 
enhance consumers' understanding of the nutritional content of products and to promote 
healthy eating;  
• evidence is available in Latin America on the effectiveness  of a front -of-pack labelling system 
with characteristics similar to the one adopted in Uruguay;  
• it was developed according to a process consistent with good regulatory practices defined 
by PAHO;  
• a nutrient profile model was used as the basis for determini ng the product categories 
amenable to front -of-pack labelling;  
• products marketed in other markets were allowed to comply with the regulation through the 
use of stickers ; and 
• it applies to both domestic and imported products and does not take into account the origin 
of the raw materials used or the place where they are processed.  
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   G/TBT/W/614  
 
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  APPENDIX  
Montevideo, 2 5 February  2019. 
 
1.  Views on the need and justification for Decree No. 272/018 and the draft law on the labelling of 
packaged foods are presented in detail below, in response to questions from the Republic of Colombia 
on the texts notified to the World Trade Organization in documents G/TBT/N/URY/14, 
G/TBT/N/URY/25 and G/TBT/N/URY/26.  
2.  The Eastern Republic of Uruguay understands health to be  a human right, which involves explicitly 
assuming a set of responsibilities inherent to the Uruguayan State in its role as guarantor . It means 
acting in accordance with three specific obligations, all aimed at ensuring the conditions for leading 
a healthy  life: 
• The obligation to define and spearhead intersectoral health policies that encourage the 
participation and involvement of users, workers and society as a whole in improving lifestyles 
and reducing health risks.  
• The obligation to promote the adoption of different measures – legislative, administrative, 
judicial, programmatic and budgetary – so that institutions related to the health -disease 
process provide the best possible comprehensive physical and mental health care.  
• The obligation to protect, in wh ich the State stops third parties from interfering with, 
violating or impeding the enjoyment of the right to health . As the right to health is an 
inclusive right, the State's obligation is not limited to health care, but also extends to 
determinants that c ontribute to individuals being able to lead a healthy life . This means that 
advocating for the defence of the right to health involves enforcing other civil, political, 
social, economic and cultural rights to the extent that violations of them have direct and 
negative consequences on human health and welfare.  
3.  Consequently, what society must provide in order to guarantee good health includes elements 
related to health care in its own right and also elements related to the conditions and the 
environment in wh ich life unfolds : water, sanitation, food, nutrition , housing, working conditions 
and environment, health education and information , and others.  
4.  In the health sector, bringing the rights perspective into stewardship of the health system – in a 
broad sense – means adopting it as a framework that guides the design, implementation, 
assessment and oversight of the different health policy and collective health actions . General 
Comment No. 14 of the UN Committee on Economic, Social and Cultural Rights establishes  that both 
health care and basic services should be available, accessible, of good quality and ethically and 
culturally appropriate.  
5.  The Government of Uruguay defined National Health Objectives (OSNs) in order to identify 
specific and measurable outcomes t hat would benefit the population, with targets expressed through 
a set of indicators . The aim is to have an impact on critical issues from a rights -based perspective, 
taking account of gender -related differences and improving comprehensive care for the mos t 
prevalent pathologies.  
6.  Another aim is to reduce the degree of exposure of individuals and populations to modifiable risk 
factors (including unhealthy eating), while at the same time building their capacity to make decisions 
and adopt healthy behaviours a nd working to ensure work environments, food conditions  and 
environmental conditions that support their full development.  G/TBT/W/614  
 
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  7.  The United Nations and the World Health Organization (WHO) recognize that noncommunicable 
diseases represent one of the main obstacles  to development in the twenty -first century and require 
a multisectoral approach . Following WHO recommendations on promoting healthy eating and 
physical activity as two key actions for the prevention and control of NCDs, Uruguay placed the 
reduction of ove rweight and obesity in all stages of the life course and the implementation of an 
intersectoral plan for healthy eating and physical activity among its National Health Objectives . In 
connection with that, it has been working to implement various interventi ons related to the following 
items:  
• Promoting good dietary practices for infants and small children  
• Improving spaces in educational institutions that favour healthy eating and physical activity  
• Dietary Guidelines for the Uruguayan Public  
• Physical Activity Guidelines  
• Decree No. 114/018 on the phasing out of trans fats  
• Programme for the progressive reduction of sugar and sodium  
• Overweight and obesity control programme  
• Implementation of Decree No. 272/018 on front -of-pack labelling for packaged foods  
 
8.  In order  to develop these activities, the President created a National Coordinating Council on 
public policies for the prevention of overweight and obesity, which seeks to promote the 
mainstreaming and coordination of public policies in this area . As part of these  actions, regulations 
were developed on front -of-pack labelling for packaged foods, and these were set forth in Decree 
No. 272/018 of 2 9 August  2018. 
1  JUSTIFICATION FOR THE REGULATIONS  
9.  Noncommunicable diseases (NCDs) are the primary cause of death and disease in the 
country . Six out of every ten people die from an NCD, both among individuals aged 70 and over 
and among individuals between 30 and 70, which is known as premature mortality . According to the 
latest estimates, 15 out of every 100 Uruguayans who were 30 years old in 2016 will die before the 
age of 70 from one of the four main NCDs (cardiovascular diseases, cancer, diabetes and chronic 
lung diseases).  
10.  This situation carries high social and economic costs, as, for example, it is estimated that t he 
direct costs (doctors' visits, laboratory tests, treatments, etc.) and indirect costs (lost work days and 
productivity, etc.) incurred in the country in 2015 and attributable to diabetes came to 
USD 512 million . 
11.  There is broad scientific consensus regar ding the four common behavioural risk factors for 
NCDs : tobacco use, harmful use of alcohol, unhealthy diets and physical inactivity . Unhealthy diets 
and physical inactivity are also associated with the development of overweight and obesity, which is 
one o f the metabolic risk factors for NCDs.  
12.  Uruguay is facing a troubling situation with respect to overweight and obesity . 
According to the latest Survey on Risk Factors for Noncommunicable Diseases (Ministry of Public 
Health, 2013), the prevalence of overweig ht and obesity in adults is 64.9 %, with 37.2 % presenting 
with overweight and 27.6 % with obesity . These figures place the country above the regional and 
world averages, reaching double the world average in the case of obesity (FAO, 2018) . Obesity 
prevalence  is rising quickly, having increased 8 % in 7 years (that is, more than 1 % each year).  
13.  Similarly, 38.5 % of youth between 15 and 24 present with some degree of overweight or obesity 
(Ministry of Public Health, 2013) . In children, the problem is even more ala rming ; a study of 10 - to 
13-year-old school children in Montevideo found that 26 % presented with overweight and 13 % with 
obesity . In addition, the risk of high blood pressure was found to be twice as high in overweight or 
obese children as it was in normal -weight children (Honorary Cardiovascular Health Commission 
2015).  
14.  As with NCDs, obesity also represents an enormous economic cost for the country, with the 
annual cost of care associated with obesity estimated at USD 500  million  for 2020, an amount equal 
to 1% of GDP (Kaufmann and Pontet, 2018) . With this background, it can clearly be seen that obesity 
and noncommunicable diseases constitute one of the country's major challenges . This fact has been G/TBT/W/614  
 
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  recognized in the Ministry of Public Health's (MSP) Nation al Health Objectives, where the first two 
strategic objectives are : "Favour healthy lifestyles and environments and reduce risk factors" and 
"Reduce the premature and avoidable burden of death, disease and disability" (MSP, 2015).  
15.  Recognizing that NCDs hav e multiple causes, unhealthy diets and physical inactivity have 
been identified as the primary factors associated with obesity and noncommunicable 
diseases ; they should therefore be key components of the prevention strategies implemented 
(WHO, 2004).  
16.  In recent years, significant changes have been observed in the public's eating patterns, leading 
to increases in the energy density of diets and in the consumption of sugars, fats and sodium (Popkin 
BM 2012) . Over time, traditional meals prepared at home using fresh foods have been replaced with 
processed food products containing excess fats, especially saturated fats, sugars and sodium 
(WHO  2003).  
17.  According to Pan American Health Organization (PAHO) estimates, between 2000 and 2013, 
sales of sugary drinks in Ur uguay tripled, increasing from 33 to 96 litres per person annually, while 
sales of other products with excess sugars, fats and sodium increased from 16 to 30 kg per person 
annually . This 146 % increase in total sales over that period puts Uruguay first amon g 
13 Latin American countries as the country with the greatest growth in sales (PAHO 2015) . At the 
same time, a 12.1 % reduction was observed in fruit and vegetable purchases by households 
(National Institute of Statistics, 2008).  
18.  Furthermore, 90 % of adults  do not consume the recommended portions of fruits and vegetables 
(Ministry of Public Health 2013), 70 % of adolescents drink one or more sugary drinks a day (Ministry 
of Public Health, 2013) and the elevated consumption of products with excess sugars, fats  and 
sodium is observed from early childhood (Nutrition, Child Development and Health Survey 
(ENDIS  2015; ENDIS 2018).  
19.  Today, there is sufficient scientific evidence on the association between excessive 
consumption of sodium, sugars, fats and saturated fats and the development of 
noncommunicable diseases . This evidence has been classified by the WHO as "convincing" or 
"probable", the highest levels of scientific evidence (WHO 2003).  
20.  Sugar consumption  has risen steadily, mainly because of sugars added to foods during their 
preparation (Lustig RH 2012) (Popkin BM 2017) . Sugars contribute to an increase in the overall 
energy density of the diet, which can lead to a positive energy balance, triggering excessive weight 
and body fat gains (Johnson RK 2009) (WCR F/AICR5 2007) (Elia M 2007) as well as an alteration in 
the metabolism of lipids and carbohydrates (Stanhope KL 2016).  
21.  Sugars, and those in sugary drinks in particular, not only increase total energy intake but can 
also reduce intake of foods with more app ropriate nutritional profiles, leading to an unhealthy diet, 
weight gain and a greater risk of noncommunicable diseases (Hur Y -I 2016) . Excessive intake of 
added sugars is associated with an increase in the risk of a variety of diseases, including 
cardiova scular diseases, metabolic diseases, diabetes and non -alcoholic fatty liver disease, as well 
as cognitive impairment and even some types of cancer (WHO 2015) (Popkin BM 2017) 
(Vos MB 2017) (Stanhope KL 2016) (Johnson RK 2009) (Rippe JM 2016) . Added sugars have been 
associated with the development of these diseases regardless of the increase in body weight or total 
energy intake (Rippe JM 2016) . In particular, the fructose that is added during food production 
causes an alteration in the metabolism of lipids,  which leads to hepatic lipid accumulation, 
dyslipidemia and reduced insulin sensitivity (Bidwell AJ 2017).  
22.  The WHO classifies this evidence as "strong", which means it should be considered in 
policy -making . The WHO guidelines recommend reducing intake of sugars to less than 10 % of total 
daily energy intake, and point out that there is evidence suggesting that this level should be reduced 
to less than 5 % in order to prevent caries (WHO 2015).  
23.  Among environmental factors, high sodium intake  (more than 2 g pe r day, equal to 5 g of salt 
per day) and insufficient potassium absorption (less than 3.5 g per day) are common risk factors 
(WHO 2009) (WHO 2012) (WHO 2007) (Luzardo L. 2011) for hypertension and increase the risk of 
heart disease and stroke. (Choi HY. 20 15) (Olde Engberink RH. 2015) (Strazzullo P. 2009) . In G/TBT/W/614  
 
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  Uruguay, high blood pressure affects 36 % of the adult population (Ministry of Public Health 2013), 
which is higher than the global average . Apparent salt consumption has been estimated at 10 g (that 
is, twice the recommended limit) while apparent consumption of fruits and vegetables, the principal 
dietary source of potassium, is at approximately half the recommended level.  
24.  Evidence shows that small reductions in dietary sodium intake have been associate d with 
significant decreases in blood pressure and a reduction in cardiovascular events (He FJ. 2002) 
(He FJ. 2011) (Guyatt GH. 2008) (Cook NR. 2007).  
25.  As reducing the intake of salt is considered to be one of the most cost -effective measures that 
countries  can take to prevent and control NCDs, WHO member States have agreed to reduce the 
consumption of salt by the world's population by 30 % by 2025 (WHO 2012).  
26.  Fats have a significant influence on health (WHO 2002) (FAO 2010) . The quantity and quality 
of fats play a role in the development of cardiovascular diseases, insulin resistance and 
type 2 diabetes (Qiao L. 2015) (Ros E. 2015).  
27.  High-fat diets have a number of effects on metabolism and body composition, including 
adiposity, insulin resistance, hyperinsuli nemia and an increase in circulating lipids (WHO 2002) (FAO 
2010) . Moreover, an increase in dietary fats alters the composition of other macronutrients, reducing 
the level of carbohydrates and proteins (Kereliuk SM. 2017) . In the diets of Uruguayans, it ha s been 
found that an excessive amount of energy comes from total fats (Ministry of Public Health 2016).  
28.  The elevated consumption of saturated fats has been associated with the development of an 
atherogenic lipid profile, an increase in coronary events and increased low -density lipoprotein 
cholesterol, which is associated with an increased risk of disease (FAO 2010) (Ros E. 2015) 
(Eckel  RH. 2013) (Zevenbergen H. 2009) . Saturated fats have also been linked to the development 
of metabolic syndrome and diabetes  (FAO 2010) (Alhazmi A. 2014) (Kastorini CM. 2014) 
(Shadman  Z. 2013) (Mensink RP. 2003) . Furthermore, studies using animal models provide solid 
evidence that consuming a diet high in saturated fats during pregnancy or lactation promotes obesity 
and a range  of metabolic and cardiovascular disorders in offspring (Kereliuk SM. 2018).  
29.  In light of the above, it is evident that to halt the epidemic of obesity and associated 
noncommunicable diseases, we must change the obesogenic environment and promote healthy 
surroundings that allow for the selection and consumption of natural foods that are low in sugars, 
fats and sodium.  
30.  In this regard, various international organizations have prepared guidelines  to support 
States' efforts in developing new policies or streng thening existing ones that aim to reduce the 
impact of the consumption of food stuffs with excess fats, sugars and sodium.  
31.  The PAHO Plan of Action for the Prevention of Obesity in Children and Adolescents was 
unanimously adopted at the 53rd PAHO Directing Council in 2014 and calls for the implementation of 
effective interventions, particularly regulatory ones, such as the establishment of front -of-pack 
labelling systems for processed foods with high sodium, sugar, fat and saturated fat content 
(OPS 2014) . To support implementation by countries, PAHO defined criteria for evaluating excesses 
of sugars, salt, fats and saturated fats in beverages and food stuffs (OPS 2016).  
32.  In 2016, the WHO issued the Report of the Commission on Ending Childhood Obesity, which 
assessed a comprehensive, integrated package of recommendations for addressing childhood 
obesity and calls on governments to take leadership . Among the recommendations selected, 
Recommendation 1.7 points to the need to implement interpretive front -of-pack l abelling, supported 
by public education, in order to promote the selection of foods with healthy nutritional profiles 
(OMS  2016).  
33.  Furthermore, in 2017, the WHO released a list of "best buys" and other recommended 
interventions for the prevention and contro l of NCDs based on an update of Appendix 3 of the Global 
Action Plan for the Prevention and Control of NCDs 2013 –2020. The most cost -effective interventions 
for reducing unhealthy eating include, notably, reducing salt intake through the introduction of la bels 
on the front of packages and nutrition labelling to reduce total intake of energy (kcal), sugars, 
sodium and fats (WHO 2017).  G/TBT/W/614  
 
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  34.  To support these processes, Uruguay recently completed a review of the Dietary Guidelines for 
the Uruguayan Public and prepar ed Physical Activity Guidelines . The first frames an appropriate and 
healthy diet as a human right and sets out 11 keys for eating healthy, together and enjoyably:  
IN YOUR DAILY LIFE  
1. Enjoy your food : eat slowly and, when you can, eat with others.  
2. Base your  diet on natural foods and, in your day -to-day life, avoid consuming 
ultra-processed products that have excess fats, sugar and salt.  
3. Start the day with a good breakfast and don't skip meals . Cooking our own food does us 
good: discover the pleasure of cooki ng and make it an activity you can share.  
4. Cooking our own food does us good : discover the pleasure of cooking and make it an 
activity you can share.  
5. Look critically at the information and advertising messages that you see on food.  
6. Do at least two and a hal f hours of physical activity over the course of the week and reduce 
the amount of time you spend sitting.  
AT THE TABLE  
1. Always choose water over other beverages . Limit soft drinks, artificial juices and flavoured 
waters.  
2. Include fruits and vegetables in all  your meals . This will help you feel good and stay at a 
good weight.  
3. Choose oil for your dishes instead of other fats . Don't buy products with an excessive level 
of fats, especially if they contain trans fats.  
4. Include fish at least once a week and reduce y our consumption of processed meats like 
cold cuts and sausages.  
5. Reduce the salt and sugar you use in cooking : small amounts are enough to bring out the 
taste.  
35.  The front -of-pack labelling regulations provide consumers with easy -to-understand information 
that helps them make decisions, given the wide range of products available on the market today ; 
however, it is known that most consumers spend less than ten seconds choosing each item, an 
amount of time that is insufficient for reviewing the complex nutrition  label currently used 
(Cowburn  G. 2005) (Rothman RL. 2006) (Wartella  EA. 2010) . The front -of-pack label is designed to 
help them interpret the nutrient declarations that provide quantitative information, generally in small 
print, on the back of the package  (WHO 2015) . It could also encourage manufacturers to improve 
the nutritional quality of their products in order to meet the standards (Vyth EL. 2010).  
2  SELECTING THE FRONT -OF-PACK LABELLING SYSTEM  
36.  Labels are an important source of information for the publi c, as they communicate a food's main 
characteristics . Nutritional information should facilitate the assessment of how healthy a food is and 
promote the choice of healthy foods . Since 2006, it has been mandatory for nutritional information 
to be included on  the labels of food stuffs marketed in our country . The nutrient declarations of the 
nutrition label must be grouped together and appear in one place, in tabular or linear form.  
37.  Providing nutritional information on packages is one of the strategies that ha ve been used 
around the world to inform the public about the nutritional composition of foods and to enable 
informed decision -making . Requiring that nutritional information be provided is considered to be a 
duty of the State in assuring citizens' basic rig ht to information ; it is a tool for nutritional education 
and promotes self -reliance and self -care among the public . Under Decree No. 117/006, which 
incorporates the "MERCOSUR Technical Regulation on Nutrition Labelling for Packaged Foods" G/TBT/W/614  
 
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  (MERCOSUR Common  Market Group Resolution No. 46/03) into Uruguayan law, all packaged food 
marketed in the country must have a nutrition label.  
38.  Although the purpose of the label is to provide citizens with information on the nutritional 
characteristics of foods and contrib ute to an appropriate consumption of those foods, a large portion 
of the public feels the label is difficult to find and understand . In many cases, the information is 
placed on the back of the package or in an area with little visibility, in a small font s ize, and this 
makes it difficult to use . The complexity of the information provided makes it difficult for our citizens 
to interpret it correctly and discourages them from using it when making decisions . Along these 
lines, it should be noted that several s tudies conducted in a large number of countries have shown 
the need for simplified nutritional information in order to promote informed decisions by citizens.  
39.  Including nutritional information on the front of packages  is one of the strategies being 
impleme nted around the world to improve access to nutritional information and to allow consumers 
to make informed decisions . At the 44th Session of the Codex Committee on Food Labelling (CCFL44), 
it was agreed to establish an Electronic Working Group (EWG), chair ed by Costa Rica and co -chaired 
by New Zealand, with the following terms of reference:  
i. To consider the Guidelines on Nutrition Labelling  (CXG 2 -1985) and any other Codex 
guidelines that may be relevant in relation to the changes that may be required to 
incorporate the guidance on front -of-pack nutrition labelling (FOPL) into the Codex 
texts.  
ii. To prepare proposed draft guidelines for circulation for comments and for consideration 
at CCFL45 that include four key aspects : (a) purpose and scope ; (b) definitio n of FOPL ; 
(c) general principles for FOPL ; and (d) aspects to consider in the development of FOPL 
systems, identified under section 3 ( "Main Aspects to be Covered ") of the project 
document.  
iii. To make recommendations on the placement of the guidelines.  
40.  The E WG also determined that the Guidelines on Nutrition Labelling  (CXG 2 -1985) allow for the 
use of supplementary nutrition information . However, these guidelines do not provide the necessary 
guidance to help governments (and other stakeholders) apply suppleme ntary nutritional information, 
such as FOPL, in a way that ensures the protection of public health and minimizes potential barriers 
to trade . Consequently, strong guidance on FOPL could have a meaningful impact around the world.  
41.  In Uruguay, it was decided that the main objectives that should be pursued by front -of-pack 
nutrition labelling are:  
• To provide the public with simple information that is easy to find and understand and that 
will promote informed food choices.  
• To encourage consumption of foods with favourable nutrient profiles so as to be in line with 
the recommendations of the Dietary Guidelines for the Uruguayan Public.  
42.  There are several formats for nutrition labels on the front of packages, which differ in the degree 
to which they educate consumer s on how healthy a product is . Non-directive systems, such as the 
guideline daily amounts (or "GDA") system, only provide information on a food's per -portion nutrient 
content and do not contribute to a better understanding of nutritional information among the public 
(Figure 1a) . Semi-directive systems, such as the traffic light system, inform the consumer of the 
per-portion nutrient content and classify it as high, medium or low through colour coding and 
explanatory text ( Figure 1b) . These systems do not ma ke a value judgement as to how healthy a 
food is and require consumers to make an overall assessment on the basis of the levels of each of 
the nutrients presented . Lastly, directive systems, such as the warnings system ( Figure 1c), identify 
unhealthy produ cts without presenting detailed information on the quantity of each nutrient.  G/TBT/W/614  
 
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  Figure 1 Leading front -of-pack nutrition labelling systems around the world : 
(a) guideline daily amounts system ; (b) traffic light system ; (c) warnings system
 
43.  Uruguay's selectio n of a front -of-pack nutrition labelling system was based on 14 studies in 
which a total of 3,499 Uruguayans of different age groups and socio -economic levels participated . 
Various quantitative methods were used to study the effects of different front -of-pack nutrition 
labelling systems on perceptions of healthfulness and purchase intent . The results of the studies 
indicated that the warnings system had a number of advantages, summarized below, over the GDA 
and traffic light systems.  
44.  The system adopted by U ruguay had the best results in terms of information processing . When 
this system is used, consumers need less time to identify labels indicating high nutrient content than 
when the traffic light or GDA system is used ( Table 1).  
Table 1 Time required to ide ntify a label indicating high sodium content from a set of 
three labels . Visual search study with 32 trained participants  
Labelling systems  GDA Traffic light  Warnings  
Average time 
(in milliseconds)  2,187  1,784  1,422  
 
45.  With respect to the traffic light system, it is important to highlight that the colour code 
associated with the nutrient content must be included so that the information can be more easily 
processed and products with high nutrient content rapidly identified.  
46.  The system adopted by Uruguay a llows for clear identification of products with unfavourable 
nutritional profiles and reduces the public's perception of the healthfulness of products generally not 
thought to be high in critical nutrients, without this entailing scaring consumers or induc ing them 
not to eat certain foods . In one of the studies conducted in connection with the design of the decree 
on front -of-pack labelling, this system succeeded in reducing the healthfulness perception of three 
of the five products considered . The traffic light system, on the other hand, did not change the 
healthfulness perception of products when compared to the GDA system ( Figure 2). This result can 
be explained by the fact that the traffic light system classifies the levels of all critical nutrients, whi ch 
means that consumers must assess the relative importance of a high -content nutrient when 
compared to other low - or medium -content nutrients.  
G/TBT/W/614  
 
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  Figure 2 : Average healthfulness perception of labels of five products using different 
front -of-pack nutrition la belling systems (1=unhealthy, 7=very healthy) . Study 
conducted with 387 participants of different socio -economic levels . Average values for a 
single product shown with different superscripts indicate significant differences 
between front -of-pack labelling systems.  
 
47.  Consumers have a limited capacity to identify the healthiest product from a set of options when 
the GDA system is used . This capacity improves slightly when written information is included that 
classifies the nutrient content as high, medium or low. Under the system adopted, there is an 
improvement similar to that under the traffic light system in consumers' ability to correctly identify 
foods with unfavourable nutritional profiles.  
48.  The system adopted has the greatest potential for discouraging consumption of products with 
unfavourable nutritional profiles . In one of the studies, in which participants were asked to buy food 
for a healthy dinner at home using a virtual supermarket, it was observed that the system adopted 
significantly reduced the average energy, sugar, fat and sodium content of the foods selected 
(Table 2). The traffic light system also led to a reduction in the energy, sugar and fat content of the 
foods, but it did not affect the sodium content . Furthermore, the system adopted suc ceeded in 
reducing school children's desire to consume products with unfavourable nutritional profiles for their 
afternoon snack . The traffic light system, on the other hand, did not have a significant influence on 
the children's choices.  
Table 2 : Average nutritional composition of foods selected in a virtual supermarket for a 
healthy dinner . Online study conducted with 1,182 participants . Average values for a 
nutrient shown with different superscripts indicate differences between front -of-pack 
labelling sy stems.  
 Control 
(no information)  Traffic light  Warnings  
Energy (kcal/100 g)  181a 171b 170b 
Sugar (g/100 g)  7.1a 6.5b 6.2b 
Saturated fat (g/100 g)  2.0a 1.8b 1.7b 
Sodium (mg/100  mg) 399a 363a,b 323b 
 
49.  It should be noted that a number of studies conducted  around the world, both with children and 
with adults, have shown that the traffic light system does not affect the intention to consume or 
purchase unhealthy foods . Similar results were found in other empirical studies as well as in the 
United Kingdom after the system was implemented.  
50.  In an online opinion survey involving 1,416 participants, the perception of the system adopted 
was extremely positive . Ninety-five per cent  expressed a positive view of the policy, as exemplified 
in the following statement s: "Are necessary so that consumers can choose with the most information 
G/TBT/W/614  
 
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  possible", "It's very important to have warnings about unhealthy foods ; then each individual can 
decide whether to eat them or not", "Excellent . It's needed", "Great idea ! Very helpfu l in knowing 
what to choose in order to eat healthy", "I think it's perfect… it's a big wake -up call…" . Furthermore, 
94% of the participants agreed that the front -of-pack nutrition labelling system would allow them 
to clearly identify unhealthy products an d indicated that they would take it into account in selecting 
foods when doing their shopping.  
51.  The design of the symbols has a strong influence on their effectiveness . For this reason, 
five studies were conducted to select the design, with an emphasis on c olour, shape and the textual 
information included . Out of eight colours, black had the lowest healthfulness perception ( Figure 3). 
In addition, black circles with a white border are easier to find on labels than red circles with a white 
border . The healthf ulness perception of symbols with three shapes (octagon, triangle and inverted 
triangle) and three phrases (excess, too much and high) was also compared . The results indicated 
that the octagonal shape and the word "excess" had the strongest association wit h an unhealthy 
product.  
Figure 3 Average healthfulness perception score for eight colours (0 = completely 
unhealthy, 9 = very healthy) . Online study conducted with 100 participants . Average 
values shown with different superscripts indicate significant diff erences.  
 
52.  A series of studies were conducted to assess the expected effect of implementing the 
front-of-pack nutrition labelling system on the buying behaviour of Uruguayans . The results 
suggested that Uruguayans would prefer foods that did not have symbols indicating an excess of 
sugars, fats, saturated fats and sodium . The most likely effect, however, is substitution ; that is, 
within a category, consumers will sub stitute the products they habitually buy that have an excess of 
nutrients with products that do not have an excess . Consequently, for the industry, the reformulation 
of products is a strategy for remaining competitive in the market . The results also showed  that 
product characteristics (brand, price, type of reformulation) and consumers' motivation to eat 
healthily will also play a role in the effect that the front -of-pack nutrition labelling system will have.  
53.  When compared to traditional nutrient declaratio ns (nutrition table), certain front -of-pack 
labelling systems have been shown to be effective in facilitating consumer access to nutritional 
information, and this has led to the measure being recommended as a public policy (WHO 2015).  
54.  The first results of the study assessing the effects of Law No. 20.606, which entered into force 
in Chile in June 2016, suggest that implementation of the labelling law was initially associated with 
changes in food environments and the eating habits of ind ividuals, particularly children, that are in 
line with improving the diets and health of the public . For example:  
• Sodium and sugar content was reduced in important categories of packaged foods : an 
analysis of the nutritional information declared on packages of more than 10,000  products 
HEALTHY  UNHEALTHY  8.7a 
6.5b 6.4b 
5.7bc  
5.2cd  
4.4d 
2.2e 
1.7e G/TBT/W/614  
 
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  prior to implementation of the regulation and 7 -8 months thereafter showed significant 
decreases in the average sugar content of top -selling beverages, dairy products and 
breakfast cereals (20 -35% of the initial conten t) as well as a notable reduction in sodium in 
top-selling cheeses and cured meats (5 -10% of the initial content) . This decreased sodium 
and sugar content means a reduction of about 50 % in products that are high in sugars or 
sodium in these categories.  
 
• Consumers' recognition of the nutritional value of packaged foods was improved : it was 
observed that the mothers of pre -school children and the adolescents studied appreciated 
the presence of the warning labels on packaged foods (>90 % in both groups), unders tood 
their meaning (>90 % in both groups), used them when they wanted to know how healthy 
foods were (50 % and 40 %, respectively) and were better able to identify less healthy 
packaged foods after the labels were introduced . 
 
• Household purchases of key categ ories of "high in" products decreased : six months after the 
law entered into force, purchases of breakfast cereals were observed to be down an average 
14%. Eighteen months after the law was implemented, purchases of high -sugar beverages 
were down 25 %. 
 
55.  Under Executive Decree No. 272/018, adopted in August  2018, foods packaged in the absence 
of the customer and legally required to have a nutrition label must have a label on the front of the 
package if the amount of sodium, sugars, fats or saturated fats in t he final composition of those 
foods exceeds the values established in the Decree . It includes specific provisions on packages and 
labels that are aimed at guaranteeing the right of citizens to reliable and easily interpreted 
information.  
3  SETTING LIMITS TO DEFINE EXCESS FATS, SATURATED FATS, SUGARS AND SODIUM  
56.  Recognizing that nutrient profile models enable clear criteria to be established for regulations 
on food and beverage advertising targeting children, front -of-pack labelling, tax policies and other 
interventions, the WHO has formulated general principles and a methodological approach for the 
development of such models . In response to a mandate from their member States, the WHO regional 
offices prepared their own models on the basis of the WHO report,  published in 2010, set up along 
different regional plans and strategies.  
57.  PAHO's nutrient profile model was prepared and reviewed by a committee of experts external 
to PAHO, is based on independent evidence and has been distributed to PAHO's member States,  
including Uruguay.  
58.  The limits that are set in the PAHO nutrient profile model are based on WHO recommendations 
for intake of sugars, fats and sodium . According to PAHO, this model can be used by policymakers 
and programme managers for food and nutrition l abelling, citizen education, food marketing 
regulations and fiscal policies.  
59.  Notable among the advantages of this model are that:  
• It does not assume a daily energy intake of 2,000 kcal, as the current nutrition label does.  
• It is based on the proportion of energy in a food that comes from critical nutrients.  
• It always uses the same basis for comparison : the proportion of energy provided by the 
various critical nutrients.  
• It allows for comparison with any product, regardless of portion, package size or catego ry. 
• It can be applied to different age groups.  
• It rectifies the disadvantages of expressing nutrients based on energy needs (which vary 
according to individual requirements) or the amount of food.  G/TBT/W/614  
 
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  60.  The criteria under the nutrient profile model are thereby m ade independent of individual 
variations and the amount of food consumed, and focus on the nutritional composition of the food.  
61.  The model assumes that, whatever their age range, if the food individuals consume does not 
exceed the criteria, those individual s will, at the end of the day, meet the WHO intake 
recommendations ; that is, if their energy intake is in line with the recommendation for their age, 
their intake of sugars, sodium and fats will, at the end of the day, be in line with the 
recommendations.  
62.  The use of different limits for each category would allow for the comparison of products within 
the same category . However, it would not allow for an overall assessment of foods . Uruguay is not 
the first country to use a single set of criteria for all prod uct categories . Chile, Ecuador and the 
United Kingdom have used the same approach in designing their front -of-pack nutritional labelling 
systems . Since PAHO's nutrient profile was developed on the basis of international standards, 
guidelines and recommenda tions prepared by the competent organizations, it is consistent with 
Article 3.1 of the Agreement on the Application of Sanitary and Phytosanitary Measures of the 
World  Trade Organization (WTO).  
63.  As a result of the public consultation held on the draft decr ee in 2017, the criteria for determining 
that there was an excess of critical nutrients were relaxed, and this was reflected in the final wording 
of Decree No. 272/018.  
4  JUSTIFICATION FOR RESTRICTING LABELLING TO FOODS WITH ADDED SUGAR, FATS, 
SATURATED FATS  AND SODIUM  
64.  The Decree applies solely to packaged foods with added sugars, fats and sodium . Consequently, 
it focuses on the addition of nutrients rather than on processing, it being recognized that processed 
foods are not in and of themselves responsible f or obesity and noncommunicable diseases . The 
decision to consider only foods with added sugars, fats, saturated fats and sodium is rooted in the 
lack of substantive scientific evidence showing that the consumption of natural foods without added 
nutrients h as adverse health effects . For each one of the critical nutrients considered, the scientific 
evidence shows differences between the foods in which they are present naturally and those to which 
they have been added . In this regard, it should be noted that a ccording to the PAHO 
recommendations, natural foods should not bear front -of-pack labels indicating that they have 
excess sugars, fats and sodium.  
65.  The intake of sugars beyond the recommended amount is associated with health risks . However, 
the sugars found  in whole fruits have not been associated with negative health effects, with the 
natural food matrix being considered to offer protection . Ripe fruits contain simple sugars, along 
with other bioactive substances and components, but do not have the negative  metabolic effects of 
foods or beverages that have been sweetened through the addition of simple sugars . WHO sugars 
intake recommendations do not, therefore, apply to consumption of the intrinsic sugars present in 
fresh fruits and vegetables . Furthermore, the Decree does not cover the lactose found naturally in 
milk, as it also is not included in the WHO recommendations on sugars intake.  
66.  With regard to sodium, a number of studies have shown that the salt added during food 
preparation is the main source of d ietary sodium . In industrialized countries, the majority of the 
sodium consumed by the population comes from processed foods . In the case of Uruguay, half the 
daily consumption of sodium comes from processed foods to which salt has been added during 
produc tion. 
67.  There is also evidence that the effects of natural foods with a high fat content differ from those 
of foods to which fats have been added during production . For example, a number of benefits in 
terms of cardiovascular health and obesity prevention ha ve been attributed to the regular 
consumption of different varieties of nuts, which are foods with a high fat content . Because of this, 
it was decided to amend the wording of the Decree so that fats from nuts would not be considered 
in making determination s of excess fat and saturated fat content.  
68.  The evidence mentioned above has prompted several countries to recommend consuming less 
food with added sugars and salt in their dietary guidelines . Lastly, it should be noted that the vast 
majority of packaged foods marketed in Uruguay contain added sugars, fats and sodium.  G/TBT/W/614  
 
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  5  CONFORMITY ASSESSMENT PROCEDURES  
69.  The conformity assessment procedures will be in line with the guidelines established by the 
Ministry of Public Health and which, in addition to Decree No. 272/018, are laid down in Ministerial 
Ordinance No. 160 of 1 1 February  2019. The procedure used by the competent bodies (Ministry of 
Public Health and departmental authorities) to authorize the marketing of packaged foods will be 
adapted to those guidelines, without distinction as to whether the products are domestic or imported . 
In this regard, and in keeping with the country's international commitments, the regulation does not 
distinguish between domestic and foreign products, nor does it take into account t he origin of the 
raw materials used or the place of their processing . It is purely a health measure that aims to 
improve eating habits on the basis of better decision -making by consumers and, therefore, covers 
all products falling within its scope, regardl ess of whether they are of domestic origin or imported.  
70.  A Handbook on the Application of Front -of-pack Labelling was prepared at the same time, setting 
out the procedure for determining whether a product should have a front -of-pack label and its correct 
application.  
6  DIFFERENCES BETWEEN THE DRAFT LAW AND DECREE NO. 272/018  
71.  The draft law does not establish the criteria for or the design of the front -of-pack label, as it is 
expected that, if it is adopted, those will be established in the regulation implementi ng the law, 
which will, in principle, be aligned along the same principles as Decree No. 272/018 . As indicated in 
Annex  IV, the criteria for applying a front -of-pack label are set forth in Annex II ; the criteria in 
Annex  III were included for informational  purposes and provide the reference values under the 
PAHO  nutrient profile model.  
72.  In short, the measure adopted under Decree No. 272/018 on front -of-pack labelling of packaged 
foods is justified and non -discriminatory, given that:  
• Uruguay is experiencing a n epidemic of overweight, obesity and NCDs.  
• There is sufficient evidence supporting the relationship between the consumption of foods 
excessive in fats, saturated fats, sugars and sodium and the development of the health 
problems targeted.  
• Front-of-pack la belling is one of the public policy measures recommended by PAHO/WHO to 
enhance consumers' understanding of the nutritional content of products and to promote 
healthy eating.  
• Evidence is available in Latin America on the effectiveness of a front -of-pack la belling system 
with characteristics similar to the one adopted in Uruguay.  
• It was developed according to a process consistent with good regulatory practices defined 
by the Pan American Health Organization.  
• A nutrient profile model was used as the basis for  determining the product categories 
amenable to front -of-pack labelling.  
• Products marketed in other markets were allowed to comply with the regulation through the 
use of stickers.  
• It applies to both domestic and imported products, and does not take into account the origin 
of the raw materials used or the place of their processing.  
__________