Implementing Regulation on the Front-of-Package Labelling Law

Implementing Regulation on the Front-of-Package Labelling Law

By Mariano Peruzzotti, María Luisa Santa María and Antonella Balbo.

On March 23, 2022, Decree 151/2022 (the “Decree”), which regulates the implementation of Law 27,642 on the Promotion of Healthy Eating, also known as the Front-of-Package Labelling Law, was published in the Official Gazette.

This new legislation provides, among others, the obligation to display nutritional information on food and non-alcoholic beverages, using a front-of-package warning label in the shape of a black octagon, to warn consumers of excesses of fat, sodium and sugar in these products (please see our previous report on Healthy Eating Law,

The most relevant aspects of the Decree are mentioned below:

  • The provisions of the Law cover both physical and online commercial premises or points of sale.
  • The maximum reference values for critical nutrients are set within the limits established by the Pan-American Health Organization Nutrient Profile. Said values indicate the maximum values allowed of sugar, sodium, saturated fat, total fat and calories, which will determine whether or not a product shall include a label.
  • According to the Decree, these maximum reference values will not be considered for foods for specific medical purposes, dietary supplements and formulas for children up to 36 months of age. Therefore, such products will also be exempt from displaying warning octagonal labels.
  • In order to obtain approval for product labelling, the obliged subjects must file a sworn statement with the Food and Drug Administration (by its Spanish acronym, ANMAT), through the National Foods Institute (INAL), informing the critical nutrients and calories in their products, as well as the presence of sweeteners and/or caffeine.
  • The enforcement authority will be the Ministry of Health.
  • According to the Decree, the obliged subjects must comply with the new provisions within 9 months, so that the term to adjust to the legislation will expire on August 21, 2022.  For SMEs, the term is 15 months. Therefore, the deadline to adjust will expire on February 21, 2023. An extension of another 180 days shall be granted on reasonable grounds in specific cases.

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