Health claims on freeze-dried fruit fall under Regulation (EC) No 1924/2006. A claim may reach the label only after the Commission has authorised the wording and the finished food meets the conditions of use attached to it.

Health claims on freeze-dried fruit sit under one regulation and one register

Regulation (EC) No 1924/2006 went into OJ L 404/9 on 30 December 2006. Article 10(1) states that health claims “shall be prohibited” unless the Commission has authorised them. So the default answer on any new recipe is no. Article 5(1)(a) adds a second condition. The nutrient must show a beneficial effect “as established by generally accepted scientific data”.

The regulation covers two categories, and teams mix them up. A nutrition claim says what the food contains. A health claim says what the food does. Article 8(1) allows a nutrition claim only when it appears in the Annex to the regulation. New Food Magazine counts 30 permitted nutrition claims, and they need no dossier. Health claims go through an EFSA assessment first.

Article 6 puts the burden on you. Claims rest on “generally accepted scientific evidence”, and the operator making the claim “shall justify the use of the claim”. Your supplier hands you data. The justification stays with the company whose name sits on the pack.

A nutrition claim turns on a threshold per 100 g

The Annex fixes the wording and the condition. “Source of [vitamin]” needs a significant amount, which Annex XIII, Part A of Regulation 1169/2011 sets at 15 % of the reference intake per 100 g. Beverages use 7,5 % per 100 ml. A single-portion pack may work per portion. “High in [vitamin]” needs twice the source value.

Run the arithmetic once and keep it. The reference intake for vitamin C is 80 mg, so a source claim needs 12 mg per 100 g. High doubles that figure. Potassium follows the same percentage rule, while fibre works on absolute grams. The table below holds the values you will reuse on every project.

Freeze-dried fruit passes the fibre threshold easily as an ingredient, because water removal concentrates everything left behind. That fact tempts people into the wrong conclusion. The number on your ingredient specification belongs to the ingredient. The claim belongs to the finished food.

Claim	Condition per 100 g	Worked value
Source of vitamin C	15 % of 80 mg	12 mg
High vitamin C	twice source	24 mg
Source of potassium	15 % of 2 000 mg	300 mg
Source of fibre	fixed in Annex	3 g
High fibre	fixed in Annex	6 g

Work the dose backwards from the wording you want

The threshold applies to the food as sold. So a bar, a yoghurt or a cereal has to reach 12 mg of vitamin C per 100 g on its own, whatever the powder analyses at. Start from the claim and solve for the dose.

Take a breakfast cereal at 3 % freeze-dried aronia powder. Suppose the certificate shows 200 mg of vitamin C per 100 g of that powder. On that assumption, the cereal gains 6 mg per 100 g from that source. That result sits below the 12 mg threshold, so the claim fails. Lift the dose to 6 % and the arithmetic works, provided nothing else in the process destroys the vitamin. Sensory limits and cost usually decide whether 6 % is realistic, so hold that conversation during analytical support during recipe development, well before artwork.

Two more constraints follow from the same calculation. First, the claim has to hold across the whole shelf life of the finished food, including the last day. Second, the value has to hold across batches of raw material. Both make a specification minimum the safer entry, because a typical value carries no obligation.

Document the calculation while you run it. Record the assumed content of the powder, the dose in the recipe, the resulting value per 100 g of the finished food and the threshold you compared it against. An inspector who questions the claim asks for exactly that chain. Rebuilding it two years later from memory costs far more than writing one page today.

Which health claims on freeze-dried fruit are authorised today

Commission Regulation (EU) No 432/2012, OJ L 136/1, carries the list. Article 1(1) puts the permitted claims in the Annex, and Article 1(2) ties their use to the conditions there. The wording is fixed. You may adapt it for the consumer, yet the meaning has to stay the same.

Most entries relevant to fruit powders run through vitamins and minerals. Vitamin C carries claims such as “vitamin C contributes to normal collagen formation for the normal function of blood vessels” and “vitamin C increases iron absorption”. Potassium carries “potassium contributes to the maintenance of normal blood pressure” and “potassium contributes to normal muscle function”. Each one repeats the same condition: the food has to be at least a source of that nutrient. So the threshold from the previous section controls the health claim as well.

The list moves slowly. FoodNavigator reports that the 2012 list “has only been amended 16 times since then”, with a July 2025 amendment on kiwifruit and bowel function. New Food Magazine puts the running total at more than 3 000 claims evaluated by EFSA and roughly 270 authorised. EFSA checks “the scientific substantiation of the submitted claims” before the Commission decides.

Antioxidant and immunity fail on Article 10(3)

Article 10(3) allows a “reference to general, non-specific benefits” only when a specific authorised claim accompanies it. Words like antioxidant, detox, immunity and wellbeing fall into that group. On their own they break the rule. Next to an authorised vitamin C claim they pass, because the specific claim carries the meaning.

Article 12 rules out three further constructions. A claim may not suggest that health suffers without the food. Nor may it refer to the rate or amount of weight loss. The third ban covers references to an individual doctor or an unapproved professional body. Marketing copy trips over the first of these more often than R&D expects.

Article 7 adds a labelling duty that people forget. When a claim appears, the nutrition declaration becomes mandatory. A substance named in the claim but absent from that table goes in the same field of vision, in the same units. So a potassium claim puts potassium on the label even though the mandatory table covers only energy, fat, saturates, carbohydrate, sugars, protein and salt.

Botanical claims stay on hold, and the file has to say so

Claims built on plant extracts wait for an assessment that has not resumed. New Food Magazine counts about 1 548 botanical claims “for which finalisation is pending”. FoodNavigator describes EFSA’s suspension of systematic assessment of these dossiers as continuing to this day. Article 28(5) and 28(6) of Regulation 1924/2006 let operators keep using such claims while evaluation runs.

That transitional status works today, though it can end at short notice. A decision can arrive and remove the wording from your artwork after a short grace period. So treat any botanical claim as temporary. Record the register entry number in the product file, review it at every artwork revision, and keep a fallback wording that rests on an authorised vitamin or mineral claim.

Recent decisions show the pace. NutraIngredients reports a positive opinion in 2026 on oat beta-glucans and postprandial glucose peaks, alongside negative opinions on creatine and Echinacea angustifolia. The same round-up notes that EFSA has evaluated more than 2 300 health claims and rejected more than 70 % of applications.

What your supplier must deliver to support health claims on freeze-dried fruit

Ask for four things before you write anything on artwork. Start with a batch value for the nutrient, expressed per 100 g of the powder. Second comes the analytical method behind that value. Then ask for the spread across recent batches, so one flattering figure cannot stand for the whole delivery. Finally, tie the result to real material through a date and a batch number.

Then convert the range into a contract. Put a minimum in the specification and agree that deliveries below it get rejected. A typical value collapses once an inspector asks how you justified the claim under Article 6(2). Grades matter here as well, since particle size and the presence of skin change the analysis. For aronia the choice between powder and pieces is a real decision, and the freeze-dried aronia grades and particle sizes page shows what that means in practice.

Water content deserves a line of its own in that file. Freeze-dried material picks up moisture from the air, so a hygroscopic powder that sat open on a bench analyses differently from sealed material. Agree with your supplier which moisture basis the certificate uses. Then check that your own laboratory reports on the same basis, since a mismatch here shifts every nutrient value in the file.

Keep the same discipline for the finished product. Analyse the food itself at least once per formulation, so the calculation gains an experimental check. Recipes that sit near the threshold need a wider margin, because process losses and analytical tolerance both reduce it. Products with a long shelf life need a stability point as well, so schedule one at the end of the declared life.

Export markets read the same wording differently

Codex Alimentarius applies the same logic with a wider set of options. The Guidelines for Use of Nutrition and Health Claims allow a source claim at 15 % of the NRV per 100 g for solids, 7,5 % per 100 ml for liquids, 5 % per 100 kcal, or 15 % per serving. High doubles the source value. Markets that build on Codex therefore accept a per-serving route that the EU rules do not offer for a multi-portion pack.

Plan the label set early when one recipe ships to several regions. A cereal bar that qualifies per serving may still fail per 100 g, so the artwork splits into two versions. The freeze-dried ingredients for bars and snacks category shows how often the same base recipe travels across markets. Keep the claim decision and the dose decision in one document, because separating them is how a compliant recipe turns into a non-compliant label. SALESWAVE confirms analytical values and methods for a specific batch, once the scope of documentation is agreed at specification stage.

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