“High Protein” and “Low Sugar”: The Ultimate EU Food Labelling Guide

One of the biggest mistakes a new food company can make is adding attractive-sounding messages to its packaging without checking what they legally mean.

“High protein.” “Low sugar.” “Supports your gut.” “Boosts immunity.” “No added sugar.”

These phrases may sound like ordinary marketing. They can make a product easier to understand, more attractive on a shelf, and more competitive online. But they are not statements a food business can simply add because the product seems healthy or contains a fashionable ingredient.

Under EU food law, many of these messages are regulated claims. Some require the product to reach a minimum amount. Others require it to remain below a fixed limit. Health-related messages must correspond to an authorised relationship between a food or nutrient and health and meet additional conditions.

Getting the wording wrong can mean changing finished artwork, reprinting packaging, removing advertising, losing a retailer listing, delaying a launch, or facing enforcement action.

The good news is that claims such as “high protein” and “low sugar” can be checked before you print your packaging.

The rules at a glance

You can use “high protein” when at least 20% of the food’s total energy value is provided by protein.

You can use “low sugar” when the product contains no more than:

• 5 g of sugars per 100 g for solid foods; or
• 2.5 g of sugars per 100 ml for liquids.

These conditions appear in the Annex to Regulation (EC) No 1924/2006 on nutrition and health claims made on foods. They also apply to wording likely to have the same meaning for consumers.

Meeting the number is essential, but it is not the only check. The product data, the nutrition declaration, wording, and overall presentation must also be accurate and not misleading.

Nutrition claims and health claims: what is the difference?

“High protein” and “low sugar” are nutrition claims. A nutrition claim describes a beneficial nutritional property of a food—for example, the energy it provides or the amount of protein, sugar, fibre, fat, vitamins, or minerals it contains.

Permitted nutrition claims and their conditions are listed in the Annex to Regulation (EC) No 1924/2006. A business cannot invent its own definition of “high,” “low,” or “free.” It must meet the condition attached to the permitted claim or wording with the same meaning.

A health claim states, suggests, or implies a relationship between a food, nutrient, or substance and health. Examples include authorised statements about vitamin C and normal immune-system function or protein and the maintenance of muscle mass.

Health claims must be authorised and used under their applicable conditions. The main list appears in Regulation (EU) No 432/2012, and the European Commission’s EU Register provides a searchable reference.

The practical distinction is simple: a nutrition claim requires a compositional check; a health claim requires an authorised health relationship plus every applicable condition.

A verified €250,000 food-claims fine

In September 2014, the Italian Competition Authority announced a €250,000 fine against Named S.p.A. over advertising for the food supplement Immun’Age.

According to the authority, the campaign appeared in print, radio, television, and on a dedicated website. It communicated alleged effects relating to serious diseases, influenza, colds, cellular ageing, vaccination, and states of debilitation.

The authority found numerous parts of the campaign misleading. It reported that the advertised benefits lacked the necessary scientific validation and authorisation and presented the supplement as having effects normally associated with medicines.

This was a health-benefit case rather than a dispute about the numerical “high protein” or “low sugar” thresholds. It nevertheless shows why a food business must assess its complete commercial message—not only the nutrition table.

What can happen when a claim is incorrect?

Enforcement and penalties operate through national systems, so the consequences depend on the country and circumstances. They can include:

• removing or changing the claim;
• reprinting packaging;
• stopping advertising;
• delaying a product launch;
• losing retailer or distributor approval;
• withdrawing affected stock;
• fines, legal proceedings, or competitor action.

For a startup, the largest immediate cost may be unusable packaging, lost launch time, and marketing that must be rebuilt.

The €250,000 Italian fine is not a standard EU-wide penalty. It is an example of what enforcement can look like in one jurisdiction and set of circumstances.

When can you call a food “high protein”?

A food may carry a “high protein” claim only when at least 20% of its total energy value is provided by protein.

The number of protein grams alone is not enough. Two products containing the same grams of protein can reach different results because their total energy values differ.

“Source of protein” has a lower threshold: at least 12% of the food’s energy value must come from protein.

Use the final product specification and declared energy value when assessing the claim. Do not rely on an early recipe, a supplier’s marketing material, or a competitor’s packaging.

When can you call a food “low sugar”?

The “low sugar” test depends on whether the product is a solid or a liquid.

A solid food may use “low sugar” only when it contains no more than 5 g of sugars per 100 g. A liquid may use the claim only when it contains no more than 2.5 g per 100 ml.

The liquid threshold is half the solid-food threshold. Applying the 5 g limit to a drink can lead to an incorrect claim.

“Low sugar” refers to total sugars

For a “low sugar” claim, the relevant value is total sugars—not only refined sugar or sugar deliberately added during production.

A product does not become low sugar merely because:

• it contains fruit instead of table sugar;
• its sweetness comes from juice concentrate;
• its sugars occur naturally;
• no white sugar was added;
• the recipe is perceived as healthy.

Those facts may matter for a different claim, such as “no added sugar,” but they do not replace the total-sugars threshold for “low sugar.”

Low sugar, sugar-free, and no added sugar are different

A product can contain naturally occurring sugars and potentially use “no added sugar” when all applicable conditions are met. That does not automatically make it low sugar.

Likewise, a product may meet the low-sugar threshold even if a small quantity of sugar was added. The claims answer different questions.

Check your proposed food claims—free

rukola helps identify potential compliance risks before they turn into expensive packaging changes, delayed launches, or retailer problems—so you can spend less time untangling regulatory requirements and more time building your product.

Paste your packaging text, nutrition values, ingredients, product name, badges, or webshop copy into our free EU food-claims checker. It can help flag wording that appears supportable, wording that may be risky, and information that needs further review before your artwork is printed or your product goes live.

The checker provides informational compliance screening. It does not certify a label, guarantee compliance, or replace product-specific legal or regulatory advice.

Frequently asked questions