Lactose-free, ABC


After Have analyzed the rules – and reported abuses – on the wording gluten-free, è now by consider the theme lactose-free‘. Indication that the Ministry of Health allows on dairy products only and instead


it is also found on

the advertisements for



. L’

ABC of rules


Free from

‘, gluten and


The words ‘free from– on food labels-express the absence of certain substances (e.g. pesticide residues) or ingredients (e.g. GMO, palm oil). These are voluntary claims, generally without specific regulation and therefore subject to the general criteria of fairness and transparency of consumer information. (1)

Claims related to gluten and lactose
on the other hand, follow special rules, which derive from the former regulations for products intended for a special diet. (2) These rules address the need of certain vulnerable categories of consumers to receive accurate news, according to uniform parameters.

The absence or reduced content

of gluten and lactose
, consequently, can only be claimed on certain products, subject to special criteria expressing precise meanings. (3) Precisely because it is, the content of which cannot be left to the arbitrariness of individual operators.


‘, ‘


‘. What rules?


Ministry of Health
has clarified, in special circulars, the conditions for the use on the label of the words ‘
‘ e ‘
‘. Specifying first of all that such news is reserved for ”
Dairy and dairy products

Given the existing situation, given an also the parerand EFSA of 2010 and that of the Single Commission on Dietetics and Nutrition of June 12, 2015, the claim “senza lattosio” puCan be used for milk and dairy products with a residuor lower lactose a 0,1 g per 100 g o ml, in
waiting c
he the

European level.

To use the above indication, the products in question must bear the information on the label on the specific
soglia residual lactose with “less than” type mode. The threshold

be in any case


a 0,1g for 100g

Only for milks and fermented milks. puThe indication “reduced Iat contenttosio” if thel residuor disaccharide is
a 0
5 g per 100 g or ml. Labels of such products should state that it lactose content is

less than 0.5 g per 100 g or


To fo
accurate information ai consumers On the contents of “lactose-free” delactose-free products or “a reducedo Lactose content,” should be stated on the label anche an indication such as “iI

product contains glucose and galactose as a result of the cleavage of lact


The long aging of cheeses
– e.g. Parmigiano Reggiano, Grana Padano, Provolone Valpadana – in turn allows for significant reductions in their lactose content. Therefore, the Ministry of Health has clarified, including in relation to such products, how consumers should be informed.

In dairy products

in which the usual production process leads to the elimination or reduction of the lactose content, the following claims may be made on the label (under the same conditions as defined for delactose products):

1) “naturalmenlactose-free tea”(or equivalent expression) when the tenore residualor Lactose, to be reported on the label, é inferiore At 0.1 g/100 g;

2) “naturalmentand to reduced lactose content (or equivalent expression) when the tenore residualor lactose, to be reported on the label, and́ “inferiore at 0.5 g/100/g.”

For both
e of products should be stated on the label.

– that the absence of lactose or its reduced presence is a “natural” consequence of the typical manufacturing process by which the cheese in question is obtained;

– an indication such as “

contains gala




In the sole case of “naturally lactose-free” products, if it is deemed possible to quantify and guarantee una maximum residual threshold of galactose, pmay be used in altemative to the previous one a statement such as “contains galactose in an amount inferiorand to …” with a view to providing accurate information also for an eventualand usOr by galactosemics.(5)

Dario Dongo


(1) Refers to reg. EU 1169/11 (Articles 7 and 36) and the Unfair Commercial Practices Directive (dir. 2002/29/EC), implemented in Italy through the Consumer Code (d.lgs. 206/05) and d.lgs. 145/07. See also the previous article

(2) See dir. 2009/39/EC, repealed by reg. EU 609/2013

(3) And it is therefore completely inadmissible, for example, to report the absence of gluten on tea drinks. See the article



(4) Ministry of Health, DGISAN, Circular 7.7.15 (27673-P)

(5) Ministry of Health, DGISAN, Circular 16.6.16 (24708-P)

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.