“Forte” is a term commonly used in the labelling and advertising of food supplements. Most often, it forms part of a marketing name. It also appears as voluntary wording, independent of the product name.

According to the definition in a Polish dictionary, in the context of a medicinal product, “forte” means: “with an increased dose.” This is also confirmed by one of the communications issued by the President of the Polish Office for Registration of Medicinal Products (URPL), according to which “Forte” in the labelling of medicinal products denotes “a higher dose than previously registered.”

In the labelling and advertising of food supplements, “forte” is used to highlight characteristics similar to those of medicines.

But not only that.

“Forte” also appears on supplements where manufacturers want to emphasise that they have changed the formula by adding a new ingredient—and that the content of this new ingredient is intended to make the supplement “work more strongly” (i.e., have a stronger effect, hence “forte”).

A “stronger effect” is not the same as a higher content of an ingredient!

The term “FORTE”, regardless of whether it is intended to mean a “strong effect” of active ingredients or their increased content, when used in the labelling and advertising of a food supplement, falls under Regulation (EC) No 1924/2006 on nutrition and health claims, as well as Regulation (EU) No 1169/2011 on the provision of food information to consumers—and entails meeting a number of conditions.

When assessing whether “FORTE” can be used in supplement labelling, multiple elements should be verified:

• Is it a nutrition claim or a health claim?

• Why can “forte” not be used when certain health claims are used at the same time?

• Does it matter, for the legality assessment, if “forte” is part of the product name?

• How do the European Commission and selected Member States approach the possibility of using “forte”?

• What conditions must be met to use the term “forte”?

• How does the average consumer understand “forte”?

• How does the use of “forte” affect the borderline food–medicine classification?

• How to properly assess whether “FORTE” can be used lawfully?

We would be happy to address these questions within an advisory project or a training session.

Food labelling and advertising (including supplements and FSMP) are frequent topics of advisory projects and practical workshops delivered by IGI FOOD LAW.
Enquire about an advisory project or training: igifoodlaw@igifoodlaw.com

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