How Colombia's front-of-pack warning labels are calculated (Res. 810/2021)
Ketchup gets a sugar warning label, and it's not a sweet product. Here's how Colombia's thresholds work, and the traps that show up when you reformulate.
Ketchup carries a sugar warning label, yet nobody buys it thinking it's a sweet product. That case sums up how front-of-pack warning labeling works in Colombia: the labels don't measure taste or intent, they measure proportions. Understanding those proportions is what lets you design a product without surprises.
The reference regulation is Resolution 810 of 2021, amended by Resolution 2492 of 2022, issued by Colombia's Ministry of Health and Social Protection.
The sugar label measures a fraction, not sweetness
The "Excess sugars" label is triggered when free sugars provide 10% or more of the product's total calories.
A ketchup has about 90 to 100 kcal and roughly 22 g of sugars per 100 g. Those 22 g provide about 88 kcal: more than half of the product's energy comes from sugar. And it's there to balance the acidity of the tomato and add body, not to sweeten.
The denominator trap
Because the criterion is a percentage, anything that changes total calories moves the result. Cut the fat and you cut total kcal. With the same sugar and a smaller denominator, the percentage goes up. Some reformulations have triggered the label precisely while "improving" the product.
The sodium label: two thresholds, crossing one is enough
For solid foods, the "Excess sodium" label is triggered if either of these two conditions is met:
- Amount: 300 mg or more of sodium per 100 g.
- Density: 1 mg or more of sodium per kcal.
Both exist because each one catches what the other lets through:
| Product (per 100 g) | Amount criterion | Density criterion | Result |
|---|---|---|---|
| Snack: 500 kcal and 400 mg sodium | 400 mg, above 300 | 0.8 mg/kcal, passes | Gets the label |
| Soup: 50 kcal and 200 mg sodium | 200 mg, passes | 4 mg/kcal, above 1 | Gets the label |
| Product: 400 kcal and 299 mg sodium | 299 mg, passes | 0.75 mg/kcal, passes | No label |
The gap the regulation doesn't cover
The third product has 50% more sodium than the soup and carries no label. That's not a flaw in the regulation: it's the unavoidable consequence of setting any threshold. And it's exactly the zone where formulations end up when the project goal is "get rid of the label" instead of "reduce sodium." They are two different goals, and it pays to define the real one from the start.
It's evaluated per 100 g, not per serving
The criteria are calculated per 100 g (or 100 mL for liquids). Reducing the declared serving size doesn't change the label outcome.
Sweeteners: swapping one label for another
Sweeteners trigger the "Contains sweeteners" label at any amount. Removing the sugar label by replacing sugar with sweeteners doesn't remove a label: it swaps it for another one. We explain the alternatives for reducing sugar without falling into this in how to reduce sugar in food.
Front-of-pack labeling is calculated in the first iteration
The practical lesson is simple: front-of-pack labeling isn't reviewed at the end of the project, when the formula, packaging and supplier are already set. It's calculated from the first formula iteration, together with the nutrition facts table, so every ingredient decision is made knowing its effect on the labels. If your product is already on the market and you want to remove labels, read our article on reformulating to remove warning labels.
This article is for information only and doesn't replace reading the regulation in force or regulatory advice for each product.
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