CLEAR CHECK

COPY ∙ LABELLING ∙ EDUCATION ∙ ADVERTISING ∙ REGULATION

hfma clearcheck logoCLEAR CHECK can help you navigate the regulatory minefield in one of the world’s most complex industries.

Hundreds of companies each year receive specialist, and highly cost-effective, advice and HFMA member companies enjoy beneficial hourly rates.

  • Publicity, advertising and promotion are vital to the successful marketing of specialist health products – but, the regulatory framework is highly complex
  • There are detailed and specific requirements for the various different categories of specialist health product – foods, food supplements, herbal and homoeopathic products, cosmetics, etc.
  • Failure to tailor labelling, advertising and promotional material to UK regulatory requirements is a certain route to market failure
  • CLEAR CHECK’s aim is to achieve the maximum marketing advantage for the product within the law – and in particular the maximum permissible information to the consumer
  • Amongst a broad range of services, CLEAR CHECK offers a procedure for reporting non-compliant non-member companies to enforcement authorities; it can liaise with other EHPM member Secretariats to provide market specific advice from other EU member states; it can provide tailored training, on (or off) site.

CLEAR CHECK’s Code of Practice Administrators have over 50 years of combined experience offering advice to companies seeking help with understanding the complexities of the regulatory minefield before them and administrating the HFMA’s Code of Advertising Practice.

  • Gwyneth Massey BSc (Hons) Biochemistry, MRSB, CBiol
  • Dr Katie Burren PhD Neural Development and BSc (Hons) Biochemistry
  • Esther Mills-Roberts BSc (Hons) Nutritional Biochemistry
Service Fee
HMFA Member £82.00 per hour + VAT (minimum invoice value £30.00 + VAT)
HFMA Non-Member £155.00 per hour + VAT (minimum invoice value £50.00 + VAT)
Telephone Enquiries First 10 minutes (5 minutes for non-members) of initial enquiries are not chargeable. After that, the hourly rate applies.

Service required at very short notice may attract a £50.00 + VAT surcharge. Please contact the Administrators for further details.

Invoices are submitted monthly and must be settled within 30 days. First time users of the service will require pre-payment via pro-forma invoice.

CLEAR CHECK aims to return comments within 7 working days, but this can increase during times of heavy work load or during staff holidays’

If you would like more information, please do not hesitate to Contact Us.

HFMA CLEAR CHECK is an accredited compliance service

Surrey and Buckinghamshire Trading Standards, who are the HFMA’s Primary Authority, have assessed the CLEAR CHECK service for its food standards support and concluded:

“… that their activities are organised to ensure … a high level of quality in compliance services which include: advice; checks on labels and advertising; and training.”
Furthermore, concluding:

“The quality level has been independently reviewed and in our opinion is likely to provide users of those services with a defence of ‘having taken all reasonable precations and exercised all due diligence’…”

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primary authority partnership with buckinghamshire & surrey trading standards logo

Review Procedure Information

hfma clearcheck logoProcess and scope of review

The material submitted is reviewed by a Code Administrator for compliance with the principles of the HFMA Code of Advertising Practice, with reference to:

  • the relevant labelling or advertising regulations
  • the terms of the marketing authorisation or product licence/registration, where applicable
  • government and industry guidelines
  • other relevant codes of practice

Advice on any required/recommended alterations is then provided.  Where available, the Code Administrator will provide guidelines and checklists on subjects relevant to the material submitted.  In the case of issues not clearly defined in the regulations, current industry practice and the current approach of the authorities are taken into account to determine the suitability of a proposal.

Note that the following areas are outside the scope of the Code and are not routinely considered as part of the review:

  • accuracy and efficacy of formulation, except in relation to appropriateness of claims
  • the safety of ingredients and finished product
  • the accuracy of declared quantities in final product
  • the accuracy of GM status claims and other negative-presence claims
  • the determination of novel ingredient/food status
  • the content of any referenced websites, publications or similar [separate review of these materials can be carried out]

Agreement and the review stamp

When agreement has been reached on suitable copy, the copy is returned stamped with a reference number.

The review stamp conveys compliance with the principles of the HFMA Code of Advertising Practice and is provided based on current scientific opinion and current regulatory and industry practice.  Until a body of case law has been built up to form the basis of an authoritative statement, advice on the law and application of the regulations can be given as informed opinion only.

The copy should be resubmitted for review every two years if it is still in use.  At times, changes in the law, codes of practice or interpretation may necessitate an earlier review.

The review stamp does not constitute an endorsement or approval of the product or services offered, nor should it be regarded as a guarantee of the legality of the product.  It remains the responsibility of the manufacturer/supplier/importer to ensure that the product placed on the market meets its claims.

If you would like more information, please do not hesitate to Contact Us.

HFMA CLEAR CHECK is an accredited compliance service

Surrey and Buckinghamshire Trading Standards, who are the HFMA’s Primary Authority, have assessed the CLEAR CHECK service for its food standards support and concluded:

“… that their activities are organised to ensure … a high level of quality in compliance services which include: advice; checks on labels and advertising; and training.”
Furthermore, concluding:

“The quality level has been independently reviewed and in our opinion is likely to provide users of those services with a defence of ‘having taken all reasonable precations and exercised all due diligence’…”

accredited compliance services badge
primary authority partnership with buckinghamshire & surrey trading standards logo

Guidelines and Helpnotes Information


Guidelines and helpnotes are compiled by CLEAR CHECK and the Advisers of the HFMA as an aid to understanding the requirements of relevant legislation.

Guidelines Available to Non-Members:

Guidelines Available to HFMA Members:

  • Allergen labellinghfma clearcheck logo
  • Best practice standard for food supplements providing bacterial strains
  • Calculation of vitamins EC Regulation on Nutrition and Health Claims
  • Composition of food supplements
  • Contaminants in food supplements
  • EU Food Information to Consumers Regulation
  • Flavourings, definitions, use of natural
  • Food additives categories, FIC Annex VII Part C
  • Food labelling
  • Food labelling versus food supplement labelling
  • Food law definitions (selection)
  • Food supplements, claims
  • Food supplements, consumer advertising reminders
  • Food supplements ingredients listing & product information layout
  • Food supplements labelling
  • Foods for sportspeople
  • Foods with added vitamins, minerals & other substances
  • Free from claims
  • GM Free & non-GMO claims
  • HFMA guidelines for maximum nutrient supplement levels
  • Ingredients listing, foods & food supplements
  • Labelling statements relating to absence or reduced presence of gluten
  • Labelling of glucosamine containing food supplements
  • Labelling of food supplements providing phytosterols-phytostanols
  • Labelling requirements for six artificial colours
  • Mandatory & voluntary label statements & cautions, food supplements
  • MHRA final determination and urgent notices
  • Minimum font size EU Reg 1169/2011
  • Nutrient definitions for nutrition labelling
  • Nutrition labelling energy conversion factors
  • Nutrition Labelling for Food
  • Omission of certain ingredients from an ingredients list
  • Vitamin & mineral advisory statements for food supplements
  • Vitamin & mineral reference intakes (NRVs)
  • Vitamin A levels in food supplements
  • Vitamins, minerals & sources permitted in food supplements
  • Quantity marking
  • Herbs in the UK THR registrations
  • Cosmetic products
  • Access to information, EU UK legislation
  • Access to information, UK Legislation

Access to information, useful web links

If you would like more information, please do not hesitate to Contact Us.

HFMA CLEAR CHECK is an accredited compliance service

Surrey and Buckinghamshire Trading Standards, who are the HFMA’s Primary Authority, have assessed the CLEAR CHECK service for its food standards support and concluded:

“… that their activities are organised to ensure … a high level of quality in compliance services which include: advice; checks on labels and advertising; and training.”
Furthermore, concluding:

“The quality level has been independently reviewed and in our opinion is likely to provide users of those services with a defence of ‘having taken all reasonable precations and exercised all due diligence’…”

accredited compliance services badge
primary authority partnership with buckinghamshire & surrey trading standards logo

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