A first-time own-brand drink powder project usually hits the same snag at artwork stage. The nutrition panel comes back and the sugar figure is enormous. Somebody asks whether the producer got it wrong, the producer confirms it is correct, and the launch stalls while the brand works out whether it has a product problem or a labelling problem.
It is almost always a labelling problem, and EU law already provides the answer.
Why the number looks wrong
Per 100 g of powder is not a serving. It is roughly ten servings of a concentrate with the water taken out. Sugar and energy per 100 g of powder are therefore several times what the consumer actually drinks in a cup, and the figure sits on the pack next to ready-to-drink competitors whose per-100 ml values were never comparable in the first place.
Nothing about that figure is inaccurate. It is simply describing a state of the product that nobody consumes, and a shopper comparing it against a chilled drink on the next shelf draws a conclusion that is wrong in substance while being arithmetically sound.
The provision that solves it
Article 31(3) of Regulation (EU) No 1169/2011 allows the nutrition information to relate to the food after preparation, provided sufficiently detailed preparation instructions are given and the information relates to the food as prepared for consumption.
Read the condition carefully, because it is the operative part and it is the part that gets skipped. The as-prepared basis is not a free choice; it is permitted on the basis that the pack tells the consumer how to prepare the food in a way that produces the declared drink. If the instructions are vague, the declaration describes something the consumer did not make, and the permission it rests on has not really been satisfied.
What "sufficiently detailed" has to mean in practice
The working test is reproducibility. Can a consumer, following the pack, make the drink whose values are declared?
"Mix with milk" fails that test. How much powder, how much milk, and which milk are all left open, and each materially changes the outcome. "Stir 20 g of powder into 200 ml of semi-skimmed milk" passes it: the quantities are fixed, the liquid is specified, and the declared values describe a drink the consumer can actually produce.
This is also where the liquid question becomes unavoidable. For a hot chocolate or salep-style base intended for milk, the declared as-prepared values depend entirely on the milk, which in most such products contributes more of the energy, fat and sugar than the powder does. A declaration cannot honestly cover both a water preparation and a whole-milk preparation, because those are nutritionally different foods. The instructions have to pick one, and the panel follows the instructions rather than the other way round.
Choosing the basis deliberately
Neither basis is correct in the abstract, and this is a commercial decision informed by a legal constraint rather than a purely legal one.
An as-prepared declaration is more meaningful to a consumer, avoids an alarming headline figure, and makes the product comparable with ready-to-drink alternatives. An as-sold declaration is simpler, requires no assumptions about preparation, and makes the product comparable with other powders — which is what a shopper in that aisle is usually doing.
Two practical rules matter more than the choice itself. State the basis unambiguously on the pack, so nobody has to infer it. And keep it consistent across a range: a line where the cocoa powder declares as prepared and the fruit powder declares as sold invites exactly the comparison that makes one of them look bad, and the inconsistency is entirely self-inflicted.
Responsibility, and what to ask the supplier for
The declaration belongs to the food business operator under whose name the food is marketed. On an own-brand programme that is the brand owner, not the powder producer.
What the brand owner should request, early, is composition data sufficient to calculate or substantiate both bases, together with the analysis method used. Asking for it at artwork stage is what turns a two-day question into a three-week one, because the producer then has to go back and generate figures they were never asked to produce.
TeraVella works in beverage powders as a sourcing partner rather than a manufacturer — we do not operate our own beverage-powder plant. Our part is verifying a producer against your brief and making sure composition and specification, including the data behind a nutrition declaration, are written down before production rather than chased afterwards. The declaration itself, and the preparation instructions it depends on, remain the brand owner's responsibility, and we say so plainly rather than letting it blur. Volumes, formats and prices are confirmed at quotation.
