Operational question for supplement and functional-food brands: may the authorised green-kiwifruit bowel-function claim be used on food supplements, powders, juices or dried kiwi — or only on fresh Hayward green kiwi meeting the 200 g flesh condition? Answer from the act: fresh green kiwifruit only, sold as such or merely peeled and/or cut, providing a minimum of 200 g flesh, with information on a daily intake of 200 g. CELEX 32025R1560.
1. What does the act do?
Commission Implementing Regulation (EU) 2025/1560 of 30 July 2025 (OJ L series 2025/1560, 31.7.2025; ELI: eli/reg_impl/2025/1560/oj; EUR-Lex: CELEX 32025R1560):
- Article 1 — the Annex claim is included in the Union list of permitted claims under Art. 13(3) of Regulation 1924/2006;
- Article 2 — the Annex to Regulation (EU) No 432/2012 is amended accordingly;
- Article 3 — the Regulation enters into force on the twentieth day following OJ publication → with publication on 31.7.2025, that is 20 August 2025.
Legal base: Art. 18(4) of Regulation (EC) No 1924/2006. Applicant: Zespri International Limited (Art. 13(5); EFSA-Q-2020-000562).
2. EFSA opinion ≠ Commission authorisation
On 11 June 2021 EFSA published its opinion (EFSA Journal 2021;19(6):6641; DOI 10.2903/j.efsa.2021.6641): a cause-and-effect relationship was established between consumption of green kiwifruit (var. Hayward) and maintenance of normal defecation; target population — the general population. The Panel’s scientific wording concerned maintenance of normal defecation, with about 200 g of flesh (two large fruits).
Recital (9): after a request for more consumer-friendly wording, the Authority confirmed that “Consumption of green kiwifruit contributes to normal bowel function by increasing stool frequency” reflects the evidence.
EFSA opinion ≠ market authorisation of the claim. Only the Commission implementing regulation places the claim on the 432/2012 list with conditions of use. Recital (10): the Panel noted that no conclusions could be drawn for substantiation from studies on foods other than fresh green kiwifruits — decisive for powders and extracts.
3. Annex conditions of use (432/2012)
| Field | Act text |
|---|---|
| Food | Green kiwifruit (Actinidia deliciosa “Hayward”) |
| Claim | Consumption of green kiwifruit contributes to normal bowel function by increasing stool frequency |
| Conditions of use | Only for: (i) fresh green kiwifruits sold as such, or (ii) fresh green kiwifruits which have only been peeled and/or cut providing a minimum of 200 g of kiwi flesh. Information shall be given to the consumer that the beneficial effect is obtained with a daily intake of 200 g of fresh green kiwi flesh. |
| EFSA Journal | 2021;19(6):6641 |
4. What this means for supplements and processed kiwi
For B2B supplement / functional-food operators, this Union-list entry does not unlock the claim on:
- food supplements (capsules, tablets, “kiwi fibre” powders, extracts);
- juices, smoothies, concentrates “with kiwi” as such;
- dried kiwi, chips, bars with dried fruit — unless the food literally meets fresh-fruit conditions (i) or (ii).
Novel-food or additive status is irrelevant here: claim use is gated by 1924/2006 + the 432/2012 conditions. Broader bowel-claims survey (with a kiwi mention): constipation / intestinal transit — EU health claims; claims hub: health claims and food supplements.
5. Contrast: other bowel-related 432/2012 entries
Not every bowel claim is “fresh fruit only”. Examples from the consolidated 432/2012 list:
- Lactitol — normal bowel function by increasing stool frequency; typical condition: 10 g in a single daily portion (with restrictions for foods for children). That structure can cover portioned matrices, including supplements, if the entry conditions are met.
- Lactulose — acceleration of intestinal transit; 10 g in a defined single portion.
- Chicory inulin — normal bowel function; 12 g/day of native chicory inulin (with characterisation criteria).
The 2025/1560 kiwi entry is therefore narrower: matrix = fresh Hayward fruit, not “kiwi ingredient in any form”.
6. Operator checklist
- Is the product fresh green Hayward kiwi (as such or only peeled/cut) providing ≥200 g flesh?
- Is the 200 g daily fresh-flesh information present for the consumer?
- Does the wording match the authorised claim (or an equivalent non-stronger wording)?
- If it is a supplement / powder / juice / dried product — do not use the 2025/1560 entry; consider other 432/2012 entries or no claim.
- Keep FIC labelling; for supplements, national notification remains separate; additive/novel-food status does not unlock claims.
Glossary
- Art. 13(5) 1924/2006
- Application route for claims based on newly developed scientific evidence (here: Zespri → EFSA → Commission).
- List 432/2012
- Union list of permitted health claims other than disease-risk reduction and children’s development and health.
- Hayward
- Green kiwifruit variety (Actinidia deliciosa) that is the subject of the EFSA opinion and the Annex entry.
- 200 g flesh
- Quantitative condition in the Annex (and EFSA: about two large fruits) — mandatory consumer information.
Conclusion
From 20 August 2025, Regulation (EU) 2025/1560 allows communication that consumption of green kiwifruit contributes to normal bowel function by increasing stool frequency — only on fresh Hayward fruit meeting conditions (i)/(ii) and with the 200 g daily-flesh statement. For supplement and processed-kiwi brands, this entry is not a green light. EFSA 6641 supports the science; the Commission sets the list conditions under 432/2012.
Primary sources
- Commission Implementing Regulation (EU) 2025/1560 — CELEX 32025R1560; ELI eli/reg_impl/2025/1560/oj; OJ 31.7.2025; EIF 20.08.2025.
- Commission Regulation (EU) No 432/2012 — permitted health claims list (as amended).
- EFSA NDA Panel 2021 — green kiwifruit and maintenance of normal defecation (DOI 10.2903/j.efsa.2021.6641; Journal 2021;19(6):6641; EFSA-Q-2020-000562).
- Regulation (EC) No 1924/2006 — nutrition and health claims.
- EU bowel / transit claims survey (context; this piece = deep dive on 2025/1560).