The Association of Non-Alcoholic Beverage and Juice Producers of Uzbekistan (UzBev), which brings together 12 major soft drink producers, has commented on a draft Cabinet resolution that would introduce mandatory sugar-content warnings on beverage packaging. UzBev Executive Director Alfiya Musina told Spot.
The association does not oppose informing consumers, but believes the proposed system is not yet sufficiently justified and could create an additional burden for manufacturers. UzBev said decisions in this area should be “balanced, scientifically justified and fair”.
What the government proposes
The draft resolution was published on the regulation.gov.uz portal for public discussion, which will continue until October 14.
From January 1, 2027, front-of-pack labels would be introduced for domestically produced and imported soft drinks based on their sugar content per 100 ml. For beverages containing 5−8 g of sugar, packaging would carry the warning “MEDIUM SUGAR CONTENT” in black on a yellow background.
For drinks containing 8−11 g of sugar, the proposed warning would read “HIGH SUGAR CONTENT” in black on an orange background. For beverages containing 11 g or more, packaging would carry the warning “VERY HIGH SUGAR CONTENT — FREQUENT CONSUMPTION IS HARMFUL TO HEALTH” in white on a red background.
The warning would have to cover at least 15% of the front of the package. The proposal also calls for a QR code providing information on the product’s ingredients, calorie content and recommended daily intake.
The draft provides for a unified system to register and monitor such products. A common laboratory testing methodology is planned to be approved by March 2027, while accredited laboratories would begin determining sugar content by September.
By December 2027, a digital monitoring platform for soft drinks with high sugar content is proposed. It would be integrated with the Asl Belgisi digital labeling system and the Tax Committee’s information systems. The platform would contain data on the amount of sugar and types of sweeteners in each product.
For imported beverages, electronic declaration of sugar content is proposed to be introduced by January 1, 2028. The Customs Committee would also be authorized to prevent the import of products that do not meet the new labeling requirements.
In addition, a phased restriction on the sale of labeled beverages that do not comply with the new requirements in educational institutions could begin on January 1, 2027. The draft also provides for regular test purchases and publication of information on identified violations.
Why UzBev considers the approach problematic
One of the association’s main objections is that the new requirements are proposed specifically for non-alcoholic beverages, even though sugar is also found in many other food categories.
UzBev notes that confectionery, baked goods, dairy desserts, ice cream, sauces and other products are also sources of sugar for consumers. At the same time, public health concerns are linked not only to sugar consumption but also to salt, saturated and trans fats, overall calorie intake and physical activity levels.
According to the association, if warning labels appear only on beverages, consumers may mistakenly assume that other products without similar warnings are automatically healthier.
“If the government’s goal is to help people make informed choices, the approach should cover all relevant food categories and take the overall diet into account, rather than focusing on a single industry”, UzBev said.
The association also noted that manufacturers are already adapting to digital labeling requirements. According to UzBev, companies continue to spend money on system configuration, employee training, equipment upgrades and resolving technical issues, while databases among key market participants have yet to be harmonized.
Against this backdrop, the new requirements would entail additional costs, packaging changes and new administrative procedures. UzBev also pointed to repeated changes in the tax burden on sugar-sweetened beverages in recent years and called for greater regulatory predictability.
Methodology to be introduced after the requirements take effect
Manufacturers also have concerns about the timing of the new rules.
Under the draft, labeling requirements are scheduled to take effect on January 1, 2027, while the methodology for determining the relevant product indicators is not expected to be developed until March 2027.
UzBev believes this could leave businesses in a situation where the requirements are already in force while the criteria for compliance have not yet been approved.
“This creates a paradoxical situation: businesses are required to comply with requirements whose criteria have not yet been approved”, the association said.
Manufacturers therefore question how sugar content should be determined before the official methodology is introduced, which laboratory test results will be considered valid, what deviations will be permitted and how disputed cases will be resolved.
UzBev also noted that, in its assessment, the technical regulation on food labeling has not yet been finalized. The association believes that unified rules should be established first, followed by the introduction of mandatory requirements.
Manufacturers will need to change packaging
Another concern relates to the timeline for switching to the new labeling system.
UzBev notes that changing a label is not a quick administrative process but part of the production cycle. Designing, approving layouts, preparing production molds and launching new packaging can take several months. According to the association, preparing a new label alone takes at least three months on average.
Labels and aluminum cans are also purchased in advance, with inventories potentially built up for about a year. Without a sufficient transition period, companies would either have to destroy already-produced packaging materials or incur additional costs for urgent design changes.
UzBev calls for a study of dietary patterns first
The association also questions the scientific basis of the proposed regulation. It believes that data on the population’s actual dietary patterns should be obtained before specific sugar-content thresholds are introduced.
In particular, it proposes determining which products are the main sources of sugar and salt and which factors actually pose the greatest health risks.
“Only a large-scale study of the population’s diet can answer these questions”, UzBev said.
According to the association, without such data it is impossible to objectively assess which measures would actually help improve people’s diets and which would mainly create additional administrative burdens.
At the same time, UzBev does not reject the idea of informing consumers. The association believes packaging information should help people make informed decisions, be clear and scientifically accurate, and that the proposed labeling system should first be tested on real consumers.
In particular, it should be assessed whether people understand the labels, whether the system could mislead them and whether it helps them compare products.
What the industry proposes
UzBev proposes a phased approach. First, the association believes the reform of food labeling should be completed, followed by a nationwide dietary study and analysis of its results.
After that, it proposes developing a scientifically based model for assessing products, discussing labeling options for all relevant product categories and conducting consumer testing. Only then, the association believes, should a final decision be made on introducing the new system.
UzBev emphasizes that the issue is not whether labeling is needed in principle, but whether it will become an effective tool for informing consumers or lead to rushed regulation focused on a single industry.
“Consumers need objective information. Businesses need predictable rules. The government needs effective measures to improve public health”, the association said.
UzBev believes these three goals can be reconciled through science-based decision-making, dialogue and equal treatment of all participants in the food market.
The English version of this material was generated with the assistance of AI translation tools and may differ slightly from the original text.
