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New EU food labelling rules came into force in December 2014, the culmination of a three-year transitional period. However, differences of interpretation in some areas, such as allergens declaration, has impacted its successful implementation.
 
EU Regulation 1169/2011 has introduced rules for the mandatory provision of allergen information of both pre-packed and non pre-packed foods. Article 21 of the new EU labelling requirements for food harmonises the way allergen information must be provided on foods.
 
Allergenic substances, or products containing substances originating from them, as listed in Annex II of the regulation, must be listed on the food product nutrition label and it must be emphasised through a typeset that clearly distinguishes it from the rest of the list. This can be achieved by using a different font, style or background colour.
 
The transition period came to an end on December 13, 2014. Industry stakeholders and keen-eyed consumers alike will have seen these changes appearing on packages already, hopefully increasing consumer understanding of food labels. There has however, been some confusion as different operators have interpreted the new regulations differently. In addition, the non pre-packed food sector, which includes catering services (cafes, restaurants, canteens and schools, etc.) is experiencing issues in adapting to this approach, as it is a real step-change in the way the foods they sell must be labelled.

Taking Responsibility

Across the food sector every stakeholder has a responsibility under the regulation to ensure that the foods they supply are compliant. For example, food businesses that only distribute food products, may believe that as they are not manufacturers they do not need to comply. Article 8.3 of the regulation clarifies the issue. Food business operators that do not affect food information, i.e. distribution-only, must not supply food that they know, or presume, to be non-compliant with the regulation, or relevant national provisions.

Sector Specific Issues

Some sector specific issues have been identified. In the travel retail sector, global travel and global supply chains mean that suppliers do not always know in which market, or member state, a product will be placed by retailers. This can mean that where a market specific language is used, it may not be appropriate for the majority of customers, for example, on an international flight. The competing, unharmonised, demands of CODEX and EU standards are a barrier to trade.

In the restaurant/take away sector the new EU food labelling regulations are having perhaps the greatest impact. Until now, mandatory food information was focused on the packaging label. Now though, non pre-packed foods served by commercial caterers such a takeaways, restaurants, cafes, etc. fall within the scope of regulation 1169/2011.
 
The regulation states that the food business operator responsible for providing nutritional and allergen information is the business under whose name, or business name, the food is sold to the end consumer. In this sector, that means the business from which the consumer buys their food – the restaurant/takeaway/cafe. Allergen advice on all their food products must now be made available to consumers before they make a decision to purchase. This means finding alternative ways of sourcing and providing the necessary information.

Beyond Allergens

For pre-packed foods, the new EU labelling requirements for food go beyond allergens. In an effort to increase consumer understanding of food nutrition labels, the new regulation also covers:

  • Mandatory labelling of ‘nano’ ingredients
  • Minimum font sizes to improve readability for consumers
  • Honesty in food labelling
  • Mandatory origin labelling

Nano materials: consumers must be informed of the presence of nano materials in pre-packed foods and they must be appropriately labelled in the ingredients list. There are some questions around the formal EU definition of a nanomaterial, therefore expert advice should be sought to ensure labelling is compliant.

Minimum font sizes: recognising that consumers can only use information they can access and read to support purchasing decisions, food regulation 1169/2011 sets a mandatory minimum font size for all pre-packed food packaging. This sees the minimum size increased from 0.9mm to 1.2mm. In addition, the regulation states that voluntary information on packaging shall not be provided to the detriment of the mandatory information.
 
Honesty in food labelling: wording on pre-packed food packaging must now comply with guidelines devised to ensure that consumers are better informed about the ingredients in the food they eat. For example, where a food component or ingredient that might normally be used, or naturally present, in a product has been substituted, this must be clearly labelled next to the food’s name. Vegetable oils must now specify the vegetable origin, such as rapeseed, sunflower, or palm. Pre-packed products must include labelling for ‘formed’ products (meat and fish). Products previously defrosted must also be labelled as such – though there are many exceptions. Added water and added proteins must also now be highlighted to consumers.
 
Mandatory origin labelling: food scandals have made consumers more wary about the origins of food products, especially meat products. Following the example of the beef labelling rules already in place, the new food information regulation now extends mandatory origin labelling to fresh meat from pigs, poultry, sheep and goats. Mandatory with effect from April 1, 2015, the new labelling must include country of rearing and slaughter. 

Work in Progress

In addition to the above, the European Commission continues to work on developing studies and guidelines on food information and food labelling, to help ensure consumer safety and transparency in the supply chain. Food operator concerns are being investigated and further reports are in progress. These include reviews of trans fatty acids and alcohol labelling.

With a worldwide network of food experts, SGS can conduct nutritional tests, food label reviews and nutritional labelling assessments to ensure compliance, globally.
 
For more information, please contact:
 
Alexandra Dedeilia
Agricultural & Consumer
Testing Services Business Manager
SGS Greece SA
t: +30 210 5720777 (ext.116)

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