A Seminar on EU Regulations on Food

Labelling co-funded by the European Union and the National Bureau

of Agricultural Commodity and Food Standards

Bangkok

30 April 2013

Session 1 - Current EU Food Labelling Requirements

Stuart Shotton – FoodChain Europe Ltd

Outline

• EU Labelling Law Introduction

• Typical Labelling Problems

• Mandatory Information

• Clarity & Legibility

• Mandatory Labelling Detail

EU LABELLING LAW

INTRODUCTION

Labelling Law

• Most EU food

legislation comes

from the European

Commission

• Intention for same

law throughout

Member States

Labelling Law

• Labelling law based on Directives and

Regulations

• General labelling currently Directive

2000/13/EC

Labelling Law

• Directive Issues

– Interpretation

– Gold Plating

• Can differ between Member States

• Important to research Country

• New legislation will remedy this

TYPICAL LABELLING

PROBLEMS

Typical Labelling

Problems

Typical Labelling

Problems

• Source: UK Food Standards Agency Incidents Report 2011

Typical Labelling

Problems

• Labelling problems on Import

– Product prevented entry

– Stored while under investigation

– Destruction of product

– Returned to Thailand

• All at cost of Importer into EU

MANDATORY INFORMATION

Packaging Formats

• Labelling required on all foods

– “Mandatory Information”

• Differs depending on way product sold

– Non-Prepacked

– Prepacked

Packaging Formats

• Non-Prepacked

– Loose foods

– Prepacked for Direct Sale

• Prepacked

– Packed before sold to customer

– Sealed packaging

– Applies to Caterer and Consumer packs

Prepacked

Legal Name Ingredients Allergens (inc

processing aids)

QUID Net Quantity Durability

Storage

Conditions Name & Address Country of Origin

Instructions for

Use ABV

If still in/on product

If lack of origin likely to mislead the consumer

Example Label

CLARITY & LEGIBILITY

Clarity & Legibility

• Mandatory information must be:

– Clear

– Easy to understand

– Legible

– Indelible

– Easily visible

– In a conspicuous place

Clarity & Legibility

Field of Vision

• Certain information capable of being read

at same time:

– Name of the food

– Durability Indication (or details of where it can

be found

– Quantity Statement

– Alcohol By Volume (ABV) >1.2%

– Any statutory Warnings (irradiation, raw milk)

Field of Vision

Read at same time

without turning

NAME OF THE FOOD

Name of the Food

1. Name prescribed by law

– Reserved Description

2. Customary Name

3. Indication of true nature of the food

Name Prescribed By Law

• Must be used where one exists:

• Commercial names of Fish

• Melons

• Potatoes

• Not permitted to use any other name when

sold in own right

Reserved Descriptions

• Technically not prescribed names

• If description used product must meet

compositional criteria

• Includes:

Chocolate Jam Honey

Sausage Milk Coffee

and many more....

Customary Name

• No name prescribed by law

• Name customary to area product sold

• Must be understood by consumers

True Nature of the Food

Sufficiently precise to identify the true

nature of the food and to enable it to be

distinguished from products with which it

could be confused.

Name of the Food

• Many prosecutions:

– Mechanically Separated Meat

– Textured Vegetable Protein

– Scampi

– Crispy Seaweed

– Flavour and Flavoured

– Prawn Crackers

– Cheese Analogues

Meat Products

• Formed

– Combining more than one muscle

– “Formed from pieces of chicken breast”

• Reformed

– Made from several muscles

– Separated and recombined with comminuted

meat and/or emulsion

– “Reformed Ham”

NOTE:

Changes

under new law

Meat Products

• Looks like cut, slice or portion of meat

• Contains water in excess of certain

amounts

– Legal name followed by “…with added water”

Type of Meat

Product

Water

Limit

Example

Cooked & Uncooked

Meat Products

>5% “Roasted Chicken Breast with

Added Water”

Uncooked Cured

Meat Product

>10% “Smoked back bacon with Added

Water”

Flavour or Flavoured?

• FLAVOURED

– Wholly or partially derived from food

described

– Actual foods which are eaten

• FLAVOUR

– Substance that imparts flavour only

– Not foods themselves (Additive)

Indication of Condition or

Treatment

• Provide information in name if omission

may mislead consumer

– Smoked

• Traditional smoking

– Smoke Flavoured

• Smoke distillate

– Smoke Flavour

• Artificial smoke flavouring additive

Name Must Not Be

Interrupted

“Low Fat Yoghurt

With Strawberries”

Name Must Not Be

Interrupted

“Low Fat Yoghurt

With Strawberries”

INGREDIENTS

Ingredients

• Headed by word “Ingredients”

• Descending order of weight

• Ingredients <2% in

any order

Added Water

• Water added as ingredient:

– >5% of Finished Product

• LIST

– <=5% of Finished Product

• NO NEED TO LIST

Ingredient Name

• Named as if sold as product in own right

“BBQ Sauce”

“Barbeque Flavour Sauce”

• Indicate Processes

– “Hydrogenated Vegetable Oil”

Compound Ingredients

• Ingredients which consists of two or more

ingredients

• Must be broken down in list

Allergens

• 14 Declarable EU allergens

• Must be declared within the ingredients list

• Covers intentionally added ingredients and

processing aids

• Covered in Session 2 in detail

QUID

QUantitative Ingredients Declaration

• Percentage of certain ingredients

• Characterise the food

When Does

QUID Apply?

• When ingredient or category of ingredients

mentioned in name of food:

– Cod fillet in a crispy crumb coating

• Cod percentage required

– Chocolate Chip Cake

• Chocolate Chip percentage required

When Does

QUID Apply?

• When ingredient emphasised in words or

pictures:

– “Now with more juicy raisins”

– Images of apples and cranberries

– Percentage of raisins, apple and cranberries

needed

When Does

QUID Not Apply?

• Ingredient present in small quantity for

flavouring

• Presence of ingredient does not affect

consumer choice:

– Batter on a battered fish

QUID Calculations

• No Moisture Loss in Finished Product: Weight of Ingredient at Mixing Bowl

Total weight of Ingredients at Mixing Bowl

x 100

• Moisture Loss in Finished Product: Weight of Ingredient at Mixing Bowl

Total weight of Ingredients at Final Product

x 100

QUID >100%?

• Dry Cure Ham:

“Ingredients: Pork, Salt, Dextrose, Antioxidant:

Sodium Ascorbate; Preservative: Potassium

Sorbate.

Prepared from 115g of raw pork per 100g Dry

Cure Ham”

DURABILITY INDICATIONS

Durability Indications

• Indicate shelf life of product

• “Use By”

• “Best Before”

• “Best Before End”

• AND Accompanied by storage instructions

“Use By”

• Only for highly perishable foods

• Food safety risk to consume after date

• Illegal to use to offer to sell after date

passes

• Format:

– DAY/MONTH

“Best Before”

• Not unsafe to consume after date

• Quality likely to deteriorate

• Formats:

– Best Before:

• DAY/MONTH/YEAR; or

• DAY/MONTH: <= 3 month Shelf Life

– Best Before End:

• MONTH/YEAR: 3 to 18 month Shelf Life

• YEAR: >18 month Shelf Life

“Best Before”

Storage Instructions

• If products must be stored certain way

• Must be able to reach durability date

stated based on instructions provided

• Provided with durability date or statement

where can be found

Storage Instructions

• “Keep Refrigerated”

• “Keep Frozen”

• “Store away from strong odours”

• “Keep out of direct sunlight”

• No requirement to provide

storage conditions once opened

NAME & ADDRESS

Name & Address

• Name or Business Name; and

• Address or Registered office of either or

both of:

– Manufacturer or Packer (Worldwide)

– Seller within EU

• Name on Pack = Responsible Person

• Websites and email addresses alone not

sufficient

COUNTRY OF ORIGIN

Country of Origin

• Required where leaving off may mislead

consumer

• Where product “last underwent major

processing”

• Label gives impression product comes

from a certain place but not produced in

that place

Country of Origin

• American Flag

• Suggests made in

America

• Manufactured in UK

• “Produced in the UK”

INSTRUCTIONS FOR USE

Instructions for Use

• Required if proper use of product cannot

be made without them

• Includes:

– Cooking Instructions

– Thawing Instructions

– Dilution or Reconstitution

Instructions

Instructions for Use

• Important to verify instructions

• Can consumer follow instructions?

• Do they make sense?

• Must produce SAFE product AND

QUALITY consumer expects as shown on

pack

QUANTITY MARKS

Quantity Marks

• Weight or Volume of Product

• Limited products can be packed by

number

• Metric weight or volume must be given

– Weight = g or kg

– Volume = ml or mL; cl or cL; l or L

Quantity Marks

• Minimum Sizing depending on

weight/volume:

Weight Volume Size of

Numerals

<= 50g <= 50ml 2mm

>50g and <=200g >50ml and <=200ml 3mm

>200g and <= 1kg >200ml and <= 1l 4mm

>1kg >1l 6mm

SUMMARY

Summary

• Many elements to EU labelling law

• Current requirements can differ between

Member States

• Clarity and Legibility as important as

information itself

• Nutritional information not mandatory

unless claim is made

• Incorrect labels can and are stopped at

point of entry