Labelling: the devil is in the detail

Australian Society of Baking National Conference – 28th October, Brisbane 2015

Presented by Jasmine Lacis-Lee, DTS Food Laboratories

Presentation Purpose•Why label food?•Label what - overview of the labelling basics?•Where the devil can hide in labels

• NIP format and more• False and misleading• Trade measurements• Nutrition claims• Free from / Allergen claims

•How to get the devil off your back?

Why label food?

•Legal requirement• Legalities at play include

• Food Standards Code• ACL – ACCC• Trade measurement

•Information for consumers - choice•Public health – allergens, cooking, storage, UBD

Label Must Haves: FSC

•Is the label legible?

FSC: NIP Format

Where the devil can hide – NIP Format• All numbers to 3 significant figures only

• Eg. 8111kJ can be rounded to 8110kJ• Sodium can be rounded to nearest 5

• Eg. 16mg can be rounded to 15mg• Words LESS THAN must be used, not “<“• Only LESS THAN 1g is allowed, not “<0.1g”• Check calculations when converting to 100g to per serving

Where the devil can hide – NIP calculations

• Representative sample(s) eg. R&D vs production• Incorrect subsampling – entire sample or portion?• NIP not performed as per intended use – reconstituted

(dry soups), drained (canned vegetables, edible portion (prawns)

• Serving per package – is it real? eg. 2.3• How do you determine average?

Label related claims to watch for in the baking industry

FSC 2.1.1 Cereals and Cereal products

• Wheat flour must contain folic acid and thiamine –

applicable only to bread and bread products• Addition of iodised salt – applicable only to bread and bread products• What is Wholemeal?

• Cases of testing for Crude Fibre performed for verification

Label Requirements: ACL & ACCCFalse & Misleading

•Conveys a misleading or deceptive impression or representation via words OR pictures•Typical claims made about a products:

• Quality• Quantity• Composition• Origin

Good Food magazine July 14, 2013 “Dispute over bread leaves a sour taste” - ''Look at the ingredients,'' Mr Noy said. ''If it has more than flour, salt and water, then it is not a true sourdough.''Master baker at Sydney's Bourke Street Bakery, Paul Giddings, who has been baking sourdough for 8½ years, said his sourdough took up to 17 hours to cook as the wheat fermented to create the culture that gave the sour taste

Does the consumer trust the label?SOURCE: FSANZ, Food labelling issues: quantitative research with consumers 2003 (n = 1940)–How much do you feel you can trust the information given on the (label component)?

• 17% unsure to trust ingredient list• 15% unsure to trust NIPs

–Of the above consumers, reasons for being unsure:• Companies lie on labels• Too vague• I’m naturally suspicious• Negative previous experience

Label Requirements: ACL & ACCC – false & misleading

•Consideration required – overall impression, target audience and intent

•This applies to ALL commercial messages whether deliberate, careless or unintended

Misleading Label Claim – Case Study•Label claimed 100% Fresh Orange Juice

• Label did not mention sugar in the ingredients list or state that sugar may be added when new season oranges are slightly bitter

• Testing product demonstrated sugar was added• Conclusion: product did not contain 100% orange

juice as represented on label but contained cane sugar and preservatives

• Preventative action – ACCC compliance program

Trade Measurement Requirements

• Expression of scientific notation:• kg not KG, Kilo’s or Kg• g (<1000g) not G, gm or grm• L is preferred but l is accepted• mL (<1000mL) not ML

• Position, position, position• 2mm clear space around statement• Same direction as food name• Minimum text heights depending on pack size• Consideration of how displayed at point of sale

• Name and street address not a PO Box• Pre-packaged bread, biscuits & cookies

• Address of packer• Weight (allowing for moisture loss)

Nutrition content claims• In addition to meeting code definitions –

• Low in salt • potassium declaration in NIP

• Low in cholesterol • declare trans/mono/poly/sat fats in NIP• is the food naturally low cholesterol?

• Lactose free / low• galactose must also be declared in NIP• Free = not detected

• No added sugar or sugar % free • Must declare DF in NIP

• Bakery Trends – high fibre claims

Allergen Claims Allergen

• Gluten Free• No detectable gluten, limit of quantitation, <20ppm does not

apply in Australia• Contain no oats or malt, raw material sourcing is critical

• Dairy Free• No detectable dairy, ensure the correct marker is used for

analysis

Allergen claims & Management Other allergen concerns

• Omega 3 fortification• Unable to detect Omega 3• Use of modelling for allergen cleaning verification need to

be used.

• Allergen Management• Risk assessment of the process required• Cleaning verification is critical• If there are no allergens other then 1 a plan is still required• Don’t forget the other allergens on site – egg / soy

How to get the devil off your back?• Its not what you think the product represents BUT how

the consumer interprets your representation• Substantiate your claims• Internal label checklist• Review similar products on the market• Multi-department sign off• Pre-market survey / questionnaire?• NIP / claim verification from production samples• Recipe / formulation control

Helpful Links

• Food Standards Code – Standards 1.2.1 – 1.2.11• FSANZ: Getting Your Claims Right (1.2.7)• Useful References- “User Guides “ on FSANZ Web

Site – provide easy to follow guide to specific Standards• Guide to the sale of Bread and Bakery Products

–http://www.measurement.gov.au/TradeMeasurement/Business/Pages/BreadandBakeryProducts.aspx

• Country of origin claims and Australian Consumer Law www.accc.gov.au

Thank you