All change on labelling requirements
By John Hammond - 24 October 2011
The Food Information Regulation has finally been agreed. After much debate, we now know what changes to food labels are going to be required. As is inevitable in such a complex area, there are certain exemptions to the general requirements, and exceptions to these exemptions!
The most far-reaching of these are those relating to nutrition labelling. 'Back of pack' nutrition labelling of pre–packed foods will be compulsory. Energy (in both kJ and kcal), fat, saturates, carbohydrates, sugars, protein and salt will be mandatory, as will any nutrients mentioned in claims. Voluntary 'front of pack' information will continue for energy, fat, saturates, sugar and salt, along with GDAs per portion, but the use of 'traffic light' schemes will be restricted.
Country–of–Origin labelling will be compulsory for fresh and frozen meat, and when origin claims are made for meat products and the origin of the main ingredient is different to the claim. The Commission is looking into extending mandatory labelling to 'single ingredient' products, and milk and dairy products, so we haven't heard the last of this.
Allergen labelling requirements will be much as they are now, but the presence of any of fourteen listed allergens will need they will need to be highlighted in some way to make their presence more obvious to the consumer. Allergen labelling will also be mandatory for foods sold loose. The requirement for information on the risks of cross–contamination is not changing at the moment, but the Commission is going to look into ways of making this more consistent. So this is another story that isn't finished yet.
Clarity is an issue for many, especially those consumers who can't read small type faces. There will now be more detailed and specific controls - including a minimum font size of 1.2mm (although small packs – below 80cm2 can use a 0.9mm font) and a new definition of clarity – referring to specific factors such as contrast.
Amongst the other changes is that all meat products with added water and/or some other added ingredient will need these additions to be declared prominently – currently, in the UK only meat products that have the appearance of a cut or portion of meat are subject to this type of requirement.
So, much is changing – and there are still several more potential changes being investigated by the Commission. As always these will be covered in both Food Law Alert and our electronic Food Law Notes.