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Food Information Regulation – what you ought to know

Author : By David Leeks, Principal Food Law Adviser, Campden BRI

06 July 2012

With the Food Information Regulation now in place, the industry faces the most significant changes to food labelling rules for a generation. Gaining a clear understanding of the new rules will help businesses to carry out their programme of change as smoothly and cost-effectively as possible.

Here we look at ten key things food manufacturers need to know to ensure compliance with the new rules.

1. Nutrition labelling

‘Back of pack’ nutrition labelling of pre-packed foods will be compulsory with the labelling of energy (in both kJ and kcal), fat, saturates, carbohydrates, sugars, protein and salt all mandatory. Manufacturers will also be required to declare levels of any nutrients mentioned in claims.

Nutrition labelling requirements will become obligatory on 13 December 2016 but between 13 December 2014 and 13 December 2016, where a nutrition declaration is provided on a voluntary basis, it must comply with the new provisions.

2. Country of origin labelling

Country of origin labelling will be compulsory for fresh and frozen meat of pigs, sheep, goats and poultry and also for primary ingredients where the country of origin of the primary ingredient is not the same as the stated origin of the food.

3. Allergen labelling

The presence of any of 14 listed allergens will need to be highlighted in some way in the ingredients list to make their presence more obvious to the consumer. This can be achieved by using a different typeset (font, style or background colour), but will need to be done for every allergen derivative, even if they are forms of the same allergen.

4. Labelling legibility and clarity

There will now be more detailed and specific labelling legibility controls including a minimum font size of 1.2mm (although small packs – below 80cm2 can use a 0.9mm font). These two font sizes approximately equate to 8 and 6 point print respectively. A new definition of clarity will refer to specific factors such as contrast.

5. Added water in meat products

It will be compulsory to give an indication of the presence of added water in the name of the food for meat products, meat preparations and fishery products which have the appearance of a cut, joint or fillet, and where water exceeds 5% of the finished product.

6. Other meat and fish labelling issues

There will need to be an indication of the date of freezing or date of first freezing for frozen meat, frozen meat preparations and frozen unprocessed fishery products.

Also required will be an indication of the word ‘formed’ in the name of meat products, meat preparations and fishery products which may give the impression that they are a whole piece of meat but consist of combined pieces.

7. Labelling of vegetable oil

The generic name ‘vegetable oil’ will be replaced with a requirement to declare all vegetable oils in ingredients lists as in the following example, with total weight deciding the position in the list: "Vegetable oils (soya, palm, sunflower in varying proportions) ..."


8. Mandatory information for particular products

Drinks other than tea and coffee with high levels of caffeine (above 150mg/l) will need to give the following warning:
"High caffeine content. Not recommended for children or pregnant or breast-feeding women" followed by statement of content.

For solid foods where caffeine has been added at any level for a physiological purpose:
"Contains caffeine. Not recommended for children or pregnant women" followed by statement of content.

Where aspartame or aspartame/acesulfame salt is listed in an ingredients list by E number, the following extended warning needs to be given: "Contains aspartame (a source of phenylalanine).”

9. Defrosted foods

It will be necessary to give the statement ‘defrosted’ to accompany the product name for defrosted foods where freezing has an effect on safety or quality of the food; this will not apply if freezing is a technologically necessary step.

10. Strengthening of the prohibition of misleading labelling

Labelling must not suggest that a food has special characteristics when these are shared by all similar foods – this particularly applies to emphasising the presence or absence of certain ingredients and nutrients.

In addition, labelling must not suggest the presence of a particular food or ingredient when a natural component or expected ingredient has been substituted.

Need to know more?

The summary above describes some of the main factual changes of the new legislation but there are many other specific new requirements and of course, exemptions as well as exceptions.

Campden BRI is holding two interactive training sessions on 5 July and 27 September 2012 to provide an in-depth look at the Food Information Regulation.

These sessions will be invaluable to those in the industry who generate product labels, sign-off artwork, oversee these functions or simply need to understand the implications of the changes the Regulation introduces.


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