ANALYSIS - The complexities of food labelling regulations for European food producers and those exporting to the European Union are about to become a whole lot more intricate, writes Chris Harris.
By the end of this year changes will start taking place in food labelling that will start to require country of origin labelling on fresh meat from pigs, sheep, goats and poultry, nutrition information on processed foods and information about potential allergens such as peanuts or milk.
The labelling will also have to be clear with specific font sizes for the text and the information about allergens will also have to cover non pre-packed foods, including those that are served in restaurants and cafes.
For meat and food manufacturers, this will mean some lengthy time getting familiar with the intricacies of the legislation and then carrying out a full due diligence on the products to ensure that the correct information is displayed.
The current food labelling legislation is covered by the general rules on food labelling, which broadly aim to give consumers all the essential information on composition, manufacturer, storage methods and preparation of the foods.
The rules apply to foods delivered directly to the consumer or to restaurants, hospitals, canteens and other mass caterers.
The food labels must be indelible and easy to see, understand and read, with some particulars appearing in the same field of vision.
Substances known as allergens must always be indicated on the label and labels must indicate the quantity of certain ingredients as a percentage of the final product (Quantitative Ingredients Declaration - QUID).
Producers and manufacturers can give additional labelling information, if it is accurate and does not mislead the consumer. But the regulations prohibit claims on any food that it prevents, treats or cures a human disease.
However, after 13 December 2014, the new tighter labelling restrictions will start to come into force.
Unlike other changes to the EU labelling regulations, this latest change will mean a complete redesign of the labels on the packet, which will mean processors will have to build into the timescale time for changing the artwork and graphics as well as time for printing.
The new regulations that are contained in the EU Regulation 1169/11 call for the country of origin, allergens labelling and the clarity of the labels to be introduced by 13 December 2013, with a little more flexibility on the nutrition labelling which will come into force by 13 December 2016.
By 13 December 2013, the Commission must adopt implementing acts on the mandatory indication of country of origin or place of provenance for unprocessed meat of swine, poultry, sheep and goats after an impact assessment.
The Commission must also adopt implementing acts on the application of "voluntary origin" labelling of foods after an impact assessment and submit a report to the European Parliament and the Council on the mandatory indication of the country of origin or place of provenance for meat used as an ingredient as well as:
- Types of meat other than beef, swine, sheep, goat and poultry;
- Meat used as an ingredient;
- Unprocessed foods;
- Single ingredient products;
- Ingredients that constitute over 50 per cent of a food.
The Commission has commissioned an external study on the application of rules on "voluntary origin" labelling of foods and on the mandatory indication of country of origin or place of provenance of meat used as an ingredient.
The current on-going scandal over the detection of horse meat in beef products, ready meals and other meat products as well as the discovery of products contaminated with pork and other meats not declared on the label has brought the new EU labelling regulations into sharp focus.
The regulations also look at certain specific aspects of the food production and ingredients.
For example, an indication of the presence of added water, which makes up more than five per cent of the weight of the finished product must be included in the name of the food in the following in meat products and meat preparations that have the appearance of a cut, joint, slice, portion or carcase of meat and fishery products and prepared fishery products that have the appearance of a cut, joint, slice, portion, filet or of a whole fishery product.
Whether a food product fulfils these requirements must be carried out on a case-by-case basis primarily by the food business operators and later on by the Member States in the context of control activities.
The appearance of the food has to be taken into account. Foods such as sausages (mortadella, hot dog), black pudding, meat loaf, meat/fish pate, meat/fish balls will not require an indication of the presence of water.
The new regulations now start to place the responsibility firmly in the hands of the food business operator - the store or the restaurant.
The new regulations will now shift the responsibility for the food labels sharply from the food manufacturer and processor to the retailer and could further help to shorten the food manufacturing chain as more transparency and understanding of the food chain becomes necessary.