LAST WORD
The last WORD
Food for thought Lorraine Eve discusses the EU Regulation on the Provision of Food Information to Consumers
The majority of food companies are hopefully now aware of the new EU rules on food labelling published at the end of last year, which represent one of the most significant labelling developments in a long time.
R
egulation (EU) No. 1169/2011 on the Provision of Food Information to
Consumers, which came into force on 13 December, will require the redesign of the vast majority of food labels currently on the market. Because such wholesale
changes are required, food and drink companies have been given until 13 December 2014 to become compliant. At first glance, the three-year
transition period may seem like ample time, but with the wide- ranging legislation spanning a number of aspects of food information, including country of origin, date of durability and allergen labelling, it certainly makes sense to start planning a path to compliance soon. However, because much of the
Regulation is still to be clarified and finalised, there are also risks attached to rushing into redesigning labels. Take, for example, the new
Lorraine Eve is Regulatory Affairs Manager at Ashbury Labelling.
rules on allergen declarations. The majority of UK manufacturers and retailers currently provide information to consumers on the presence of allergens by way of a ‘Contains box’ that is separate from the ingredients list. However, under the new EU Regulation, allergenic ingredients must be clearly indicated in the list of ingredients and be emphasised through a typeset
that clearly distinguished them. What isn’t clear is how exactly
this should be done – use bold, italics, brackets or capital letters? Could an asterisk be used to highlight which ingredients are allergenic? And what to do with the ‘Contains box’ information – can this be retained or must it be removed? It’s this lack of clarity that
means companies attempting to become compliant with the Regulation too quickly will most likely have to carry out further redesigns to ensure compliance with the finalised rules. So what should manufacturers
and retailers do – go ahead with re-labelling and risk not getting everything right first time, or wait until the end of the transition period and hope that all the questions on compliance have been answered? Either approach is risky. Small to medium-sized companies may be better placed to delay implementation as they will have fewer labels to update, whereas larger manufacturers and retailers may have to start redesigning now due to the sheer volume of re-labelling work. However, as both the current UK
Food Labelling Regulations 1996 and Regulation (EU) No. 1169/2011 will be in force throughout the whole of the three years, it is possible to pick which provisions to comply with, provided consumers are not misled. While it will certainly be a
challenge for the food industry to manage the implementation of the new EU Regulation, with careful planning and good regulatory advice, the labelling changes can be introduced smoothly and with as few problems as possible.
Lorraine Eve has more than 15 years’ experience in the food industry. She started her career as a Food Legislation Advisor at Leatherhead Food, gaining extensive knowledge of all aspects of UK and EC food law. She then worked for the UK’s biggest retailer Tesco for nearly 10 years, where her food law knowledge was applied to the fast-paced retail environment. She has also worked as a Regulatory Affairs Manager for a major UK manufacturer, and now brings this knowledge and experience to Ashbury Labelling. Lorraine credits her experience of working in all sectors of the food industry for her ability to provide companies with clear, practical and commercially- focused advice.
For more information, visit
www.ashbury
labelling.co.uk.
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