SGS Helps Manufacturers Implement the New EU Food Labeling Regulations

New EU food labeling rules came into force in December 2014, the culmination of a three-year transitional period.

New EU food labeling rules came into force in December 2014, the culmination of a three-year transitional period. However, differences of interpretation in some areas such as allergens declaration have impacted its successful implementation.
 
Food Allergens Labeling

EU Regulation 1169/2011 has introduced rules for the mandatory provision of allergen information of both pre-packed and non-pre-packed foods. Article 21 of the new EU labeling requirements for food harmonizes the way allergen information must be provided on foods.
 
Allergenic substances, or products containing substances originating from them, as listed in Annex II of the regulation, must be listed on the food product nutrition label and it must be emphasized through a typeset that clearly distinguishes it from the rest of the list. This can be achieved by using a different font, style or background color.
 
Implementation of the New EU Food Labeling Regulation

The transition period came to an end on December 13, 2014. Industry stakeholders and keen-eyed consumers alike will have seen these changes appearing on packages already, hopefully increasing consumer understanding of food labels. There has however, been some confusion as different operators have interpreted the new regulations differently. In addition, the non-pre-packed food sector, which includes catering services (cafes, restaurants, canteens and schools, etc.) is experiencing issues in adapting to this approach, as it is a real step-change in the way the foods they sell must be labeled.

Across the food sector every stakeholder has a responsibility under the regulation to ensure that the foods they supply are compliant. For example, food businesses that only distribute food products, may believe that as they are not manufacturers they do not need to comply. Article 8.3 of the regulation clarifies the issue. Food business operators that do not affect food information, i.e. distribution-only, must not supply food that they know, or presume, to be non-compliant with the regulation, or relevant national provisions.

Sector Specific Issues for Food Labeling

Some sector specific issues have been identified. In the travel retail sector, global travel and global supply chains mean that suppliers do not always know in which market, or member state, a product will be placed by retailers. This can mean that where a market specific language is used, it may not be appropriate for the majority of customers, for example, on an international flight. The competing, un-harmonized, demands of CODEX and EU standards are a barrier to trade.

In the restaurant/take away sector the new EU food labeling regulations are having perhaps the greatest impact. Until now, mandatory food information was focused on the packaging label. Now though, non-pre-packed foods served by commercial caterers such as takeaways, restaurants, cafes, etc. fall within the scope of regulation 1169/2011.
 
The regulation states that the food business operator responsible for providing nutritional and allergen information is the business under whose name, or business name, the food is sold to the end consumer. In this sector, that means the business from which the consumer buys their food – the restaurant/takeaway/cafe. Allergen advice on all their food products must now be made available to consumers before they make a decision to purchase. This means finding alternative ways of sourcing and providing the necessary information.

Labeling Information Beyond Food Allergens

For pre-packed foods, the new EU labeling requirements for food go beyond allergens. In an effort to increase consumer understanding of food nutrition labels, the new regulation also covers:

Nano materials (Mandatory labeling of ‘nano’ ingredients): consumers must be informed of the presence of nano materials in pre-packed foods and they must be appropriately labeled in the ingredients list. There are some questions around the formal EU definition of a nanomaterial, therefore expert advice should be sought to ensure labeling is compliant.

Minimum font sizes to improve readability for consumers: recognizing that consumers can only use information they can access and read to support purchasing decisions, food regulation 1169/2011 sets a mandatory minimum font size for all pre-packed food packaging. This sees the minimum size increased from 0.9mm to 1.2mm. In addition, the regulation states that voluntary information on packaging shall not be provided to the detriment of the mandatory information.

Honesty in food labeling: wording on pre-packed food packaging must now comply with guidelines devised to ensure that consumers are better informed about the ingredients in the food they eat. For example, where a food component or ingredient that might normally be used, or naturally present, in a product has been substituted, this must be clearly labeled next to the food’s name. Vegetable oils must now specify the vegetable origin, such as rapeseed, sunflower, or palm. Pre-packed products must include labeling for ‘formed’ products (meat and fish). Products previously defrosted must also be labeled as such – though there are many exceptions. Added water and added proteins must also now be highlighted to consumers.
 
Mandatory origin labeling: food scandals have made consumers more wary about the origins of food products, especially meat products. Following the example of the beef labeling rules already in place, the new food information regulation now extends mandatory origin labeling to fresh meat from pigs, poultry, sheep and goats. Mandatory with effect from April 1, 2015, the new labeling must include country of rearing and slaughter.

Work in Progress at the EU Commission

In addition to the above, the European Commission continues to work on developing studies and guidelines on food information and food labeling, to help ensure consumer safety and transparency in the supply chain. Food operator concerns are being investigated and further reports are in progress. These include reviews of trans-fatty acids and alcohol labeling.

About SGS Food Safety Services

With a worldwide network of food experts, SGS can conduct nutritional tests, food label reviews and nutritional labeling assessments (http://www.sgs.com/en/Consumer-Goods-Retail/Food/Processors-and-Suppliers/Testing-and-Analytical-Services/Food-Label-Reviews-and-Nutritional-Analysis.aspx) to ensure compliance, globally.

For further information, please contact an SGS expert.

Contact details:

SGS Consumer Testing Services
Alexandra Dedeilia
Agricultural & Consumer
Testing Services Business Manager
SGS Greece SA

t: +30 210 5720777
Email: [email protected]  
LinkedIn: www.linkedin.com/company/sgs-agriculture-&-food  
Website: www.foodsafety.sgs.com

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.