Doing what it says on the tin

Do you know your FIC from your COOL? Shortly there will be new rules governing the way food producers label the products that will eventually be sold through retailers. The changes will affect producers of all sizes and will also require certain compliance where food is sold loose in shops and cafés.

Colette Backwell, director of the Scottish Food and Drink Federation
Colette Backwell, director of the Scottish Food and Drink Federation

THE food industry is about to go through the most momentous change to on-pack labelling it has faced to date.

All European food and drink manufacturers, large and small, must adapt their labelling in line with the Regulation (EU) 1169/2011 on the provision of food information to consumers, commonly known in the industry as the EU FIC. Failure to comply will bring UK enforcement bodies to the producer’s door.
The Regulation consolidates and updates rules on general food and nutrition labelling into a single text. The key new requirements are: a minimum font size for mandatory information; a clearer indication of allergens in the ingredients list; an extension to the rules for country of origin labelling (COOL) for meat and mandatory nutrition labelling. Most of the requirements of the Regulation will apply from 13 December 2014 with the exception of the minced meat requirements which apply from 1 January 2014. In addition, companies which do not currently provide nutrition labelling on pack have an extra two years up to 13 December 2016 to comply with the mandatory nutrition declaration. Companies which already provide nutrition information must comply by 13 December 2014.
The mandatory particulars must be printed on the package or on the label in such a way as to ensure clear legibility, using a font size where the height of the letter or digit is equal to or greater than 1.2mm. There is an exemption for small packs – where the largest surface has an area of less than 80 square centimetres the letter height should be equal to or greater than 0.9mm.
The allergens listed in Annex II of the EU FIC must be indicated in the ingredients list and the name of the substance must be emphasised through a typeset that clearly distinguishes it from the rest of the ingredients. For pre-packed foods which are exempt from the requirement to provide a list of ingredients such as small packs – where the largest surface has an area of less than 10 square centimetres – the indication on the label must comprise the words ‘contains’ followed by the name of the allergenic substance. The EU FIC also extends the requirement for allergen information to be provided for foods sold loose including those sold in supermarkets, restaurants and cafes.
The mandatory indication of country of origin is extended to pig, sheep, goat and poultry meat. Specific rules will also be introduced in cases where the country of origin of a food is given and where it is not the same as that of its primary ingredients. The European Commission is required to set out legislation on mandatory COOL for meat and on voluntary COOL by December 2013. The European Commission is also required to report on mandatory COOL for meat as an ingredient, other types of meat, milk, as well as for milk as an ingredient, unprocessed foods, single ingredient products and ingredients that are greater than 50% of a food.
Nutrition information will be mandatory for most pre-packed foods. It will need to be provided (on a per 100g basis) for energy (both in kilojoules and kilocalories), fat, saturated fat, carbohydrate, sugars, protein and salt in that order. These values can in addition be expressed per portion. The following nutrients can be provided on a voluntary basis: fibre, vitamins and minerals, mono and polyunsaturates. Sodium will no longer be allowed. Front-of-pack nutrition labelling remains voluntary either as the energy content alone or the energy content accompanied by information on the amounts of fat, saturates, sugars, and salt.
Guidance is available to help companies comply with the new requirements and companies are also encouraged to talk to their local environmental health officer, trading standards officer, or Food Standards Agency Scotland.