Presentation slides from Eversheds Food European webinar - Food for thought preparing for the Food Information Regulation.

1. Implementing the new European rules
on labelling – 25 November 2011
Parmjit Singh, London
Owen Warnock, Cambridge
Joos Hellert, Munich

2. Implementing the new European rules
on labelling
This session will cover:
• The Food Information
Regulation – what is
changing?
• Timescales for change
• Practical implications
for food businesses

3. The Food Information Regulation
What is changing?
• Minimum font size for • Extension of rules for
mandatory origin of food labelling
information
• Food authenticity
• Nutrition labelling
• Distance selling
• Mandatory
information on • Alcohol
allergens

4. Requirements for mandatory
information
What is mandatory information? Article 9
• The name of the food
• The list of ingredients (extended)
• Allergens / intolerances from a prescribed
list (eg wheat, eggs, mustard, milk etc).
• Quantity of certain ingredients
• The net quantity of the food
• Date of minimum durability or use by date
• Any special storage conditions / conditions
of use

5. Requirements for mandatory
information
Mandatory information cont …
• Name / business name and address of the food
business operator
• Country of origin / provenance
• Instructions for use
• The actual alcoholic strength by volume
(beverages containing more than 1.2%)
• A nutrition declaration

6. New information to be given with
the name of the food
Existing requirements remain
• eg “with sweetener”, “irradiated”
New requirements
• “defrosted” – if product has been frozen at some prior stage,
exemptions
• substituted ingredient: clear indication of the substituted
ingredient „where consumers expect an ingredient to be used‟
• added water: products that look like pieces of meat if >5% added
water: “contains added water” or similar
• meat and fish products made from pieces which look like single
items: “formed meat”, “aus Fleischstücken zusammengefügt” etc
• Caffeine: warning indication on
 beverages other than tea or coffee with >150 mg/l or
 non-beverages to which caffeine is added for physiological
purposes

7. Requirements for mandatory
information
Article 13
• Mandatory food information must be:
– marked in a conspicuous place
– easily visible, clearly legible
– cannot be hidden, obscured, detracted from or
interrupted by any other written or pictorial matter or
any other intervening material
• Same field of vision now required for
– name and description
– net quantity
– alcoholic content
– NOT now required for „best before‟ or „use by‟ date or
signpost

8. Requirements for mandatory
information
Presentation - minimum font size
• Standard rule - any lower case characters must be equal to
or greater than 1.2mm
• Largest surface area is less than 80 cm squared the
minimum lower case height must be equal to or greater
than 0.9mm
• Exemptions
– glass bottles
– small items (largest surface area is less than 10 cm
squared – only name, allergens, net quantity and use
by date need appear. What about the remaining
information?)

9. Mandatory nutrition labelling
Requirements
• The nutrition declaration will include:
– energy value and
– the amount of fat, saturates, carbohydrate,
sugars, protein and salt
• No requirement for front of pack labelling
• Information to be presented in tabular format
where possible
• Exemptions
• Further options

10. Mandatory country of origin / place of
provenance labelling
Requirements
• Mandatory if failure to indicate would mislead
• Extension of the rules for origin of food labelling
– fresh, chilled or frozen meat from pigs, sheep, goat and
poultry
• If the country of origin of primary ingredient differs then:
– country of origin of the primary ingredient shall also be given
or
– country of origin shall be indicated as being different to that
of the food
• Implementing rules to be produced within two years of the
Regulation‟s entry into force.

11. Mandatory allergen information
Requirements
• Allergens
– includes any ingredient or processing aid
specifically listed in the Regulation (eg wheat,
eggs, fish, milk etc)
– the typeset should clearly distinguish the
wording and be set out in the list of
ingredients
– not required where the name of the food
clearly refers to the substance or product
concerned

12. Distance selling
Requirements
• All mandatory information must be made
available before purchase (save for „use by date‟
or date of minimum durability)
• All mandatory information must be available on
delivery
• Catalogue selling must also make required
information clear

13. Non pre-packed food
Requirements
• Mandatory provision of allergen info
• Implications for restaurants
• Members States could adopt more
stringent requirements and insist
that more particulars are highlighted to the
consumer (eg full list of ingredients)
• Members States may specify how the
particulars are to be made available and,
where appropriate, their form of expression
and presentation

14. Food authenticity
Requirements
• Food authenticity:
– Ban on saying a product does not contain an
ingredient if that kind of product never does –
eg fat in wine gums
– Ingredient substitution
made clear on packaging
– Added water and protein
made clear on meat and
fish products

15. Future changes
Many controversial issues left for later
resolution
• Transfat labelling
• Alternative presentation of nutrition information
• Additional legibility requirements
• Extensions of country of origin labelling
• Alcohol labelling

16. Mandatory country of origin/ place of
provenance labelling
Possible future changes
• Country of origin labelling could be extended in
the future (eg to milk, milk used as an ingredient
in dairy products, unprocessed foods, other
meats)
• Commission to complete
an impact assessment

17. Future Coverage
Alcoholic Beverages
• Alcoholic beverages are exempt from the
requirements to include:
– An ingredient list and
– Nutritional information
• This is subject for review three
years after implementation

18. Timetable for Implementation
• The labelling requirements are to come into effect
3 years after the adoption of the legislation
• The obligations for nutrition labelling will not apply
until 5 years after adoption
• When will EU and/or national authorities give
guidance?
• Impact on all labels in the end, but in particular
consider
– labelling redesign and product relaunch projects
– new product development

19. Issues
• Supply of raw materials change regularly
• Cost and practicality of changing labelling and
packaging
• Restrictions on trade
• Food costs increase as flexibility diminishes?
• Increased bureaucracy for business?
• Are consumers benefiting?
• Difficult to enforce

20. Questions & Answers

21. Eversheds contact details
For further information please contact either
one of the presenters on;
Parmjit Singh:+44 845 497 1410 or +44 776 895 4246
Owen Warnock:+44 845 497 4282
Joos Hellert:+49 89 54 56 51 85
Or email: food@eversheds.com