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General Food Labelling

Policy Position

Food labelling is an important means of providing essential information to consumers on the composition of products and the methods of storage and preparation etc. and identifying the manufacturer or other responsible business. The amount of information required by law to be given on food labels should be kept to essential requirements. Additional information can also be provided voluntarily, on-label or by other means such as consumer leaflets, company websites and customer care lines.

FDF welcomes the EC proposal for a Regulation on the provision of food information to consumers which aims to consolidate and update two areas of labelling legislation – general food and nutrition labelling - into a single text. This will make it easier to understand and apply the labelling rules in a way that is consistent across the European Union. However we regret that the consolidation does not include the removal of duplicating requirements and does not attempt to reduce significantly the amount of information required on the label. Aside from these general observations, there are five key areas of concern for our members:

• The proposal for front-of-pack labelling may prove too ambitious initially for many Member States and it may be more pragmatic for the Regulation to require only energy per portion on a GDA basis, allowing for more information to be provided voluntarily where there is consumer demand.
• We oppose the setting of a minimum font size of 3mm which is impractical, ignores other factors influencing legibility and could have the unintended consequence of forcing companies to introduce bigger pack sizes.
• We consider that the proposed size-related exemptions are too small and should be extended to packs where the largest printable surface area is 80cm² or less.
• We agreed that it is important to provide country of origin information where it would be misleading not to do so however we oppose any mandatory requirements to provide country of origin labelling for single ingredients (other than meat, poultry or fish) or for the ingredients of composite products due to the complexity, and necessary flexibility, in sourcing ingredients particularly seasonal ingredients.
• We oppose the concept of national schemes which we feel contradicts the very nature of a harmonising Regulation and could restrict the free movement of goods.

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Background

Food labelling is an area of EU legislative competence and Member States are generally prohibited from imposing more detailed requirements (eg on origin labelling or nutrition labelling). General food labelling is covered by Directive 2000/13/EC (as amended) and nutrition labelling is covered by Directive 90/496/EEC . Additional requirements are contained in product-specific legislation (eg for beef or chocolate products).

The Labelling Directive is implemented in the UK by the Food Labelling Regulations (FLR) 1996 (as amended). Subject to specific derogations, it requires food to be labelled with certain requirements including:

• The name of the food;
• A list of ingredients;
• The manufacturer’s name;
• A date mark;
• Any special storage conditions;
• Instructions for use where necessary; and
• Specific ingredient information including giving some quantities and identifying allergens.

Food manufacturers and retailers are able to provide additional information voluntarily, provided that it is accurate and does not mislead the consumer.

The EC has undertaken a review of food labelling legislation and its proposal for a Regulation on the provision of food information to consumers was published in January 2008. This effectively consolidates and updates two areas of labelling legislation – general food and nutrition labelling - into a single text but it also introduces a number of new requirements including:

• a minimum font size of 3mm;
• mandatory front-pack-pack nutrition labelling;
• an extension to the rules for the origin labelling of certain ingredients of manufactured foods where an origin claim is made voluntarily on a product; and
• the introduction of national schemes.

The proposal will be discussed by Codecision in which the European Parliament and Council, in liaison with the Commission, are responsible for debating and agreeing the legislation.

The new legislation could take several years to adopt, as this is an area of substantial regulatory and political interest which is expected to attract a large number of proposed amendments from the European Parliament and Council. Once adopted, there could be a lead-in time for new requirements of three to five years.

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