Country of Origin Labelling

Policy Position

FDF fully supports the requirements of the Labelling Directive to ensure that misleading statements of origin are not made but considers any extension of the legislation to require origin labelling would be burdensome to achieve; increase costs; contribute little to improving consumer information; further complicate the label; and would have no impact on food safety.

In particular, FDF considers that there should be no mandatory requirement to provide 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 many ingredients, particularly seasonal ingredients, to ensure a consistent supply of appropriate quantity and quality. It would be completely impractical to require variant labels to meet all such circumstances and would reduce consumer choice by making manufacture of many products uneconomical.

FDF supports the voluntary actions of food manufacturers in responding to consumer led interest for specific origin information, on or off pack and we have been working with the supply chain, facilitated by Defra, on the development of voluntary principles on country of origin labelling. These voluntary principles build on the current legislation to provide even clearer labelling for consumers.

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Background

Articles 2 and 3 of Directive 2000/13/EC on the labelling, presentation and advertising of foodstuffs require manufacturers to ensure that consumers are not misled with regard to, inter alia, origin or provenance of a food product and, specifically, that details on the place of origin or provenance of a product have to be indicated whenever failure to give such details might mislead the consumer as to the true origin or provenance of the product. Beyond this requirement not to mislead, country of origin labelling is voluntary. Article 3 also requires the name and address of the manufacturer or packer or seller established within the Community to be indicated on the product. The Labelling Directive is implemented in the UK by the Food Labelling Regulations (FLR) 1996 (as amended). Similar rules have been established at an international level under the Codex Alimentarius. Country of origin labelling is currently being discussed at a UK and EU level in the context of the EC proposal for a Regulation on the provision of food information to consumers. It is unclear at this stage if there will be any change to the current requirements.

Manufacturers are also able to make additional voluntary indications as to the origin of their products or of certain ingredients, if appropriate and not misleading. Consumers can also obtain information on product and/or ingredient origin from manufacturers by various off-label means.

In addition, Regulation 510/2006 of 20 March 2006 establishes EU rules for protecting designations of origin and geographical indications for agricultural products and foodstuffs intended for human consumption. Under these arrangements, the registered product name will be given protection against imitation across the EU and may carry a Community-approved logo.

Country of origin labelling for the purposes of consumer information should not be confused with Rules of Origin for the purposes of Customs classification. This is subject to a completely separate regime. Care should be taken when considering whether a “substantial change” for the purposes of the latter can justify a different origin declaration for food labelling purposes, particularly where this involves only light processing.

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Last reviewed: 22 Apr 2013