Country of Origin Labelling
FDF fully supports the requirements of the Regulation (EU) 1169/2011 on the
provision of food information to consumers to ensure that misleading statements
origin are not made but considers any extension of the legislation to require
origin labelling would be burdensome to achieve; increase costs; contribute
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
origin labelling for single ingredients (other than meat, poultry or fish) or
the ingredients of composite products due to the complexity, and necessary
flexibility, in sourcing many ingredients, particularly seasonal ingredients,
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
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.
Under Article 26 of Regulation (EU) 1169/2011 on the provision of food
information to consumers, manufacturers are required to ensure that consumers
misled with regard to origin or provenance of a food product and, specifically,
that details on the place of origin or provenance of a product have to be
whenever failure to give such details might mislead the consumer as to the true
origin or provenance of the product [same requirement as the repealed Labelling
Directive]. The EU FIC extends the rules regarding mandatory country of origin
labelling to fresh, chilled and frozen pork, poultry, lamb and goat meat.
The Commission was required to adopt an implementing act concerning the
application of the rules regarding the mandatory indication of country of
labelling to fresh pork, lamb and poultry meat. Commission Implementing
(EU) 1337/2013 was adopted on 13 December 2013 and the new rules have been
applicable since 1 April
Under these rules, animals born, reared and slaughtered in the same Member
can be labelled “origin: member state/third country”.
In other cases both the country where the animal was reared and the country of
slaughter will need to be indicated on the label. There is a derogation for
minced meat which may be simply labelled as “EU”, “non-EU” or “reared and
in the EU and non-EU countries”. The Commission is committed to issue
on the implementation and enforcement of the new Regulation.
The EU FIC also extends the rules regarding the voluntary indication of country
of origin labelling. The Commission was required to adopt an implementing act
concerning the application of the rules regarding the voluntary indication of
country of origin labelling. The Commission has drafted implementing rules for
indicating the origin of the primary ingredients of a food where it is
that given for that food. This was first discussed at a Commission Working
meeting in September 2013 and only recently in early 2016 these discussions
have continued. A draft Implementing Regulation is currently being discussed and,
via FDE and Defra, FDF are inputting to the on-going discussions. DG
confirmed that current practices on voluntary origin labelling can continue as
long as no implementing rules have been agreed.
The EU FIC also required the Commission to submit reports to the EP and the
Council regarding the mandatory indication of country of origin labelling for
used as an ingredient; milk; milk used as an ingredient in dairy products;
unprocessed foods; single ingredient products; and ingredients that represent
than 50% of a food. The Commission published its report on meat used as an
ingredient on 17 December 2013. The report weighs up the need for the consumer
informed, the feasibility of introducing mandatory origin labelling and
cost/benefit analysis including the impact on the single market and
The report concludes that: ‘Consumer interest in origin labelling for meat
ingredients appears to be considerably strong. There are significant differences
amongst the different Members States as to consumer preferences and understanding of
origin information as well as to levels of motivation/reasons for such
information. The overall strong consumer interest in origin labelling, (a) ranks behind
price and quality/sensory aspects in terms of the most important factors
affecting consumer choice and (b) it is not reflected in the relevant consumer
"willingness to pay"; at price increases of less than 10%, the "willingness to pay" falls
The Commission was due to publish the other reports on milk; milk used as an
ingredient in dairy products; other types of meat; unprocessed foods; single
ingredient products; and
ingredients that represent more than 50% of a food by 13 December 2014 but these
were delayed until 2015.
On 20 May 2015, the Commission published two further reports:
- The first on mandatory indication of the country of origin or place of
provenance for milk, milk used as an ingredient in dairy products and types of meat other
than beef, swine, sheep, goat and poultry meat (DG Agri competence). The report
concludes that ‘consumers may, if they so wish, opt for milk or meat products
where origin information is voluntarily provided for by food business operators.
This can be a suitable option without imposing additional burden on the industry
and the authorities. Mandatory origin labelling would entail higher regulatory
burden for most of the products assessed in the report’ and ‘in spite of a
consumers' interest for the origin of milk, milk used as an ingredient in dairy
products and for meats under the remit of this report, consumers' overall willingness
to pay for this information appears to be modest.‘
- The second on unprocessed foods, single ingredient products and ingredients that
constitute over 50% of a food. This report concluded that: ‘In terms of factors
affecting consumer purchasing decisions, consumer interest in origin labelling,
ranks behind price, taste, use by / best before date, convenience and/or
appearance aspects. Even if consumer interest in origin labelling for unprocessed
foods, single ingredient products and ingredients representing more than50% of a food
is claimed by two thirds to three quarters of consumers, it is lower than for
food categories such as meat, meat products or dairy products.’
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
from manufacturers by various off-label means.
In addition, foodstuffs establishes EU rules for protecting designations of
geographical indications for agricultural products and foodstuffs intended for
human consumption. Under these arrangements, the registered product name will
given protection against imitation across the EU and may carry a
Community-approved logo (e.g. PDO, PGI or TSG).
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
different origin declaration for food labelling purposes, particularly where
this involves only light processing.
Last reviewed: 06 May 2016