Food Labelling

Food Information to Consumers (FIC) Regulation

Regulation (EU) 1169/2011 on the provision of food information to consumers (FIC) establishes the general principles, requirements and responsibilities governing food information and, in particular, food labelling. The requirement for small producers to comply is the same as for much larger companies

It introduced a number of new requirements including:

  • a minimum font size for mandatory information
  • mandatory back-of-pack nutrition labelling
  • an extension to the rules for the origin labelling for fresh meat of pork, lamb and poultry
  • a clearer indication of allergens in the ingredient list and allergens information to be provide for non-prepacked foods.

In general the new rules came into force on 13 December 2014. However, the obligation to provide nutrition information applied from 13 December 2016 for manufacturers who have yet to introduce nutrition labelling on their products.

Who does the FIC Regulation apply to?

The Regulation applies to all stages of the food chain where the activities of the food business concern the provision of food information to consumers. It applies to all foods intended for the final consumer, including foods delivered by mass caterers, food intended for supply to mass caterers and food old online (i.e distance selling).

Nutrition Labelling

The Department of Health has published new guidance explaining the nutrition-related requirements under the Food Information to Consumers (FIC) Regulation: mandatory "back of pack" nutrition labelling and voluntary "front of pack" nutrition labelling.

Allergen Labelling Guidance

In partnership with FDF, BRC has produced guidance on compliance allergen labelling requirements of the Food Information to Consumers Regulation in 2013, with accompanying addendum.

With a specific focus on the labelling of prepackaged foods that use gluten-containing cereals (i.e. wheat, barley etc.) and those that declare gluten-free claims, FDF has also produced guidance on gluten labelling which has been endorsed by Coeliac UK, Anaphylaxis Campaign and the British Retail Consortium.

Gluten Labelling Best Practice: How To Label Pre-Packed Foods Which Include Cereals Containing Gluten

FDF and the British Retail Consortium has also produced joint industry guidance for manufacturers and caterers on the appropriate use of "free-from" claims in relation to food allergens. The guidance contains a foreword from the FSA and has been endorsed by Anaphylaxis Campaign and Coeliac UK.

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The Food Standards Agency has also produced guidance documents on allergen labelling, specifically for small and medium businesses.

Nutrition and Health Claims

Regulation (EC) 1924/2006 on nutrition and health claims came into force on 19 January 2007 and applied from 1 July 2007. It seeks to protect consumers from misleading or false claims. It also makes it easier for manufacturers to identify nutrition and health claims that can be used on any specific food product.

The Department of Health has developed guidance, which gives regulatory and best practice advice and is designed to help food business operators, and others choosing to use claims about foods in a commercial context, comply with the Regulation.

What does Regulation 1924/2006 apply to?

Voluntary nutrition or health claims must comply with the requirements of the Regulation. A nutrition claim is a claim that states, suggests or implies that a food has beneficial nutritional properties, such as “low fat” or “high in fibre”. A health claim is any claim which states suggests or implies that health benefits can result from consuming a given food, such as “helps build strong bones”, “helps maintain normal blood cholesterol levels”. The Regulation also controls general references to overall health and well-being, such as “healthy” or “superfood”. Regulation 1924/2006 applies to claims made in commercial communications, including labels, leaflets, menus, adverts and websites.

What does Regulation 1924/2006 require?

The Regulation requires that nutrition and health claims made on foods are authorised before being used in Europe; the EU register of authorised claims is on the European Commission's website. Other key requirements of the Regulation are that:

  • Claims must comply with the general rules which include not being false, ambiguous or misleading; not encouraging or condoning excess consumption of a food; and not implying that a balanced diet cannot provide necessary nutrients.
  • If a claim is made it is it obligatory to provide nutrition labelling in most cases.
  • Only nutrition claims in the EU Register can be made and only if a product meets with the specific conditions of use for that claim. For example, “low fat” can only be made on a product containing no more than 3g of fat / 100g (for a solid) or no more than 1.5g fat / 100ml (for a liquid).
  • Health claims must be authorised and included in the list of authorised health claims in the EU Register before they can be used.
  • Health claims which suggest that health could be affected by not consuming a food cannot be made.
  • Health claims which make reference to the rate or amount of weight loss cannot be made.
  • Health claims which make reference to recommendations of individual doctors or health professionals cannot be made on food.

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