Breaking News: UK definition on ‘small quantities and ‘local’ for nutrition labelling

On 13 December 2014, new rules set out in Regulation (EU) No. 1169/2011 on the provision of food information to the consumer (FIC) became applicable. The provision of nutrition information on a mandatory basis for prepacked foods was introduced in this regulation, however in order to give food businesses time to prepare, the date of application was set at 13 December 2016.

Annex V of this regulation provides a list of foods that are exempt from mandatory nutritional labelling. Included in this list is ‘food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer.’

The FIC does not define ‘local’ nor ‘small quantities’ in the exemption. The Commission has said that the interpretation of the exemption is left to individual Member States.

The Department of Health consulted on the issue with key stakeholders from the end of last year / early this year, and I have just received confirmation direct from the Department of Health on the final decision:

The EU definition of a micro-business will be used to define ‘small quantities’, which is

  • a business with less than 10 (full time equivalent) employees
  • turnover/balance sheet total of £1.4 million (the equivalent of €2m).

 

Local retail establishments’ means  ‘sales within the supplying establishment’s own county plus the greater of either the neighbouring county or counties, or 30 miles/50 kilometres from the boundary of the supplying establishment’s county’.

The Department of Health have updated the technical guidance to reflect this interpretation.  The guidance is available here.

Here is a link to a useful Q&A document from the Food Standards Agency.

However, it is important to note that where a permitted nutrition or health claim appears on the labelling, presentation or advertising, nutrition labelling then becomes compulsory (Regulation (EU) No. 1924/2006 lastly amended by Regulation (EU) No. 1047/2012).

If you believe you may be exempt from mandatory nutrition labelling, it is advised you seek advice from your local enforcement authority.

If you do need to apply back of pack nutrition labelling – but have not yet put plans in place, please contact Anne to discuss your requirements and to obtain a competitive quote.

Six months to Christmas… and mandatory nutrition labelling!

christmas decoration

So, with just six months until Christmas – time to start planning your marketing, events and orders …oh… and don’t forget – your mandatory nutrition labelling!

That’s right – the Food Information Regulation (FIR) deadline will be here before you know it. 13th December 2016 to be exact! But, more importantly, you still have time to do something about it if you haven’t already put plans or resources in place to update your labels.

 

So then, a quick reminder of what is required. From 13 December 2016, it will be mandatory to provide “back of pack” nutrition labelling for prepacked food, subject to certain exemptions contained in Annex V of EU Regulation 1169/2011. These exemptions relate mainly to minimally processed foods and those with little nutritional value. (This does not apply to food supplements, natural mineral waters or PARNUTS because these fall under the scope of other Directives with their own nutrition labelling provisions).

You can read more detail on the requirements and presentation of this information in my previous blog post.

But don’t forget, if you offer food for sale via a website, telephone orders or similar, the mandatory nutrition information must also be made available before the purchase is concluded.   The rules for mandatory nutrition labelling also apply if you supply prepacked food to mass caterers for further preparation.

So why, you may ask, have these rules become law?

The prime reason is to enable consumers to make informed choices about the foods they use to suit their dietary needs. The 2007 White Paper “A Strategy for Europe on Nutrition, Overweight and Obesity related health issues”, stressed the need for consumers to have access to clear, consistent and evidence-based information. Having nutrition information provided on packs assists with public health policies concerning nutrition education. Additionally, it’s presence on all products means it will be relevant for all shoppers in every price and product category.

How can I get the nutrient values for my products?

There are basically two options, you can send samples of your finished products to a laboratory for analysis, or the average values can be calculated using known values of the ingredients used and/or generally established & accepted data (such as McCance & Widdowsons 7th Edition).

AB Food Nutrition offers a cost effective, confidential and personal calculation service (contact anne@abfoodnutrition.co.uk for further information and quotes).

It’s important to remember though, that if you regularly make changes to your products the nutrition information will most likely be impacted and so another nutrition analysis or calculation will be required – something to consider when choosing which method you want to use versus overall costs. Additionally, any new products developed after the December deadline will need to have the nutrition information included on the label before you can launch it.

BNF Healthy Eating Week in the Workplace 2016

The British Nutrition Foundation is running another Healthy Eating Week between 13 – 17 June. The purpose is to provide a dedicated week in the year where UK workers and school children can simultaneously focus on healthy eating and drinking, and physical activity, in order to encourage healthy living.

Promoting health in the workplace is not only beneficial to employees but also to employers.

Healthy Eating Week Logo Welsh

You can sign your workplace up for free and download the guide to help you plan and organise your Week and provide ideas to meet the Week’s five challenges (Have breakfast; Have 5 A DAY; Drink plenty; Get active; Try something new).

If you are interested in hosting Healthy Eating Week in your workplace and need some consultancy advice or assistance with your planning, contact Anne at AB Food Nutrition (anne@abfoodnutrition.co.uk). Here are just a few ideas we could help you with:

  • which foods & drinks to include in a healthy breakfast for a morning meeting
  • provide recipes for healthy breakfast ideas that you can email to employees
  • 5-a-day portion guides and tips to include more veggies in meals
  • work with your staff canteen to offer healthier meals and snacks
  • recipe analysis to provide calories for menus

 

Why it’s a good idea to use professionally trained nutrition experts…

Nutrition labelling must be accurate. Displaying the nutrition information on back of pack is governed by strict food labelling legislation, and the most important rule of food labelling is that the consumer must not be misled. The calculation of nutrient content is very cost effective compared to laboratory analysis (which is approx. 3 times more expensive) – but this can be a difficult task for smaller food businesses that have little or no nutrition and food composition expertise. There are lots of calculation software packages available but the use of these are limited by the need to accurately match ingredients to available food composition data and take account of nutrient changes during production.

Working with technical experts, such as Registered Nutritionists and Dietitians will add credibility to your business. Such experts are professionally trained to calculate and validate comprehensive nutritional analysis based on McCance & Widdowson food and nutrient composition tables. We can also advise on relevant changes to recipes to improve the nutritional profile if required, particularly if you want to make nutrition or health claims. Nutritionists registered with the Association for Nutrition (AfN) work under a strict code of Ethics and Statement of Professional Conduct – absolute confidentiality is guaranteed.

Registered Nutritionists have demonstrated knowledge including a BSc (Hons) or MSc in a nutritional science; applied skills in relation to nutrition and competence to advise on nutrition. They are required to keep up to date through Continuing Professional Development.

Outsourcing your recipe analysis can give you peace of mind particularly if you are juggling lots of work under a tight deadline and you need to focus on creating brilliant products rather than the technicalities of the food labels. Calculated recipe analysis is anything but a simple exercise of addition. To maximise accuracy, the nutrient information for exact amounts of specific ingredients needs to be adjusted for any preparation or cooking technique — an undertaking that requires an in-depth knowledge of food and nutrition. It’s worth noting that any recipe analysis won’t be exact, average values allow for natural variability of foodstuffs as well as seasonal variability, however, it’s important that the actual nutrient content of foods should not deviate too substantially from the labelled values. Hiring an expert to analyse your recipes costs money, but the cost of not doing it right can be exponentially higher.

With a 17+ years food industry and retail background, AB Food Nutrition has many years of experience calculating the nutrient composition of recipes for labels, menu boards and magazines. From just your product recipe we can take the hassle out of nutrition labelling compliance whilst providing an inexpensive, confidential and personal service to your business.

Look our for hidden salt – 17th Salt Awareness Week House of Commons Reception, 2016

hidden salt cash logo

Salt Awareness Week is an annual campaign, run by Consensus Action on Salt and Health (CASH), to help reduce the amount of salt in our diets and, as a result, improve public health. Since its inception in 1996, a lot of progress has been made – a number of foods are now 50% lower in salt than they were 10 years ago. However, many of us are still consuming more than the recommended maximum intake of 6g of salt a day, which means that there is still work to be done.
[Professor Graham MacGregor, Chairman of CASH] It is now 20 years since it was first set out to reduce salt in the UK. We are still well away from the 6g max per day – we all have a responsibility to read food labels and choose foods with less salt.

HoC

The House of Commons reception is an opportunity for Industry & MPs to join and discuss the future of salt reduction in the UK. Exhibitors this year included Co-op, Waitrose, Subway, Kudos Blends, Low Salt, McCain and Stroke Association, with many other supporters of the week itself.

[Sir David Amess, MP] CASH survey – released at the start of salt awareness week found that salt had increased in DApopular supermarket foods: Canned Tomato Soup, White Bread, Cheddar, Cornflakes and Chilled Ready Meals. Some were found to contain more salt that a Big Mac or slice of Dominos Pizza and bread is one of the largest contributors of salt in the UK diet. The Responsibility Deal is to blame. Since 2010, the food industry has been policing itself and little has been done to reduce salt in products. When the FSA were responsible, they set targets for 86 categories resulting in salt reductions that effectively saved the NHS £1.5 billion.  Decreasing salt by just a pinch a day can prevent 4,000 deaths from stroke every year.

Urgent action is needed to improve the nation’s health and an independent agency needs to be responsible for setting targets for salt, sugar and saturated fat.

[Lord John Krebs, Former Chairman FSA] 2003 SACN report on salt & health found that reducing salt would benefit LKeveryone not just hypertensives. Salt was the cheapest way to flavour food that had none or little flavour – so the food industry were concerned that consumers wouldn’t like it. One year later came the “Sid the Slug” TV campaign after which major retailers noted that consumer queries were mainly about salt. Reducing salt then became a marketing advantage, so despite a 15% reduction in between 2003-2011 it is disappointing that 20 years later efforts have slowed or reversed. More must be done whether it means working with industry or regulation. There needs to be more use of food chemistry/sensory techniques to look at salt alternatives more creatively. Salt is one of the easiest nutrients to reduce, but there should also be focus on fat and sugar – dietary disease is just as much an issue as alcohol and smoking.

 

[Andrew Gwynne, MP] Between 1998-2000 salt in cereals decreased 44%, 2004-2008 salt from out of home DGpurchases decreased one third. It is sad to see this has slowed – the Responsibility Deal has failed and we have seen those steps forward made going back again. It is hoped that when the Childhood Obesity Strategy is launched – that it will tackle high salt food. Labour opposition will do all that they can to make sure Government steps up to its responsibility. They will support Government in making sure messages are heard and in legislation if it’s needed because the public health gains are too important.

 

 

[Professor Graham MacGregor, Chairman of CASH] In the 20 years since CASH was set up, we now know that diet is Profthe biggest cause of death/disease. Nutrition was taken away from the Department of Health to the FSA – this was a great move in reducing salt in the UK. Around the world, approx. 70 countries have copied the UK plan with slight modifications such as regulation. Many members of industry would prefer legislation – as this creates a level playing field. Andrew Lansley restructured the health service, introducing the Responsibility Deal and putting the food industry in charge. This hasn’t worked. The latest NDNS 24 hour urinary sodium excretion result will be available soon and using this CASH will be able to calculate the number of deaths that should have been prevented since the control for salt reduction was taken away from the FSA. The Responsibility Deal was under the coalition government so is now finished and nothing is happening. Hoping that this year there will be positive news from the Prime Minister.

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