It’s now been over one year since the deadline by which food businesses had to adjust their labels to comply with EU Regulation 1169/2011, which applies to all foods intended for the final consumer including those intended for supply to and delivered by mass caterers. This even includes foods sold by distance eg. Internet or telephone orders. (Exemptions are listed in annex V in addition to those with specific EU directives such as PARNUTS, Natural Mineral Waters)
If you are selling pre-packed foods and providing the nutrition information on the label, or have made a nutrition / health claim, then here is a summary of what you should already be doing:
The nutrition table on back of pack must include the energy value and the amount of fat, saturated fat, carbohydrate, total sugars, protein and salt. You may also voluntarily include mono-unsaturates, polyunsaturates, polyols, starch, fibre and those vitamins & minerals listed and present in significant amounts as defined in annex XIII. Only if space does not permit, can the declaration be made in a linear format.
The amounts must be expressed as sold per 100g or 100 ml in the order & using the units specified in annex XV, whilst energy values must be provided in kilojoules (kJ) and kilocalories (kcal). If you want to provide the values as cooked, then the cooking instructions must be included on the pack and the values must relate to the food as prepared by those instructions.
You can also provide the amounts on a per portion basis so long as the portion can be recognised by the consumer, the portion unit is quantified on the label and the number of portions in the pack has been stated. The % Reference Intakes (RI) can be included in the table (% NRV for the vitamins and minerals) and can relate to ‘per portion’ or ‘per consumption unit’. Where the % RIs are stated, the following statement must be added to the label in close proximity: Reference intake of an average adult (8 400 kJ / 2000 kcal).
Reference Intake of an average adult (8400 kJ/2000 kcal)
Contains 6 portions
So who enforces these labelling rules?
Local authority Trading Standards Officers or Environmental Officers check and monitor to see if food businesses are providing the correct information to consumers. If you are found to be in breach of the rules, the local authority should work with you – using a step by step approach to corrective action. If you fail to act upon previous advice, an Improvement Notice (penalty) may be issued, and this formally outlines corrective steps to be taken within a set period of time.
And what should you do if you think your labels are not fully compliant?
Get some advice or have your labels checked and signed off. If you get them wrong, you may have to label twice – which will increase your costs! Having labels checked by a suitably qualified person would demonstrate that you took reasonable precautions and exercised due diligence.
Link to regulation EU 1169/2011