Labelling

The rise of home food businesses

This is the first blog I have had chance to write since the UK was placed into Covid-19 lockdown (100 days ago today!) so I would like to start by saying that I hope you and your families are well whether you are working as normal or have found that work is now busier/quieter than usual or you have had to adapt to working whilst simultaneously home schooling the kids.

One observation that became apparent when we entered the strange world of lockdown was a return of community spirit.  It was admirable to see people helping neighbours with grocery shopping and even putting their own home economic skills into good use making food accessible and available to those who were self-isolating or shielding.  It was also understandable why those on furlough or who have lost most of their income, would seek alternative ways to make money by using their cooking/baking skills whilst staying at home. 

However, as all existing food business owners I’m sure will agree, starting-up a food production business is no easy task and brings with it huge responsibilities.  It’s not just as simple as make food and sell it – there are a raft of legal obligations and standards in place to ensure products are safe to consume, are made following strict hygiene regulations and that product information is presented to a standard that does not put people’s health at risk. 

First and foremost, if you wish to start preparing, cooking, storing, handling, distributing, supplying or selling food – you must be registered as a food business operator with your local authority. This is free to do, and the registration cannot be refused.

It is an offence to operate a food business without being registered – and this includes voluntary, charitable, people operating at home and via the internet as well as those on the high street.  It doesn’t exclude people who are operating from home even if the food is supplied for free.  If you are simply baking a couple of times a year for the school fete then this wouldn’t require registration but producing a tray bake once a month for a café for example, would.

Once registered, you may be inspected and given a food hygiene rating, so it’s important to ensure you have all the right procedures and record keeping in place from the start.  If you are new to the food industry it is most likely (and highly advisable) that you will require appropriate training/mentoring/experts to help you with the following start-up checklist:

  • Does the design & construction of your food preparation area meet legal requirements?
  • Have you invested in the right equipment?
  • Are you aware of the main food law requirements?
  • Do you keep written records of all the food ingredients you are buying or being supplied with?
  • Have you put food safety management procedures in place and are the records kept up to date?
  • Do you understand the principles of good food hygiene?
  • Have you considered health & safety arrangements?
  • Have you registered as self-employed?
  • Are you keeping records of all your business income and expenses?
  • Do you describe/label food and drink accurately and in compliance with legislation?
  • Are you aware of all the allergens in your products, including those present in your home for domestic use and are they communicated properly?
  • Is the packaging you are using suitable for food contact?
  • Do you have public liability and product liability insurances?
  • Do you need to apply for a licence to sell alcohol or hot food between 11pm and 5am?

The Food Standards Agency has developed this useful ‘Safer food better business’ pack specifically for small catering businesses.

I also asked some fellow North West food & drink businesses who have been there and done all the above to share their top tips for start-ups:

Do your research and then check, check and check again. Then get someone qualified to check it too! Don’t just copy existing similar products on the shelf as its 99% certain NOT to be suitable to copy especially where weights and measures and the Estimate symbol are concerned.” The Nowt Poncy Food Company Ltd, @nowtponcy


My tip is the Safer Foods Better Business website. It’s got all the documents and paperwork you need, and plenty of guidance. Make sure you register with the local authority, and use them for advice and guidance as well as inspection, they are there to help as well.” The Sunflower Kitchen, @TheSunflowerKi1


Ensure your labels are up to date with the necessary information and have the correct allergen advice.”  Farm Yard Ales, @farmyardales


Whilst this article aims to point out the main things for you to consider when starting a food business, the good news is that there is absolutely no reason why properly-registered people should not sell food they have prepared at home – it can be done safely!

With over two decades of food industry experience, Anne founded the award-winning AB FOOD NUTRITION to work closely with businesses of all sizes ensuring they can fully inform consumers about the ingredients, allergens and nutrition information legally, whilst also enabling them to make healthier dietary choices.  Contact Anne for further information about our nutrition and labelling services.

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4 reasons you need a food & nutrition labelling consultant

Maybe you are puzzled at why companies might hire consultants instead of solving their own problems themselves? As much as I hate to hear it, that question does make sense however, there are many reasons why a company might need to use a consultant to help with their nutrition and labelling obligations (and also why I am able to keep working with some of the coolest foodies in the industry!).

 

You might not want the responsibility of verifying all the information on your own

Labelling rules are strictly regulated and can get complicated when trying to establish if you have included all the mandatory information correctly, taken account of the minimum type sizes for the text on your label in addition to any specific declarations that may apply to your product type.

A labelling consultant is there to support you in producing compliant labels.  They are the experts who know what can or cannot be printed on the label and they are aware of which sets of regulations will apply to your product type no matter how complex that may be.

You are just starting out in the food industry

No doubt you have done tons of research looking at competitor products so that you can make your label the best and the most eye catching.  However, if your competitor makes certain claims on their packs, this doesn’t mean that you should too.

Consultants will advise you what is compliant rather than what sells best in the market place.  Brands who break the law do so at their own risk and are likely to be challenged by the authorities eventually.

You don’t have the time to learn about labelling laws

Perhaps you are launching several products at once or have just won a new retail contract with a very tight launch timeline.  Maybe you just don’t have the energy or desire to check your label designs are compliant amongst all the other important tasks required in the running of your expanding business?

By nature, consultants will provide advice that clearly keeps their client within the law, so do exactly what a labelling consultant tells you!!  Obvious I know, but there are so many regulations under constant change, it would be almost impossible for small businesses to keep up. Once you have established your product portfolio and had your labels reviewed, it should become a routine task to add more SKUs in the future if they are of similar ingredients.

You want to hire an experienced and knowledgeable labelling expert

In an ideal world, you would have a team of experts in-house, but the reality is, the number of hours and frequency you would need them means employing these experts full-time is not an option.

This is where the flexibility of using a consultant really comes into its own. You only pay for the services/time the consultant provides.  You also benefit from projects being completed speedily because your consultant (unlike in-house employees) isn’t distracted by other business tasks.  This means good value for money!

It may seem like a big investment or effort to employ a food and nutrition labelling consultant, though you may find that you are eligible for funding or grants that will cover some or all of the fees.  AB Food Nutrition specialises in working closely with organisations of all sizes and has years of experience supporting new and small food businesses not just in the North West, but across the UK. Contact Anne to discuss your requirements for a cost-effective food & nutrition labelling quote.

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A vegan and allergen quandary

Imagine this: It’s a Saturday morning and I’ve lovingly made a nutritious breakfast of scrambled eggs on wholemeal toast for my daughter before she heads off out to play in a footy match.  I then put away and clean up everything ready for my two friends Amanda and Tania, who are joining me for brunch.  Now, my friend Amanda is vegan and so I have opted to make us all a vegan fry-up of hash browns, mushrooms, tomatoes, scrambled tofu and baked beans.

I then remember that Tania has severe egg and milk allergies so although she can still enjoy my vegan fry-up – how do I know that absolutely all traces of egg and milk have been removed from my kitchen since I made my daughters scrambled egg this morning?? The answer is…I don’t!

 

 

And there you have it! Now, as the Vegan Society explains “Products suitable for vegans may not be suitable for people with allergies. Vegans avoid exploitation of non-human animals, whereas people with allergies need products that do not contain the allergens that affect them. These are separate issues.”

Just in the same way that companies assess whether their products may contain major allergens I had to decide whether I thought Tania would be safe eating my vegan fry-up in the same kitchen where I had previously made scrambled eggs.  If there is a risk, the label carries a ‘may also contain’ warning.

So why did M&S come under so much fire with the launch of their new plant kitchen range?

The Vegan Society states it is “not against foods labelled as vegan also carrying a ‘may contain warning about animal allergens”, and an M&S spokesperson quite rightly pointed out that “vegan products may not be suitable for people with severe allergies because allergens may be present in the environment in which they are made.  This is clearly flagged on the packaging as a steer to those who need it.”  However, many disagree and feel that it is misleading to state something is vegan whilst also stating that it may contain small amounts of dairy products.

The food industry must adhere to strict rules concerning allergen labelling, which is heavily regulated, yet the term ‘vegan’ is only used by industry voluntarily so, how can it be used accurately when no legal definition exists?  (Note: the EU Commission announced it would begin the process to establish a legal definition this year, but this will not automatically apply to the UK post-Brexit).  In the meantime, there needs to be more education for consumers to understand that “vegan” does not automatically mean “free from” and as always, it pays to read the label every time!

AB Food Nutrition works with manufacturers and caterers to provide allergen information to consumers on labels, menus and websites. We can work with you to implement procedures for updating and signing off allergen information. Contact Anne for further information about our cost-effective consultancy services.

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Unhealthy high streets

Last week it was featured in the news, a report identifying the UK’s unhealthiest high streets.  High streets were ranked by the Royal Society for Public Health (RSPH) according to the numbers of payday lenders, bookmakers, tanning salons and fast food outlets.  There was a clear link between deprived areas and unhealthy high streets with Grimsby, Blackpool and Walsall topping the list in contrast to Edinburgh, Canterbury and Taunton which had the healthiest high streets.

In recent years there has been a proliferation of fast food outlets (FFOs) in the most deprived areas – but why is this an issue?  To start with, there is plenty of evidence backing the link between the frequency of visiting FFOs and health outcomes such as weight gain, insulin resistance and high blood pressure.1 A recent study added further weight to this evidence by finding an association between FFO exposure, fast food consumption and obesity.2  These associations are hardly surprising given that fast food tends to be energy-dense, high in salt and served in large portion sizes.

Despite the reputation though, we have all had fast foods in our time and as the old saying goes ‘everything in moderation!’ I was quoted in an article a couple of years ago suggesting ways to make healthier choices when ordering your favourite takeaway:

  • Switching creamy curries to tomato-based dishes such as tandoori and madras
  • Opt for steamed dishes rather than fried foods
  • Choose diet/sugar free soft drinks instead of regular ones

 

Public Health England also announced in March 2018 a challenge for the whole food industry to reduce calories in foods (most commonly eaten by children) by 20% by 2024.  The introduction of the sugar levy has resulted in widespread reformulation amongst high profile soft drinks manufacturers resulting in commercially successful lower-sugar options.

The government is currently consulting on plans to make the display of calorie information mandatory in out-of-home food and drink outlets because some research suggests that this is effective in reducing overall calorie intake.  (Read my previous blog about this).

 But what can you start to do today in order to provide healthier options?  Now, I‘m not saying take chips off the menu – but you can make small changes to top-selling items to make a big impact!  Look at ways you can modify your existing recipes by the types and amounts of ingredients used and also in the way you cook and prepare the dishes.  Here are some of my top tips:

Reduce calories by switching from double to single cream
Use thick cut chips or wedges in preference to thin cut fries
Use rapeseed oil for frying and remember to drain food well by giving it a good bang and shake
Dry fry meats where possible after trimming away visible fat
Try to include more vegetables into dishes and use seasonal, frozen or canned to keep costs down

 

AB Food Nutrition works with manufacturers and caterers to provide nutrient composition values of their products for labelling & menu boards and also during product development or reformulation. We can work with you to find ways to make existing dishes healthier and provide support in complying with the law if you want to make nutrition claims. Contact Anne for further information about our cost-effective nutrition and labelling services.

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1  Health on the High Street, RSPH, 2018
2  Burgoine, T., Sarkar, C., Webster, C.J., Monsivais, P., 2018. Examining the interaction of fast-food outlet exposure and income on diet and obesity: evidence from 51,361 Biobank participants, , International Journal of Behavioural Nutrition and Physical Activity, 15(1):71 doi: 10.1186/s12966-018-0699-8.

So what can I really say about my traditional artisan products made with natural ingredients?

The marketing of food is essential for businesses to develop within the food industry however, they have the potential to mislead when used incorrectly.  It’s a particularly tough job for small businesses looking to find the best way to communicate the differences between their products and mainstream commercial foodstuffs.

When using marketing terms responsibly, food business operators need to be aware that there are general principles to be followed in the provision of food information to consumers:

Article 7 Regulation (EU) 1169/2011

  1. Food information shall not be misleading, particularly:

(a) as to the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production;

(b) by attributing to the food effects or properties which it does not possess;

(c) by suggesting that the food possesses special characteristics when in fact all similar foods possess such characteristics, in particular by specifically emphasising the presence or absence of certain ingredients and/or nutrients;

(d) by suggesting, by means of the appearance, the description or pictorial representations, the presence of a particular food or an ingredient, while in reality a component naturally present or an ingredient normally used in that food has been substituted with a different component or a different ingredient.

To assist with compliance however, you will be glad to know that there is some industry guidance available on the use of some certain and increasingly popular marketing terms!

 

ARTISAN

Should only be used to advertise foods that meet all of the following criteria:

  • The food is made in limited quantities* by skilled craftspeople*
  • The processing method is not fully mechanised and follows a traditional* method
  • The food is made in a micro-enterprise* at a single location
  • The characteristic ingredient(s)* used in the food are grown or produced locally*, where seasonally available and practical.

 

FARMHOUSE

To state that food originates from a farm, it must meet all of the following:

  • The food is made in a single location on a farm*
  • The food is made by a micro-enterprise*
  • The characteristic ingredient(s)* used in the food are grown or produced locally*

However, there are foods that have used the term ‘farmhouse’ for many years and are well understood by the consumer and so they may continue to be marketed this way even if they don’t meet all three criteria above eg. Bread with a split and rounded crust, coarse textured pâté and soup made with chunky vegetables.

The term ‘farmhouse’ would not be acceptable for fresh, pasteurised milk and cream however ‘farm fresh’ has been associated with these products for years and so can continue to be used.

 

TRADITIONAL

This implies that food is made to a time-honoured recipe or in a time-honoured way and so must comply with at least one of the following:

  • The food is made to an authentic recipe which can be proved to have existed without significant modification* for at least 30 years and/or
  • The food has been made using a method of preparation that has:
  • Existed for more than 30 years although automation and mechanisation of these methods is acceptable and,
  • Does not deviate substantially from the traditional food processing method associated with a certain type of food.

 

NATURAL

For single ingredient foods, the term can be used if the food* is formed by nature and is not significantly interfered with by man*, but also only if this would not be the case for other similar foods (such as processed or containing additives).

Compound foods by their very nature have been formed by man so cannot be ‘natural’ however, if different to other similar compound foods they may use the description ‘made with natural ingredients’ if:

  • The ingredients* are formed by nature and are not significantly interfered with by man*
  • The ingredients* and the final food are:
  1. Additive-free or
  2. Contain flavourings that are natural as defined in European law or
  3. Contain other food additives that are obtained from natural sources, e.g. plants, by appropriate physical processing (including distillation and solvent extraction) or traditional preparation processes.

You can see these sorts of claims on the recently launched nitrite free bacon or hams.

Dairy products have for many years included ‘natural’ in their product name to indicate they are only made from milk using starter cultures necessary for fermentation but are free from other additives, flavourings and colours eg. Natural yogurt.

 

* further information on these definitions can be found in the FSAI Guidance Note 29 and also FSA Criteria for the use of terms fresh, pure, natural etc..

 

Food Labelling can be difficult and stressful when working to tight deadlines as it often involves being aware of the minefield of legislation and codes of practice to understand which your product labels must comply with.  AB Food Nutrition has the knowledge and experience to help you label your foods legally whilst exceeding your expectations with our friendly, reliable and cost-effective solutions.  Contact Anne for further details.

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