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
- 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!
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.
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.
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.
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:
- Additive-free or
- Contain flavourings that are natural as defined in European law or
- 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.
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.