Pre-packed

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.

Is sugar really hidden?

With all the headlines and TV shows around at the moment focussing on sugar and how we are consuming too much, one phrase I hear regularly is “hidden sugars” and how our food is “full of it”!

Having been involved in writing the information that must be shown on labels (otherwise known as pack copy) since my first job in the food industry some 18 years ago, this phrase really makes me sigh. By law all ingredients must be labelled – and that includes anything added that is deemed to be sugars, so it most definitely cannot be “hidden”.

Not only that, but one of the fundamentals of food labelling is that it “must not be misleading”, and I have been fortunate over the years to work with teams of labelling technologists who share my passion in making sure labelling is done with the consumer in mind. I can recall many hours deliberating over aspects of labelling information with such individuals, and then we still have to keep the marketeers in check to make sure they don’t get carried away with what I affectionately call “marketing fluff”! So, is it any wonder why we get upset when the media accuse the food industry of misleading and hiding things?

It seems that there is an overall lack of understanding amongst consumers as to what is actually classed as ‘free sugars’. As always, education plays a huge part because you can put all the information possible on a food pack, but it is useless if it is ignored or not understood.

The official definition of free sugars is, all monosaccharides and disaccharides added to foods by the manufacturer, cook or consumer, plus sugars naturally present in honey, syrups and unsweetened fruit juices. Under this definition lactose, when naturally present in milk and milk products is excluded.

So how do we educate consumers to enable them to choose foods ain order to meet the new dietary recommendation – of which free sugars should not exceed 5% (population average) of total dietary energy?

Firstly, consumers need to understand which foods generally contribute the most free sugars in the diet – so that they can choose to limit or reduce the amount and frequency by which they consume them. These foods include chocolate and sweets, cakes and biscuits and of course sugar-sweetened drinks.

Secondly, they need to understand the names of different types of free sugars so they can look out for them in the ingredients list on pack, and because the order is in descending order by weight, if a type of sugar appears near the beginning of the ingredients list, the product is likely to have more free sugars than one in which any sugars are at the end. Some common names for those added to foods are sucrose, glucose, molasses, dextrose, honey, invert sugar, treacle, glucose syrup and maltose.

There has also been a lot of discussion lately about how we can improve the labelling of free sugars to make it easier for consumers to meet the new maximum sugar intake recommendations. Currently, under EU law, sugar labelling shows the total sugar content – this includes both the free sugars and naturally occurring sugars, and from December it will be mandatory to include this information on the back of most packaged foods and drinks. The UK Government has also confirmed that it will introduce clearer visual labelling (such as teaspoons of sugar) to show consumers about the sugar content in packaged food and drink – though this will be voluntary. The government has even indicated that Brexit will provide “greater flexibility” in relation to front-of-pack nutrition information.

So, in the meantime, I urge everyone to use the information on pack that labelling experts like me have worked so hard to provide. If you need some inspiration to help you cut back on those free sugars how about making some of these little changes to your diet:

Use fruit such as raisins, dried apricots, dates or bananas instead of sugar, which naturally add sweetness to breakfast cereals and plain yogurt.

Sweet-tasting, spices like cinnamon, nutmeg, cloves and ginger are a great way of adding flavour when preparing foods at home.

Try just a thin layer of jam or marmalade on wholegrain toast.

Swap sugar-sweetened beverages to sugar free drinks or better still water, tea or coffee (without adding sugar!).

 

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.

Food Information Regulations – 1 year on…

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

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