We are now a good few weeks into the post-Brexit era and navigating our way through the changes and challenges this has brought to the food industry. The final months of the transition period were particularly busy for anyone concerned with the regulatory aspects of food labelling – making sure necessary changes were in place before the 30 December 2020 deadline so that products could continue to be sold throughout the EU. That work still isn’t quite finished yet but thankfully for those of you who only sell to the UK market there is a bit of breathing space until 2022 to get everything in order.
The monumental increase in label/artwork checking in the latter part of 2020 meant there was clearly not enough hours in the day to lose reviewing amended versions 2 or 3 or beyond, and so it was highly important to make sure everything was correct or that all of the necessary amendments had been identified at version 1. The way I generally approach this is to follow a four stage review process, which I thought might be useful to share with you.
- Is it the correct product/recipe?
- Is the information technically correct as per the regulations?
- Is the information consistent?
- Read it again through the eyes of a consumer.
Before you start, make sure you have set aside enough time to do the review adequately and get rid of any distractions. If you are going to spot mistakes then you need to concentrate.
You will know exactly what I mean here! You have literally spent months (or longer) developing your product and modifying the recipe to perfection, so by this stage you must be absolutely sure you are using the correct and final recipe to establish your ingredients list, allergens and nutrition information. A few quick sense checks here and there are useful too – for example, if you know you are adding 1% salt to your product – do the nutrition values match and is there at least 1g/100g salt declared?
This is the bit that understandably takes the longest. First, you need to be confident that you know which pieces of legislation apply to your product. You must check carefully that all the mandatory information is included and presented correctly as specified in the regulations. For example, in addition to the selling title, have you included a suitable legal name for the food such as a customary name or a sufficient descriptive name? Are the ingredients all declared is descending order by weight including the sub-ingredients of any compound raw materials? Have you highlighted every allergen in the ingredients list? Is the nutrition table in the correct format/order? Are you making any authorised nutrition or health claims – and does your product comply with the necessary conditions? If you happen to be making products that are sold under a retailer own brand then you will have the retailer’s labelling policies to consider as well.
Consistency of the information on your artwork can mean two things. One, being consistent with the other products you already manufacture and sell – to convey your brand identity, and two, for consistency with other brands of the same or similar products. Compare to see if you are providing the same general information as the other brands and haven’t overlooked anything vital. Take care here though and don’t always assume that the other brands are 100% legal.
Finally, have a look at your new label from a consumer perspective. Absolutely no spelling mistakes! (Apparently, proof-reading backwards helps with this as it stops you from skimming the text – give it a go!). Is there anything that isn’t clear and might prompt consumer queries? Is photography realistic and representative of what will be inside the pack? Is the design eye catching and can consumers easily compare your product to something similar when they are walking down the shopping aisle? Is there enough contrast between the colour of the text versus the background and is the font type used clearly legible?
We’ve still got some time yet to get all our UK packaging compliant before October 2022, and I hope my hints might help make the process more structured for you whenever you are launching a new product or redesigning existing.
If you would prefer to outsource this important task, then don’t hesitate to contact a food regulatory/labelling expert who already does this crucial work day in and day out.
With over 20 years experience in ensuring regulatory compliance of food labels and specifications and carrying out nutrition analysis for back and front-of-pack labelling, AB Food Nutrition can review your product artwork and highlight anything that needs to change, suggesting ways you can amend so that you they meet the latest regulations and industry best practice. Contact Anne for a competitive quote today.