European Food Information to Consumers Regulation

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European Food Information to Consumers Regulation

• REGULATION (EU) No 1169/2011
• Brings together general food labelling and
  nutrition labelling.
• Published in November 2011 transition to the
  new labelling rules underway.
• Most of the general labelling requirements apply
  from 13 December 2014, with nutrition
  declarations needed from 13 December 2016

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Basic Principles

• High level of protection of consumers health
  interests
• Assist in the free movement of foodstuffs -
  Internal Market
• Food information should not be misleading be
  provided in a clear, accurate easy to
  understand format for the consumer so they can
  make informed choices
• Food businesses have responsibilities throughout
  the food chain.

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Definition of Food Information to Consumers
information concerning a food and made available
to the final consumer by means of a label,
other accompanying material, or any other
means including modern technology tools or verbal
communication
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List of mandatory particulars

1. name of the food
2. list of ingredients (Physical condition or
   treatment, Added proteins if of a different
   animal origin (meat products/preps fishery
   products)
3. allergens
4. Quantitative Indication(if necessary)
5. net quantity of the food
6. date of minimum durability or "use by" date
7. any special storage conditions and/or conditions
   of use
8. name or business name and address of the food
   business operator

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List of mandatory particulars

• country of origin or place of provenance where
  provided for
• instructions for use where it would be difficult
  to make appropriate use of the food in the
  absence of such instructions
• alcoholic strength by volume for beverages
  containing more than 1.2 by volume of alcohol
• nutrition declaration
• Lot number separate rules
• On the same field of label

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Additional mandatory information

• Substances causing allergies or intolerances
• The name of the substance as listed in Annex II
  must be emphasised through a typeset that clearly
  distinguishes it from the rest of the list of
  ingredients, for example by means of the FONT,
  style or background colour.
• INGREDIENTS Wheat flour, water, eggs, vinegar,.

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EU list of allergens (new Annex II is the same as
previous Annex IIIA)
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Whats on a label? prepacked food
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Emphasis of allergens in label (Article 21)

• In an ingredient list
• Allergen highlighted e.g.
• Peanuts
• Peanuts
• Peanuts
• Peanuts
• Peanuts,salt,butter,chocolate
• Peanuts
• If no ingredient list then on the wrapping with a
  statement e.g. Contains Peanuts

Will need to be emphasized.
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Name of allergen in ingredient list (Article 21).
Ingredients Wheat flour, casein (Milk), sugar,
water
Tahini(Sesame) Tofu (Soya) Albumen (Egg) Lactose
(Milk) Whey (Milk) Ghee(Milk) Tilapia
(Fish) Prawn (Crustacean) Oyster
(Mollusc) Yoghurt (Milk) Cheese(Milk) Butter
(Milk) Cream (Milk)
Derivative followed by allergen name.
BRC opting to use this format
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Allergens (Article 21).

• Not required if allergen listed in name of food
• Contains ... if no INGREDIENTS list e.g. An
  allergen may be used in preparation of food that
  does not need an ingredient list e.g. Wine that
  contains sulphites. This would require the
  statement Contains sulphites..

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Position on Advice Boxes (Article 21).

• The allergen details need to appear in the
  ingredients list.
• Allergy Advice boxes will disappear but may be
  replaced with a statement e.g. Food allergens
  are highlighted in the ingredients list

Old
New
Food allergens are highlighted in the ingredients
list.
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Allergen information for loose food (Article 44
(1A))

• FBOs are required to provide information on Annex
  II allergens used in the preparation of foods.
  This applies to FBO such as e.g.
• caterers,
• delicatessen,
• butchers,
• bakers,
• confectioners,
• stalls and vehicles selling loose unwrapped food.
  
• In addition manufacturers supplying these FBOs
  also have to provide the appropriate allergen
  details relating to their food.

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• Non-prepacked food
• The allergenic ingredient must be declared
• Can use a contains statement, charts, tables etc.
• e.g. Pasta Contains wheat, eggs
• Consider accessibility of allergen information.
  Signposting to where information could be found
  when it is not provided written and upfront.
• Information and signposting should be where
  consumer would expect to find allergen
  information e.g. in a folder, on menu board, at
  till or on the menu card
• Food Allergies Intolerances
• Before you order your food and drinks,
• please speak to our staff
• if you have a food allergy or intolerance

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Communication is key

• Accuracy is dependent on correct labelling,
  updating information, updating staff and
  consumers
• The person buying the food
• The person handling the food
• The person taking the order
• The person ordering the food
• Regular reviews, keep information current
• Regularly review the ingredients information
• Where ingredients change, review the accuracy of
  the recipe
• Do your garnishes or dressings change the
  allergenic profile? Check!

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ResourcesLink http//www.food.gov.uk/business-i
ndustry/allergy-guide/allergen-resources
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Material for schools
Allergy Adventures poster for children
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Poster for secondary schools
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Legibility minimum font size

• Most frequent consumer complaint small print on
  labels
• minimum font size
• 1.2 mm (x-height)
• 0.9 mm largest surface lt 80 cm²
• Commission expected to introduce rules - on other
  aspects - for legibility

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Distance selling

• In the case of foods offered for sale by means of
  distance communication, mandatory food
  information to be available before purchase is
  concluded and to appear on the material
  supporting the distance selling or be provided
  through other appropriate means clearly
  identified by the food business operator
• All mandatory information to be available at the
  moment of delivery

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Scope of Regulation EU FIC

• Mandatory information applies to all food within
  supply chain and all FBOs along that chain
  (charities and fairs can be excluded provided
  that they are not operating as a business)
• Transport (e.g inflight catering within MS) are
  included within scope e.g to provide information
  on allergens
• Mis-leading food information
• Responsibilities of the FBO FIR changes
  responsibility to
• Operator under whose name a food is marketed or
  imported.
• If FBO changes label they are liable for the
  accuracy and safety and information must not
  mislead the consumer.
• Business to Business communication Duty on all
  FBOs to cascade information to ensure that the
  consumer can be accurately informed.

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EU FIC Nutrition labelling

• Nutritional labelling will become mandatory for
  most prepacked foods from 13 December 2016
• EU FIC also contains rules governing the
  provision of voluntary nutrition information
• - repeat nutrition labelling on front of
  pack of prepacked foods
• - nutrition labelling for non-prepacked foods
  -
• - nutrition (energy) labelling for alcoholic
  drinks
• Manufacturers that voluntarily put a nutrition
  table on a label must meet the requirements of EU
  FIC
• If a food makes a nutrition/health claim or if
  manufacturer adds vitamins/minerals to food, must
  make nutrition declaration
• Nutritional labelling rules do not apply to Food
  Supplements or Natural Mineral Waters

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Exceptions to nutrition requirements.

• Un processed single ingredient
• Water/flavoured water
• Herbs and spices
• Salt and its substitutes
• Table top sweeteners
• Coffee
• Herbal/tea/fruit infusions
• Fermented vinegar
• Flavours/additives/process aids/enzymes.
• Jam and setting compounds
• Chewing Gum
• Yeast
• Packages lt 25cm square

• Food (inc handcrafted food) directly supplied by
  manufacturer of small quantities to final
  consumer or to local retail establishments
  directly supplying the final consumer.

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Voluntary Information front of pack

• Energy value or
• Energy value plus
• Fats
• Saturates
• Sugar
• Salt

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Example

• Tabular preferable but if space is limited it can
  be linear.
• Information can be repeated on Front of pack
  (1.2mm font x height).
• Energy Value
• Energy value plus (fat, saturates, sugars and
  salt)

Per 100g
Energy kJ/ Kcal
Fat g
Of which saturates g
Carbohydrate g
Of which sugars g
Protein g
Salt g

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Annex XV Nutrition Declaration
Per 100g
Energy kJ/ Kcal
Fat g
Of which Saturates Mono-unsaturates polyunsaturates g g
Carbohydrate g
Of which sugars g
Polyols starch g g
fibre g
Protein g
Salt g
Vitamins/ minerals Units in Annex XIII
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Additional Nutrition Information

• There is a list of vitamins and minerals in Annex
  13 which may be declared and rules on significant
  amounts. E.g. 15 NRV by 100g or 7.5 NRV per
  100ml for beverages.
• Whilst nutrition information required on a per
  100g/ml basis is mandatory, there is allowance
  for additional per portion information allowed
  voluntarily.
• Reference Intake information may be provided
  voluntarily on a per 100g/ml or per portion basis
• If a nutrition claim is made about any of the
  supplementary nutrient information then the
  mandatory provisions apply.

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Reference Intakes

• Information on Reference Intakes (RI) and the
  contribution a nutrient makes towards a
  RI(expressed as a percentage) can usually be
  found on the back or side of packaging. The
  percentage RI is sometimes repeated on the front
  of the pack.

Values Reference Intake
Energy (kilojoules) 8400kj
Energy (kilocalories) 2000kcal
Total Fat 70g
Saturates 20g
Sugars 90g
Salt 6g
Table on which calculations are based taken from
Regulation EU 1169/2011
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Front of Pack Nutrition Labelling
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Revised New label for FoP

• To balance what is best for consumers through
  one, consistent label in UK market
• Compliance with Regulation No. 1169/2011 (EU FIC)
• Support and buy-in from food and drink
  businesses across the UK
• Remains voluntary for businesses, but if FoP is
  added it must comply with EU FIC by Dec 2014

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Front of pack labelling compliant with Reg
No.1169/2011

• Voluntary FOP information permitted on either
• - energy-only, or
• - energy plus fat, saturates, sugars salt
• Information can be provided as sold or as
  consumed
• Information can be provided per portion or per
  100g/mls
• Reference Intakes (GDA) information can be
  given on a per 100g/ml or per portion basis
• Additional forms of expression and presentation
  are permitted, subject to certain
• requirements.

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To consider

• Colour coding remains with four nutrients- fat,
  saturates, sugars and salt.
• Changes to thresholds for fat, total sugars and
  salt.
• Separate thresholds for food and drink
• Energy- in kilojoules and kilocalories
• High, medium and low text optional
• Term Reference Intake replaces GDA

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Determining red, amber and green colour coding

• Criteria for 100g of food . Portion criteria
  apply for servings greater than 100g

Text Low Medium High High
Colour code Green Amber Red Red
Fat lt 3.0g/100g gt3.0g to lt17.5g/100g gt17.5g/100g gt21g/portion
saturates lt1.5g/100g gt1.5g to lt5.0g/100g gt5.0g/100g gt6.0g/portion
Total sugars lt5.0g/100g gt5.0g and lt22.5g/100g gt22.5g/100g gt27g/portion
salt lt0.3g/100g gt0.3g to lt1.5g/100g gt1.5g/100g gt1.8g/portion
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Criteria for drink (per 100ml)Portion size
criteria applies to portions greater than 150ml
Text Low Medium High High
Colour code Green Amber Red Red
Fat lt1.5g/100ml gt1.5g to lt8.75g/ml gt8.75g/100ml gt10.5g/portion
Saturates lt0.75g/100ml gt0.75g to lt2.5g/100ml gt2.5g/100ml gt3g/portion
Total sugars lt2.5g/100ml gt2.5g to lt11.25g/100ml gt11.25g/100ml gt13.5g/portion
Salt lt0.3g/100ml gt0.3g to lt0.75g/100ml gt0.75g/100ml gt0.9g/portion
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Thresholds

• The green/amber thresholds are aligned to
  European Health claims legislation and conditions
  of use for low claims.
• The red/amber thresholds are set at 25 of the RI
  per 100g/ml for food and 12.5 per 100ml for
  drink.(drinks are lower relative nutrient density)

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Portion Cap

• A portion cap is applied where a single portion
  contributes 30 or over of the daily maximum RI
  for a given nutrient in the case of food, or 15
  or over in the case of drink. At this level, the
  portion of food or drink will code red for the
  respective nutrient.

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A green colour means the food is low in that
nutrient. The more green colours, the healthier
the choice. Many of the foods with colour coding
that you see in shops will have a mixture of red,
amber and green. So, when choosing between
similar products, you should choose foods with
more green and ambers, and fewer reds, to ensure
healthier choices.
A red colour on the front of pack means the food
is high in something you should try to cut down
on in your diet. It is fine to have the food
occasionally, or as a treat, but you should watch
how often you choose these foods, or try eating
them in smaller amounts.
An amber colour, means the food is not high or
low in the nutrient, so this is an acceptable
choice most of the time. You may want to go for
green for that nutrient some of the time.
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Sources of information

• European Commission (FIC Regulation and
  Commission Q A)
• http//ec.europa.eu/food/food/labellingnutrition/f
  oodlabelling/proposed_legislation_en.htm
• Food Information Regulations (Northern Ireland)
  2014
• http//www.legislation.gov.uk/nisr/2014/223/made/d
  ata.pdf
• Nutrition Labelling Guidance
• https//www.gov.uk/government/publications/technic
  al-guidance-on-nutrition-labelling
• On line training
• http//www.food.gov.uk/enforcement/enforcetrainfun
  d/onlinetraining/food-labelling-training-online/
• Food allergy / intolerance
• British Retail Consortium (Guidance on food
  allergens)
• http//www.brc.org.uk/downloads/Guidance20on20Al
  lergen20Labelling.pdf
• FSA advice
• FSA Food Information Regulations 2014 Summary
  guidance for food business operators and
  enforcement officers http//www.food.gov.uk/sites
  /default/files/fir-guidance2014.pdf

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Whats on a label resource
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Questions?