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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 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. 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 List of mandatory particulars a. name of the food* b. list of ingredients (Physical condition or treatment, Added proteins if of a different animal origin (meat products/preps & fishery products) c. “allergens” d. Quantitative Indication(if necessary) e. net quantity of the food* f. date of minimum durability or "use by" date g. any special storage conditions and/or conditions of use h. name or business name and address of the food business operator List of mandatory particulars i) country of origin or place of provenance where provided for j) instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions k) alcoholic strength by volume for beverages containing more than 1.2 % by volume of alcohol* l) nutrition declaration Lot number – separate rules * On the same field of label 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,…. EU list of allergens (new Annex II is the same as previous Annex IIIA) Peanuts Nuts Milk Soya Mustard Lupin Eggs Fish Molluscs Cereals containing gluten Sesame Celery Sulphur dioxide Shellfish What’s on a label? –prepacked food 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. 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 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.”. 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. 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. 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 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! Resources Link: http://www.food.gov.uk/business-industry/allergy-guide/allergenresources Material for schools Allergy Adventures poster for children Poster for secondary schools 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 < 80 cm² • Commission expected to introduce rules - on other aspects - for legibility 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 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. 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 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 < 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. Voluntary Information – “front of pack” • Energy value or • Energy value plus – – – – Fats Saturates Sugar Salt 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 Annex XV Nutrition Declaration Per 100g Energy kJ/ Kcal Fat g Of which Saturates Mono-unsaturates polyunsaturates g Carbohydrate g Of which sugars g Polyols starch g g fibre g Protein g Salt g Vitamins/ minerals Units in Annex XIII g 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. 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 Front of Pack Nutrition Labelling 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 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. 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 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 < 3.0g/100g >3.0g to <17.5g/100g >17.5g/100g >21g/portion saturates <1.5g/100g >1.5g to <5.0g/100g >5.0g/100g >6.0g/portion Total sugars <5.0g/100g >5.0g and <22.5g/100g >22.5g/100g >27g/portion salt <0.3g/100g >0.3g to <1.5g/100g >1.5g/100g >1.8g/portion 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 <1.5g/100ml >1.5g to <8.75g/ml >8.75g/100ml >10.5g/portio n Saturates <0.75g/100ml >0.75g to <2.5g/100ml >2.5g/100ml >3g/portion Total sugars <2.5g/100ml >2.5g to >11.25g/100m >13.5g/portio <11.25g/100m l n l Salt <0.3g/100ml >0.3g to <0.75g/100ml >0.75g/100ml >0.9g/portion 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) 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. 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. 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. 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. [ Sources of information European Commission (FIC Regulation and Commission Q & A) http://ec.europa.eu/food/food/labellingnutrition/foodlabelling/proposed_legislation_en.htm Food Information Regulations (Northern Ireland) 2014 http://www.legislation.gov.uk/nisr/2014/223/made/data.pdf Nutrition Labelling Guidance https://www.gov.uk/government/publications/technical-guidance-on-nutrition-labelling On line training http://www.food.gov.uk/enforcement/enforcetrainfund/onlinetraining/food-labelling-training-online/ Food allergy / intolerance British Retail Consortium (Guidance on food allergens) http://www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Labelling.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 • FSA allergy pages for tools, advice and guidance: http://food.gov.uk/policy-advice/allergyintol/ • Allergy E-learning http://allergytraining.food.gov.uk/ • Consumer advice http://food.gov.uk/multimedia/pdfs/publication/allergy-leaflet.pdf • EU Food Information for Consumers Regulation http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:304:0018:0063:EN:PDF What’s on a label resource Questions?