Manufacturers must act now if they are to make sure that food labels are printed and ready in time for the forthcoming FIC regulation deadline on December 13th.
The FIC regulations set out a standardised format for food information on product packaging, such as the way allergens are distinguished, how nutritional information is displayed and font size.
And according to RSSL senior food safety and allergens consultant, Simon Flanagan, there are likely to be further changes on the horizon, as stricter rules for 'free from' food claims may follow.
"There are only a finite number of companies who can and will print packaging, so there is an awful lot of work to be done," Flanagan told Foodnavigator.
"If you haven't got your order in with your printer now there is a chance you won't be able to have those labels changed before it is needed."
Aside from the logistics, the labelling of allergens is likely to present the biggest challenge to the food industry. Particularly in the UK where the customary allergen advice box will no longer be used unless it directs consumers to the ingredients list for allergen information, without naming them.
Claims around ‘free-from’ foods are currently outside the FIC's scope, according to Flanagan, who is the author of a new white paper called "Countdown to Compliance - Allergen Labelling Implications of the Food Information Regulations (FIR)". FIC will be known as FIR in UK law. th
He comments: "Whilst ‘free-from’ products, like all others, must have ingredient labels that conform to the new rules, FIC offers no specific guidance or restriction on appropriate labelling for them."
The 'free-from' category includes dairy-free, soy-free, lactose-free and egg-free foods, among others. Such claims must be backed up by a robust risk assessment, validated allergen management regime and other evidence.
However, Flanagan said that Commission Regulation (EC) 41/2009, concerning the composition and labelling of foodstuffs suitable for people intolerant to gluten, is currently the only European regulation with direct relevance to ‘free-from’ claims - specifically ‘gluten-free’ and ‘very low gluten’.
"The regulation does not override existing allergen labelling regulations and it is possible that it will soon be consolidated within the FIC," Flanagan explained.
"Should this consolidation take place, it could in theory, open the door for regulatory limits on other ‘free-from’ claims."
In the UK failures to comply with FIC will be addressed in the first instance by Improvement Notices and more latterly by First Tier tribunals. Ultimately, there are criminal sanctions for breaches of food allergen provision.
Yet Flanagan believes there some leeway is likely in the first year: "I think it would be fool-hardy to assume that our regulators are going to go in heavy-handed. There will be common sense."