The current EU general labelling rules have been in place since 2000 via a labelling directive, but this will be completely replaced by the FIC regulation in December 2014.
In the spotlight is revamped nutrition labelling, which will become mandatory; replacement of GDAs (guideline daily amounts) with RIs (reference intake); new rules for allergen labelling; and requirements for ingredient origin labelling, among many other more detailed changes.
Leeks said it was possible to conceive of a product that might not be affected by the legislation – a single-ingredient, large container of juice, for example, with no need for allergen labelling – but most foods and drinks currently sold in the EU were likely to need new labelling.
“There are some major issues,” he said. “The top one may be in nutrition labelling, which is changing drastically. At the moment, it is given voluntarily and only becomes mandatory when you make some kind of claim…The FIC will make it compulsory.”
For those companies that already use nutrition panels on their products, the new rules will apply by December 13, 2014, but others – mainly smaller businesses – will have until December 2016 to comply.
There will be changes to the composition of the nutrition label too, with both total fat and saturated fat to be presented at the top of the table, second only to energy.
He added that plans to replace GDAs with RIs may take some adjustment for consumers.
“Consumers I think have got used to seeing GDAs.”
The FIC reference intakes are slightly higher than the GDAs for carbohydrates and protein, but it remains the same for fats. However, Leeks suggests that consumers may not notice too much of a change, speculating that they may just focus on a nutrient’s percentage RI value, rather than paying attention to the adjustments behind the new terminology.
New rules for allergen labelling seek to control it much more precisely than before, and allergen information must be highlighted in the ingredients list, with allergen words like ‘milk’ or ‘soy’ emphasised in some way.
“What seems to be emerging in the UK is to put the allergenic ingredients in bold so they stand out from the other ingredients,” he said. “The thing that has caused most concern is that in the UK we have become used to seeing allergen advice boxes. That will have to stop.
“What you can do is have an allergen box that says “for allergens see ingredients list”. …It can only direct consumers to the ingredient list but can’t name the allergens.”
In time, the hope is that allergy sufferers throughout the EU will know to look at the ingredient list and nowhere else for allergen advice. In the meantime, European food agencies are embarking on educational programmes to ensure those with allergies are aware of the change.
Allergen labelling will also apply to products without ingredients lists, like alcoholic beverages, which will have to carry a ‘contains’ label, and food sold loose will also be subject to the new allergen rules.
“Legally required information gets squeezed to the sides of the label by all the marketing stuff, so the Commission has introduced a measure to try and counteract that,” said Leeks.
The minimum font size for nutrition and allergen labelling is defined by the height of a lower case ‘x’, which will have to be at least 1.2 mm. For smaller labels, where the largest surface area on a pack is less than 80 square centimetres, the lower case ‘x’ must be at least 0.9 mm.
Changes to origin labelling rules are also included, meaning that a company would have to state if a product is processed in one country, but the main ingredient comes from somewhere else.
“This has been a hot political issue about animal welfare and supporting local farmers,” said Leeks, adding that the Commission has said it will release more details on how this part of the FIC will work.
“It can be an ingredient that represents more than 50% of the food, or which is associated with the name of the food,” he said.
“For some products, it is not so clear. In a mint sauce, for example, is it the mint, or is it the vinegar? And in soup, is it the water? And does the consumer really want to know where the water comes from?”
Companies have until December 13, 2014 to comply with most parts of the FIC, but will be able to use up old labels until that date and sell them afterwards. Although the FIC is completely different from the old rules, businesses will be allowed to comply early, said Leeks.
Among other issues:
- The FIC also does away with use of the generic term ‘vegetable oil’, requiring companies to specify the oil.
- Meat and fish products will have to mention the addition of water or other ingredients, such as vegetable proteins.
- Meat and fish products will have to carry the word ‘formed’ on pack if they are made from more than one piece of meat or fish.