Questions we find that are being frequently asked by businesses as they review their labels are:
- Nutrition often appears on the front of a pack as well as the back but in a different style – will both of these be mandatory?
- There is too little space on my label to fit a nutrition declaration on; what can I do?
- Does nutrition have to appear on all my food products, or are there any exemptions?
- I only supply a small number of products directly to a local store: Do I need to put nutrition on?
- If I choose to put nutrition on products when it is not mandatory, where can I put the nutrition panel?
- I do not currently put nutrition on the label. Will I have to start from December 2014?
While it is certainly good practice to put front of pack nutrition on a product it is entirely voluntary to do so. Back of pack nutrition is mandatory in most cases but there are circumstances when it does not apply:
- If the largest surface area is twenty-five square centimetres or under then nutrition does not have to be declared;
- Seventeen food categories listed in the regulation are exempt from mandatory nutrition labelling. Some make sense, such as herbs and spices whereas others are a little more surprising, such as unprocessed fruit, vegetables and meats;
- Manufacturers of small quantities of products that they supply themselves directly to local retail establishments do not need to include a nutrition panel;
- Where nutrition is declared on a voluntary basis (such as on unprocessed fruit or vegetables) then the requirements of FIC for it to be in plain sight do not apply and it can be located elsewhere on a pack (such as on the underside of a label);
- Finally, if nutrition is not currently being declared on a product, then that may continue until December 2016 as there is an extended transition measure in this circumstance.
So, mandatory is not mandatory in every circumstance! It is therefore worth checking the regulation or taking advice if there is some debate over whether or not nutrition information must appear on a food label.
Steve Spice is head of regulatory affairs at Campden BRI.