An opponent of the national origin labelling schemes spreading across the bloc, FDE submitted a five-page document with its concerns and recommendations.
For instance, it welcomed the fact that trademarks and protected geographical origins were excluded from the draft regulation “for the time being”, but said the wording of the text created confusion and it asked for more clarity.
FDE said the draft rules left a number of fundamental questions unanswered and called for an EU guidance or Q&A document to address them.
This included the definition of a primary ingredient in the case of ‘exotic’ primary ingredients that can only be sourced outside the EU, such as cocoa or coffee, or foods that have water as a primary ingredient.
It also asks for clarification on how to approach cases where ingredients have multiple processing steps that could occur in multiple countries, as well as a longer transition period of at least two years.
Requirements on font size were “unnecessarily restrictive and overly prescriptive” as well as being unnecessary to avoid consumers being misled.