UK: New EU Food Safety Regulations May Prove Too Much To Digest

Last Updated: 14 July 2014
Article by Esme Saynor

Summary and implications

New EU Regulation (1169/2011) on the provision of food information to consumers consolidates and updates two areas of labelling legislation – general food and nutrition labelling – into a single text. This will apply the labelling rules in a way that is consistent across the EU. The intention is that packaging and labelling plays a part in the health of consumers. Ultimately the information is to be more inclusive, with a focus on nutrition, allergens and country of origin as well as being in larger print and increasing clarity. The issues raised by industry have centred around the increased amount of information required coupled with increased size and clarity – how will these sit with consistent branding as well as smaller packaging? 

The new rules will apply from 13 December 2014. The obligation to provide nutrition information will apply from 13 December 2016 for manufacturers who have yet to introduce nutrition labelling on their products, whereas manufacturers who already provide nutrition information must comply with the new rules by December 2014.

The main changes

The regulation will change existing EU legislation on food labelling by requiring packaging/labels to include (amongst other changes) the following:

  • Nutrition labelling will be required for most foods and there is mandatory nutrition information on all processed foods including energy, fat, saturates, carbohydrates and salt. Simplified information may be provided voluntarily also on the front of the pack.
  • Allergen information will have to be provided on all food (whether sold pre-packed or loose, including in cafés and restaurants). For pre-packed foods, the allergens will have to be highlighted on the ingredients list.
  • Country of origin – the introduction of mandatory origin information for most fresh and frozen meat, including pigs, sheep, goats and poultry. Also, the origin of main ingredients will have to be given if different from where the final product is made.
  • Meat and fish products that look like a cut, joint or slice and contain more than five per cent added water will have to show this in the name of the food.
  • Labelling clarity – a minimum font size has been set for all mandatory information.
  • Drinks with high caffeine content will have to be additionally labelled as not recommended for children, or pregnant and breastfeeding women, with the actual caffeine content quoted.
  • The types of vegetable oil used in food, such as palm oil, must be stated.

Additional information can also be provided voluntarily, on-label or by other means such as consumer leaflets, company websites and customer care lines.

Allergen labelling

With the new food law, all food service organisations serving unpackaged food or food that is packaged on site for immediate consumption will have to supply details of the menu items that contain the EU top 14 allergens within the dishes they serve. These are eggs, molluscs, crustaceans, celery, milk, fish, treenuts, sulphites, soya, sesame, peanuts, mustard, lupin and gluten.

Details of the top 14 allergens will have to be listed clearly in an obvious place such as a menu, chalkboard or information pack (each dish on the menu would require a breakdown of allergens). The effects of the new laws are: 

  • you can no longer state that you don't know if an allergen is present;
  • you can no longer state that all foods "could" contain allergens; and
  • oral statements have to be backed up in writing if required.

Your local environmental health officers will enforce the regulations, and non-compliance can result in large fines.

Multilingual packaging

Article 15 of the new regulation deals with language requirements for packaging labels, which must appear in a language easily understood by the consumers of Member States where a food is marketed. Member States may also stipulate that the particulars of labels shall be given in more than one of the official languages of the EU. 

Implementation of the EU Regulation in England

Defra has already completed a consultation on the implementation of the new regulation in England. As part of the consultation, Defra has published a draft statutory instrument to implement the regulation, together with non-statutory guidance. The new instrument (the Food Information Regulations 2013) is intended to revoke the framework of 14 statutory instruments which currently govern food labelling (including the Food Labelling Regulations 1996). However, because food labelling is a devolved matter, the draft legislation will apply to England only.

However, it is warned that this might not be the end of the matter, and even after December 2014 the EU might want to tinker with the directive. The EU have indicated that there are 35 different areas that will be looked at for further amendment, and so it could be said that the changes that will be enforceable by the end of the year create a fair amount of uncertainty.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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