Once again, an English term that has been gaining ground in recent years, so we thought it is worth exploring in more detail.
1.) What is a clean label?
In English, it is called "clean labelling", which originally meant that a product is made up of as few ingredients as possible for the product, and that these ingredients are primarily those that are considered to be beneficial to health and that we would use ourselves if we were to make the product in our own kitchen.
2) What are the characteristics of clean label products?
It follows from the description of clean label products that the list of ingredients is short, transparent and easy to understand.
The basic purpose of the clean label is to identify and suggest to consumers products made from natural ingredients - i.e. it is of great importance for health-conscious consumers in particular when choosing which products to buy.
3.) The clean label as advertising
Given that clean labelling indicates that your product is free from certain ingredients - artificial substances - it has significant promotional power; and there are brands, for example, that print the list of ingredients on the front of the packaging.
4.) Clean label "prints"
As clean label products do not contain ingredients that may have a dubious effect on health, this has great market potential, and manufacturers also try to manipulate consumers with the labels on the packaging of their products.
The packaging of many products will say, for example, that they are 'free' of something - such as flavour enhancers or artificial additives or colourings.
These claims may be true, but the problem is that consumers are not aware of the food law requirements for the product - for example, although the product may be free of the ingredient, it may be the result of legal requirements and not due to higher quality than other similar products.
It follows that, although this "exemption" suggests that the product in question is of a higher quality, cleaner and better for health, it is merely a manufacturer following the legal requirements, i.e. it does not offer anything more than its comparable counterpart, which, at the same time, the manufacturer does not use the terms - in a fair way.
5) Are there legal requirements for clean labelling?
Not directly - indirectly, yes.
This means that a positive indication can also be used to influence or mislead the consumer in a way that is detrimental to consumer protection.
The claims that can be made about a product are partly regulated by legal requirements (e.g. sugar-free labelling), but in other cases manufacturers must take into account the general consumer protection requirement not to mislead consumers about the composition and quality of the product.
6.) The clean labelling "issue"
As we can see, this means that a positive indication can also be used to disadvantage the consumer in terms of consumer protection.
Indeed, manufacturers often deliberately operate in a grey area when they 'whitewash' a product - for example, just because a product is free of colouring (i.e. an additive, whether natural or man-made, that is used to colour the product) does not mean that it cannot contain a food colouring to make the product more desirable; however, it can often be a distraction and lead to a purchase.
It may also be the case that although a product is free of certain ingredients, this does not preclude it from containing other ingredients used for the same purpose (e.g. to enhance the taste of the product) - but it gives the average consumer the impression that the product is completely foregoing the use of ingredients with certain properties.
7.) Who takes responsibility?
The manufacturer/distributor assumes legal responsibility for any statements made to consumers about the product.
Accordingly, any markings that fall within the scope of the clean label on a product are also covered by this responsibility.
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.