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Food - European Food Webinar Presentation - 25 November 2011

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Presentation slides from Eversheds Food European webinar - Food for thought preparing for the Food Information Regulation.

Presentation slides from Eversheds Food European webinar - Food for thought preparing for the Food Information Regulation.

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  • 1. Implementing the new European ruleson labelling – 25 November 2011Parmjit Singh, LondonOwen Warnock, CambridgeJoos Hellert, Munich
  • 2. Implementing the new European ruleson labellingThis session will cover:• The Food Information Regulation – what is changing?• Timescales for change• Practical implications for food businesses
  • 3. The Food Information RegulationWhat is changing?• Minimum font size for • Extension of rules for mandatory origin of food labelling information • Food authenticity• Nutrition labelling • Distance selling• Mandatory information on • Alcohol allergens
  • 4. Requirements for mandatoryinformationWhat is mandatory information? Article 9• The name of the food• The list of ingredients (extended)• Allergens / intolerances from a prescribed list (eg wheat, eggs, mustard, milk etc).• Quantity of certain ingredients• The net quantity of the food• Date of minimum durability or use by date• Any special storage conditions / conditions of use
  • 5. Requirements for mandatoryinformationMandatory information cont …• Name / business name and address of the food business operator• Country of origin / provenance• Instructions for use• The actual alcoholic strength by volume (beverages containing more than 1.2%)• A nutrition declaration
  • 6. New information to be given withthe name of the foodExisting requirements remain • eg “with sweetener”, “irradiated”New requirements • “defrosted” – if product has been frozen at some prior stage, exemptions • substituted ingredient: clear indication of the substituted ingredient „where consumers expect an ingredient to be used‟ • added water: products that look like pieces of meat if >5% added water: “contains added water” or similar • meat and fish products made from pieces which look like single items: “formed meat”, “aus Fleischstücken zusammengefügt” etc • Caffeine: warning indication on  beverages other than tea or coffee with >150 mg/l or  non-beverages to which caffeine is added for physiological purposes
  • 7. Requirements for mandatoryinformationArticle 13• Mandatory food information must be: – marked in a conspicuous place – easily visible, clearly legible – cannot be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material• Same field of vision now required for – name and description – net quantity – alcoholic content – NOT now required for „best before‟ or „use by‟ date or signpost
  • 8. Requirements for mandatoryinformationPresentation - minimum font size• Standard rule - any lower case characters must be equal to or greater than 1.2mm• Largest surface area is less than 80 cm squared the minimum lower case height must be equal to or greater than 0.9mm• Exemptions – glass bottles – small items (largest surface area is less than 10 cm squared – only name, allergens, net quantity and use by date need appear. What about the remaining information?)
  • 9. Mandatory nutrition labellingRequirements• The nutrition declaration will include: – energy value and – the amount of fat, saturates, carbohydrate, sugars, protein and salt• No requirement for front of pack labelling• Information to be presented in tabular format where possible• Exemptions• Further options
  • 10. Mandatory country of origin / place of provenance labelling Requirements• Mandatory if failure to indicate would mislead• Extension of the rules for origin of food labelling – fresh, chilled or frozen meat from pigs, sheep, goat and poultry• If the country of origin of primary ingredient differs then: – country of origin of the primary ingredient shall also be given or – country of origin shall be indicated as being different to that of the food• Implementing rules to be produced within two years of the Regulation‟s entry into force.
  • 11. Mandatory allergen informationRequirements• Allergens – includes any ingredient or processing aid specifically listed in the Regulation (eg wheat, eggs, fish, milk etc) – the typeset should clearly distinguish the wording and be set out in the list of ingredients – not required where the name of the food clearly refers to the substance or product concerned
  • 12. Distance sellingRequirements• All mandatory information must be made available before purchase (save for „use by date‟ or date of minimum durability)• All mandatory information must be available on delivery• Catalogue selling must also make required information clear
  • 13. Non pre-packed foodRequirements• Mandatory provision of allergen info• Implications for restaurants• Members States could adopt more stringent requirements and insist that more particulars are highlighted to the consumer (eg full list of ingredients)• Members States may specify how the particulars are to be made available and, where appropriate, their form of expression and presentation
  • 14. Food authenticityRequirements• Food authenticity: – Ban on saying a product does not contain an ingredient if that kind of product never does – eg fat in wine gums – Ingredient substitution made clear on packaging – Added water and protein made clear on meat and fish products
  • 15. Future changesMany controversial issues left for laterresolution• Transfat labelling• Alternative presentation of nutrition information• Additional legibility requirements• Extensions of country of origin labelling• Alcohol labelling
  • 16. Mandatory country of origin/ place ofprovenance labellingPossible future changes• Country of origin labelling could be extended in the future (eg to milk, milk used as an ingredient in dairy products, unprocessed foods, other meats)• Commission to complete an impact assessment
  • 17. Future CoverageAlcoholic Beverages• Alcoholic beverages are exempt from the requirements to include: – An ingredient list and – Nutritional information• This is subject for review three years after implementation
  • 18. Timetable for Implementation• The labelling requirements are to come into effect 3 years after the adoption of the legislation• The obligations for nutrition labelling will not apply until 5 years after adoption• When will EU and/or national authorities give guidance?• Impact on all labels in the end, but in particular consider – labelling redesign and product relaunch projects – new product development
  • 19. Issues• Supply of raw materials change regularly• Cost and practicality of changing labelling and packaging• Restrictions on trade• Food costs increase as flexibility diminishes?• Increased bureaucracy for business?• Are consumers benefiting?• Difficult to enforce
  • 20. Questions & Answers
  • 21. Eversheds contact detailsFor further information please contact eitherone of the presenters on;Parmjit Singh:+44 845 497 1410 or +44 776 895 4246Owen Warnock:+44 845 497 4282Joos Hellert:+49 89 54 56 51 85Or email: food@eversheds.com