Asb conference bne 2015 labelling #3
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This presentation discusses food labelling requirements and how to avoid misleading labels. It covers why food must be labelled, including legal obligations and providing consumer information. Key labelling elements that must be included are outlined, such as the Nutrition Information Panel format and calculations. Potential issues are explored, like rounding numbers, serving size determinations, and ingredient representations. Claims around nutrition content, allergens, and quality are examined for veracity. Sources of non-compliance like production variances and interpretation of standards are reviewed. The importance of substantiating claims and internal verification processes are stressed to ensure label accuracy and avoid legal issues.
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Asb conference bne 2015 labelling #3
- 1. Labelling: the devil is in the detail Australian Society of Baking National Conference – 28th October, Brisbane 2015 Presented by Jasmine Lacis-Lee, DTS Food Laboratories
- 2. Presentation Purpose •Why label food? •Label what - overview of the labelling basics? •Where the devil can hide in labels • NIP format and more • False and misleading • Trade measurements • Nutrition claims • Free from / Allergen claims •How to get the devil off your back?
- 3. Why label food? •Legal requirement • Legalities at play include • Food Standards Code • ACL – ACCC • Trade measurement •Information for consumers - choice •Public health – allergens, cooking, storage, UBD
- 5. Label Must Haves: FSC •Is the label legible?
- 7. Where the devil can hide – NIP Format • All numbers to 3 significant figures only • Eg. 8111kJ can be rounded to 8110kJ • Sodium can be rounded to nearest 5 • Eg. 16mg can be rounded to 15mg • Words LESS THAN must be used, not “<“ • Only LESS THAN 1g is allowed, not “<0.1g” • Check calculations when converting to 100g to per serving
- 8. Where the devil can hide – NIP calculations • Representative sample(s) eg. R&D vs production • Incorrect subsampling – entire sample or portion? • NIP not performed as per intended use – reconstituted (dry soups), drained (canned vegetables, edible portion (prawns) • Serving per package – is it real? eg. 2.3 • How do you determine average?
- 9. Label related claims to watch for in the baking industry FSC 2.1.1 Cereals and Cereal products • Wheat flour must contain folic acid and thiamine – applicable only to bread and bread products • Addition of iodised salt – applicable only to bread and bread products • What is Wholemeal? • Cases of testing for Crude Fibre performed for verification
- 10. Label Requirements: ACL & ACCC False & Misleading •Conveys a misleading or deceptive impression or representation via words OR pictures •Typical claims made about a products: • Quality • Quantity • Composition • Origin Good Food magazine July 14, 2013 “Dispute over bread leaves a sour taste” - ''Look at the ingredients,'' Mr Noy said. ''If it has more than flour, salt and water, then it is not a true sourdough.'' Master baker at Sydney's Bourke Street Bakery, Paul Giddings, who has been baking sourdough for 8½ years, said his sourdough took up to 17 hours to cook as the wheat fermented to create the culture that gave the sour taste
- 11. Does the consumer trust the label? SOURCE: FSANZ, Food labelling issues: quantitative research with consumers 2003 (n = 1940) –How much do you feel you can trust the information given on the (label component)? • 17% unsure to trust ingredient list • 15% unsure to trust NIPs –Of the above consumers, reasons for being unsure: • Companies lie on labels • Too vague • I’m naturally suspicious • Negative previous experience
- 12. Label Requirements: ACL & ACCC – false & misleading •Consideration required – overall impression, target audience and intent •This applies to ALL commercial messages whether deliberate, careless or unintended
- 13. Misleading Label Claim – Case Study •Label claimed 100% Fresh Orange Juice • Label did not mention sugar in the ingredients list or state that sugar may be added when new season oranges are slightly bitter • Testing product demonstrated sugar was added • Conclusion: product did not contain 100% orange juice as represented on label but contained cane sugar and preservatives • Preventative action – ACCC compliance program
- 14. Trade Measurement Requirements • Expression of scientific notation: • kg not KG, Kilo’s or Kg • g (<1000g) not G, gm or grm • L is preferred but l is accepted • mL (<1000mL) not ML • Position, position, position • 2mm clear space around statement • Same direction as food name • Minimum text heights depending on pack size • Consideration of how displayed at point of sale • Name and street address not a PO Box • Pre-packaged bread, biscuits & cookies • Address of packer • Weight (allowing for moisture loss)
- 15. Nutrition content claims • In addition to meeting code definitions – • Low in salt • potassium declaration in NIP • Low in cholesterol • declare trans/mono/poly/sat fats in NIP • is the food naturally low cholesterol? • Lactose free / low • galactose must also be declared in NIP • Free = not detected • No added sugar or sugar % free • Must declare DF in NIP • Bakery Trends – high fibre claims
- 16. Allergen Claims Allergen • Gluten Free • No detectable gluten, limit of quantitation, <20ppm does not apply in Australia • Contain no oats or malt, raw material sourcing is critical • Dairy Free • No detectable dairy, ensure the correct marker is used for analysis
- 17. Allergen claims & Management Other allergen concerns • Omega 3 fortification • Unable to detect Omega 3 • Use of modelling for allergen cleaning verification need to be used. • Allergen Management • Risk assessment of the process required • Cleaning verification is critical • If there are no allergens other then 1 a plan is still required • Don’t forget the other allergens on site – egg / soy
- 18. How to get the devil off your back? • Its not what you think the product represents BUT how the consumer interprets your representation • Substantiate your claims • Internal label checklist • Review similar products on the market • Multi-department sign off • Pre-market survey / questionnaire? • NIP / claim verification from production samples • Recipe / formulation control
- 19. Helpful Links • Food Standards Code – Standards 1.2.1 – 1.2.11 • FSANZ: Getting Your Claims Right (1.2.7) • Useful References- “User Guides “ on FSANZ Web Site – provide easy to follow guide to specific Standards • Guide to the sale of Bread and Bakery Products – http://www.measurement.gov.au/TradeMeasurement/Business/Pages/Bre adandBakeryProducts.aspx • Country of origin claims and Australian Consumer Law www.accc.gov.au
- 20. Thank you
Editor's Notes
- ACL – Australia Consumer Law ACCC – current investigation on Free range egg labelling – use of the term, and to enhance consumer confidence and certainty
- Address – Recall information requirement Date Marking – BB, UB and Bread with &lt;7 days can have a baked on or baked for date
- Exemptions: small packages, single ingredient (herbs), unpackaged foods and foods sold at the point of sale (bakeries) Note that it still needs to be available at the point of sale if requested by a consumer
- Average = determined from analysis, calculation from the actual or average quantity of nutrients in the ingredients or calculation from generally accepted data
- Folic acid fortification does not include organic products – verification is required Iodine deficiency resulted in a change in salt 2009 (25-65mg /kg in the salt refinery) Wholemeal – product containing all the milled constituents of the grain in the typical ratio of those in the whole cereal
- 1.2.7 effective 18/1/16, ensures health claims are based on food-health relationships. Must meet compositional requirements as well as nutrient profiles IN addition the FSC has been amended and the new version comes into effect on the 1/3/16 with no transition
- Performance within a business can relate to how successful a company is performing in the market place and how it stac We began this campaign by delivering Performance Management training to all leaders down to Team leader level at the start of the year. We continued it with the Performance Measurement focus at the strategy Management sessions. You will have seen the performance articles on the intranet and email. They have addressed both Performance Management and Performance Measurement issues. Shortly we will introduce some articles about Pay for Performance issues. You will have noticed the Performance values banners installed at traffic points around the business. We’re now asking all staff to contribute to this campaign, by asking: What does “performance” mean to you? What does “performance” mean to our clients? Performance Working smarter and making informed decisions and ethical judgments to meet our objectives.