Ten food products were surveyed to check compliance with food labeling regulations. Only three products (Yum Yum peanut butter, Heineken beer, and D'lite cooking oil), all imports, fully complied. The survey found a 30% compliance rate overall. Local companies were not wholly adhering to standards, showing loopholes in enforcement. Stricter penalties were recommended to improve compliance.

1. NATIONAL UNIVERSITY OF
SCIENCE AND TECHNOLOGY
DEPARTMENT OF APPLIED BIOLOGY AND BIOCHEMISTRY
Student Name: Joseph Ndondo
Student Number: N0110859W
Course: Food Nutrition
Lecturer: Mr. Mangoma
MINI PROJECT
A survey on the compliance of locally manufactured and imported food products to food labelling regulations.

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ABSTRACT
A detailed survey was conducted to determine the compliance of food producers to local and international food labelling guidelines. Ten different foodstuffs were sampled and involved in the study. These were PRObands rice, Irvines mixed portions, Yum yum peanut butter, Heineken lager beer, Victoria Self raising flour, Nestle cerelac, D’lite pure cooking oil and Olivine buttercup margarine. Labels of various foodstuffs were analyzed and were compared to local and international standards to check if they were complying with the specified labelling regulations. Out of the ten foodstuffs, only three were found to be complying (Yum Yum peanut butter, Heineken beer and D’lite cooking oil). These findings showed that there was a 30% conformance score. All the conforming products/ foodstuffs were imports (foreign brands). The survey findings clearly revealed that companies, especially local firms were not wholly complying with food labelling standards. This shows that there might be some loopholes in the enforcement of the food laws. Strict penalties should be slapped on defaulting firms, and/or suspensions of licences.

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OBJECTIVES
 To analyze various food labels of ten different foodstuffs.
 To grasp and understand food labelling regulations.
 To understand which information, by law, must appear on food products.
 To check if the labels are complying with local food labelling regulations.
 To check if the labels are complying with international food labelling codes.

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LITERATURE REVIEW
Food labelling is the primary means of communication between the producer and seller of food on one hand, and the purchaser and consumer on the other. (www.foodafactoflife.org.uk ). Food labelling regulations prescribe rules for the labelling of food which is in whole or in part, intended for human consumption or which is intended for entry into, or to be used in the manufacture of, any substance. In Zimbabwe these regulations are embodied in the Food and Food Standards (Food Labelling) Regulations, 2002 as amended by S.I. 95 of 2003. These regulations apply to all foods which are sold or manufactured for sale in Zimbabwe. Other regulations include those of voluntary bodies like Standards Association of Zimbabwe’s (SAZ) ZWS ISO 22005:2008: (Traceability in the feed and food chain General principles, and basic requirements for systems design and implementation) and ZWS ISO 22000:2005: (Food safety management systems requirements for organization in the food chain). The most important feature of labelling or labels is “nutrition labelling”. It is a description intended to inform the consumer of nutritional properties of a food;
Nutritional labelling consists of two components
(a) Nutrient declaration
(b) Supplementary nutrition information
Nutrient declaration means a standardized statement or listing of the nutrient content of a food. Nutritional labeling aims at providing the consumer with information about a food so that a healthy and wise choice of food can be made. (www.nutrition.org.uk)
Food labelling assist consumers in making informed food choices; encourage food manufactures to apply sound nutrition principles in the formulation of foods and regulates misleading or deceptive labels and claims. Zimbabwe also subscribes to international food laws. It has been a member since 1985 of the Codex Alimentarius (Latin, meaning Food Code) Commission, a 170 member intergovernmental body, established by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO), with the purpose of protecting the health of consumers and ensuring fair practices in the food trade. The Commission also promotes coordination of all food standards work undertaken by international governmental and non-governmental organizations.
The Codex alimentarius is divided into the following sections:

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1. general standard for the labelling of prepackaged foods (CODEX STAN 1-1985)
2. general standard for the labelling of food additives when sold as such (CODEX STAN 107- 1981)
3. general standard for the labelling of and claims for prepackaged foods for special dietary uses (CODEX STAN 146-1985)
4. general guidelines on claims (CAC/GL 1-1979)
5. guidelines on nutrition labelling (CAC/GL 2-1985)
6. guidelines for use of nutrition and health claims (CAC/GL 23-1997)
7. general guidelines for use of the term “HALAL”
The local food law is embodied in the food and food standards (food labelling) regulations, 2002, however additional labelling is also covered in subsections specific to foodstuffs such as:
 Food and Food Standards (Flour, Bread and Cereals) Regulations, 1972
 Food And Food Standards (Fish And Fish Products) Regulations, 1990
 Food and Food Standards (Peanut and Peanut Products) Regulations, 1990
 Food and Food Standards (Poultry, Poultry Meat and Poultry Products) Regulations,1990
SUMMARIZED DETAIL OF THE LAW
The name and business address of the manufacturer
The name and address of the manufacturer, packer or seller must be stated on the label. Consumers can then contact the manufacturer if they have a complaint about a product or if they wish to know more about it. (Food and Food Standards (Food Labelling) Regulations, 2002) Statutory Instrument 265 of 2002
Weight and volume
The weight or volume of the food must be shown on the label. By comparing the weight with the price of different brands, consumers can make sure that they are getting value for money. Some foods such as bread, tea and butter are only sold in standard amounts. (www.nutrition.org.uk)

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The common or usual name of the food
It is important that the name of the food must be clearly stated and not be ambiguous or misleading. If the food has been processed in some way, the process must be included in the title e.g. dried apricots, salted peanuts, and smoked bacon.
Fig 1. A typical labelled cereal box
Ingredients
If the food is made from two or more ingredients, the common or usual name of each such ingredient must be stated, in order of weight, according to the amounts that were used to make the food, starting with the largest ingredient and ending with the smallest. The ingredients or proportions of any article shall be set out on the label in type of a uniform size and prominence throughout. Pork fat, lard and beef fat shall always be declared by their specific names. Food additives and water must also be included in the list if they have been added. Where the food contains any artificial flavouring or artificial colouring the name of the artificial flavouring or artificial colouring must be labelled. Where the food contains a chemical preservative, immediately preceding or following the name of the preservative ingredient, the words “added as a preservative” must be added. No label on any article of food shall contain the words “vitaminised”, “vitamin-fortified” or “enriched”, or any words which may be construed as indicating that such fortifying ingredients have been added to or produced in such article of food, without the written approval of the Secretary. (www.nutrition.org.uk)
Best before date
The law requires the producers to provide and label the date of minimum durability in the form of “Best before ………” Foods have a ‘best before’ date, after which the foods may not be at their best, with regard to flavour, colour and texture, even though they will probably be safe if they have been stored according to the instructions on the label
Genetically modified foods
The presence of genetically modified organisms (GMOs) or ingredients produced from GMOs must be indicated on the label.

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1. http://.www.foodafactoflife.org.uk
2. http://www.cfanfda.gov/label.html
3. http://www.webmd.com/content/article/100/105752.html
http://www-fp.mcs.anl.gov/otc/Guide/CaseStudies/diet/complete_table.html
Packing/code number
It is a code which is required by law to appear on the label. It helps to identify batches of food in the event that they need to be recalled by the manufacturer, packer or producer.
Language, print and print size
The labelling information particulars a required to appear on the label in English language. Another predominant language may be used in addition to English in areas where English is not the pre- dominant language. The print should be clear, prominent, legible and indelible print should be used. A significant contrast should be maintained between the text and background so as to be that the nutrition information is clearly legible. The print should be in type no smaller than six point. Labels shall be affixed on a conspicuous position on the package.
http://.www.foodafactoflife.org.uk.
Direction of use
A label shall state any necessary direction for the handling use storage of the particular food, for example “keep refrigerated”
Nutrients to be declared on label
Protein content, Carbohydrate content (excluding dietary fibre), Fat content, Content of nutrient for which claim has been made and the Energy value are to be declared on food label.
Other
Poultry which consists wholly or in party of poultry meat products should be labelled with the words “Poultry Meat Products” or the name of the specific parts contained in the product. (Food and Food Standards (Poultry, Poultry Meat and Poultry Products Regulations, 1990) Statutory Instrument 103 of 1990

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MATERIALS & METHODS
MATERIALS
1. Camera
2. Packaged Foodstuffs/ foodstuffs labels
3. Food labeling guidelines (Codex Alimentarius and food and food standards (food labelling) regulations, 2002
METHOD
Ten different food labels were analyzed and compared to both local and international food labelling standards. Although ten products were sampled, other products in the same category for example cereals were analyzed for comparison. A camera was used to photograph labels of various foodstuffs. The comparison was done as per food category, that is, alcoholic foods were compared to their law, and compliance was checked for their category. The same was done for bread, cereals, poultry and other foodstuffs. Non-compliances were recorded and stated. Non-compliances were categorized as either major or minor. Major Non compliances were those that affected the consumer’s decision making in their buying choice. The foodstuffs were selected from each category as categorized by the Zimbabwean food laws and also to the Codex Alimentarius (Food Code). Compliance was checked in accordance to the following benchmarks/ criteria: the name and business address of the manufacturer, (packer or distributor) weight and volume, the common or usual name of the food, ingredients, best before date, genetically modified foods, packing/code number, language, print and print size, direction of use,nutrients to be declared on label.

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RESULTS
Table 1. Non compliances of various foodstuffs
Foodstuff
Compliance
Detail of NC
Nature of NC
Other sampled products TM Supermarket Bread  No label, No nutritional information, No business address Major Choppies Supermaket bread
PRObands rice

No nutritional information
Major
Tastic rice Yum Yum peanut butter  perfect - Lyon’s Peanut butter
Irvine’s Mixed portions

Failure to label product “Poultry meat products” as prescribed by law
Minor
Drummond mixed portions Heineken lager beer  perfect Minor Castle lager beer
Victoria Self raising flour

No nutritional information
Major
Gloria self- raising flour Nestle cerelac  Did not promote breast milk on label, did not label as required by CODEX on (see appendix) Minor D’lite baby cereal
D’lite pure cooking oil

perfect
-
Red seal cooking oil Green Valley baked beans  No nutritional information Major Koo baked beans
Olivine Buttercup Margarine

Position of nutritional label at the base of product, in a not conspicuous
Minor
Stork margarine
*NC stands for Non-Conformance

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Table 2: Comparison of compliance as a percentage
Category
Count
Percentage
Complying products
3
30%
Non-complying products
7
70%
Chart comparing complying and non-complying products
30
70
0
20
40
60
80
category
Comparison of complying and non- complying products
Complying products
Non-complying products

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DISCUSSION
The project findings showed that food manufacturers were breaching food labelling regulations. Only three out of the ten sampled foodstuffs complied with the regulations, giving a 30% conformance score. The three complying foodstuffs (Yum Yum peanut butter, Heineken lager beer, and D’lite cooking oil) were all imports (Foreign brands). Local brands composed the 70% non-complying products category, with a variety of labelling breaches of different sorts.
Four Major labelling non conformances were found. The first was a total failure by the manufacturer (TM supermarket) to put a label on its bread. While other supermarkets like the newcomers in the market, Choppies also produced bread in their supermarket; their bread was labelled. Labels enable cconsumers to contact the manufacturer if they have a complaint about a product or if they wish to know more about it. The other major labelling non-conformances were failure by some manufacturers to include only nutritional labels on their products. The defaulters in this category included PRObands rice, Victoria Self raising flour and Green Valley baked beans. The manufacturers failed to declare the mandatory nutrients (Protein and Fat content). From a Food nutrition point of view, the most important feature of labelling or labels is nutrition labelling. Nutritional labeling aims at providing the consumer with information about a food so that a healthy and wise choice of food can be made. (www.nutrition.org.uk). The manufacturers for reasons best known to them, decided not to provide all the information to consumers.
The other non-compliances were rather minor. One of the non–compliance was common in all the poultry products. This was failure to label their product (s), with the words “Poultry Meat Products” or the name of the specific parts contained in the product. (www.parlzim.gov.zw ). This is embodied in Statutory Instrument 103 of 1990, section 27 of the Food and Food Standards Act [Chapter 15:04]. Irvine’s Zimbabwe had one of their product labelled “Mixed Portions” and had no trace whatsoever of the required label: “Poultry Meat Products”.
The other unique non-compliance was that of the positioning of the labels. The food label standard requires that labels shall be affixed on a conspicuous position on the package. Olivine’s buttercup margarine had its nutritional information, ingredients, business address and directions of use on the base of their product, a not so conspicuous position for the consumer.

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CONCLUSION
The survey findings clearly revealed that companies, especially local firms were not wholly complying with food labelling standards. This was impacting and affecting the consumer in making sound healthy choices on buying products as vital information was being omitted from products by manufacturers/ packagers. Foreign products were complying with both local and international food labelling products (70% compliance score). This shows that there might be some loopholes in the enforcement of the food laws. Strict penalties should be slapped on defaulting firms, and/or suspensions of licences.

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REFERENCES
4. Food and Food Standards (Advisory Board) Regulations, 1995 (S.I. No. 322 of 1995). - 1995 [LEX-FAOC026313]
5. Food and Food Standards (Alcoholic Beverages) Regulations, 2001 (S.I. No. 25 of 2001). - 2001 [LEX-FAOC061614]
6. Food and Food Standards (Fish and Fish Products) Regulations, 1990 (S.I. No. 104 of 1990). - 1990 [LEX-FAOC061616]
7. Food and Food Standards (Flour, Bread and Cereals) Regulations, 1972 (S.I. No. 1211 of 1972). - 1972 [LEX-FAOC061617]
8. Food and Food Standards (Food Labelling) Regulations, 2002. - 2003 [LEX- FAOC061620]
9. Food and Food Standards (Pasta Products) Regulations, 1991 (S.I. 149 of 1991). - 1991 [LEX-FAOC061629]
10. Food and Food Standards (Peanut and Peanut Products) Regulations, 1990 (S.I. No. 99 of 1990). - 1990 [LEX-FAOC061630]
11. Food and Food Standards (Poultry, Poultry Meat and Poultry Products) Regulations, 1990 (S.I. 103 of 1990). - 1990 [LEX-FAOC061632]
12. www.parlzim.gov.zw/.../FOOD_AND_FOOD_STANDARDS_ACT_15
13. http://www.nutrition.org.uk
14. http://.www.foodafactoflife.org.uk
15. http://www.cfanfda.gov/label.html
16. http://www.webmd.com/content/article/100/105752.html
17. http://www-fp.mcs.anl.gov/otc/Guide/CaseStudies/diet/complete_table.html

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APPENDIX
Category: Food and Food Standards (Flour, Bread and Cereals) Regulations
TM Supermarket bread
*No label
PRObrands Rice *No nutritional information
Victoria flour
*No nutritional labelling on Victoria self-raising flour

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Category: Food and Food Standards (Peanut and Peanut Products) Regulations, 1990
Category: Food and Food Standards (Poultry, Poultry Meat and Poultry Products) Regulations, 1990
*The name “Mixed portions” was chosen but the law says “where the food consists wholly or in party of poultry meat products, the words “Poultry Meat Products” or the name of the specific parts contained in the product.
Category: Food & Food Standards (Alcoholic Beverages) Regulations, 2001

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CODEX standard for processed cereal-based foods for infants and young children
(CODEX STAN 074-1981, REV. 1-2006) requires that:
1. The products covered by this standard are not breast-milk substitutes and shall not be presented as such.
2. In addition, the label shall include a statement indicating that the decision when precisely to begin complementary feeding, including any exception to six months of age, should be made in consultation with a health worker, based on the individual infant’s specific growth and development needs.

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D’lite baby cereal Nestle Celerac
*Statement on pointed by the arrow on the Nestle product did not specify “Breast milk” and did not promote breast milk fully as required by CODEX statement 1 above.
*Statement on Nestle cerelac product highlighted by the arrow was not presented as exactly as required by CODEX statement 2 above.

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