Have you started preparing for 2014 yet? – Countdown to the Food Information for Consumers Regulation (FIC), which modifies existing food labelling provisions in the Union to allow consumers to make informed choices and safe use of food, while at the same time ensure the free movement of legally produced and marketed food. The Regulation entered into force on 12 December 2011 and it shall apply from 13 December 2014, with the exception of the provisions concerning the nutrition declaration, which shall apply from 13 December 2016.
The new FIC Regulation, EU Regulation 1169/2011 on the provision of food information to consumers changes existing legislation on food labelling including:
* Mandatory nutrition information on processed foods;
* Mandatory origin labelling of unprocessed meat from pigs, sheep, goats and poultry;
* Highlighting allergens e.g. peanuts or milk in the list of ingredients;
* Better legibility i.e. minimum size of text;
* Requirements on information on allergens also cover non pre-packed foods including those sold in restaurants and cafés.
The new law combines two directives into one legislation 2000/13/EC – labeling, presentation and advertising of foodstuffs; and 90/496/EEC – nutrition labeling for foodstuffs.
According to Mr Sukh Gill, Head of Global Regulatory Services at Leatherhead Food Research “in 2014 the task of implementing the EU Food Information to Consumers Regulation (FIC) looms largest, and those who plan ahead will secure scarce resources economically, and those that leave it too late will find themselves paying premium.”Leatherhead assists companies with their re-labeling tasks. Here is their countdown to the Food Information to Consumers Regulation:
10. Familiarization – Companies need to familiarize themselves with the label changes that need to be made. Leatherhead’s experts deliver seminars and training events on implementing the Food Information to Consumers Regulation.
9. Checking presence and accuracy –Review the food information briefs within your product specifications and secure the resources needed well in advance of 13 December 2014.
8. Multi-lingual labels – the majority of products will require a label redesign, even if only to accommodate new rules on minimum font size – this is even more challenging when you have several EU languages to work with.
7. Artwork – with a new minimum font size of 1.2 mm ‘x-height’ introduced for key labelling requirements (0.9 mm for small packages), have your artwork reviewed and review and approved by a professional firm for compliance. There will be time pressures to get new labels/packaging printed, in place and functional in time to exhaust old label stocks without incurring packaging write-off, so plan ahead.
6. Food safety – with a new definition of ‘use by’ that creates the presumption that food past its ‘use by’ date is unsafe, there is a need to give careful consideration to whether products could be labelled ‘best before’ rather than ‘use by’.
5. Technical advice/support – from allergens to cooking and storage conditions
4. Reformulation – whether it’s reformulating to reduce sodium, ingredient count, or allergen declaration.
3. Nutrition – subject to a five year transition period, unless exempt, nutrition labelling will be mandatory for all pre-packed foods. If you need assistance with adhering to the new back-of-pack formatting changes that now need to emphasize the nutrients important to public health, information on validation etc., or seek other nutrition advice, Leatherhead can help.
2. Claims – Leatherhead’s new Marketing and Claims Service can help with all of your on- and off-label marketing message substantiation. Their new Average Consumer Panel™, can also be used as an objective tool for assessing marketing claims that would otherwise have been subjectively judged by marketers or their advisors.
1. Responsibilities – in 2013, ‘horsegate’ put the spotlight firmly on the new Article 8, of the FIC, which relates to responsibilities. The balance of responsibilities in the value chain will now change (and has to in light of this scandal) with everyone’s responsibility in the supply chain under review.
For enquiries regarding the Food Information to Consumers Regulation contact the Leatherhead’s Global Regulatory Services Teamlegislation@leatherheadfood.com