The EU obliged all member states to enact their Regulation EU No 1169/2011 for food labelling on 13 December 2016. This legislation affects all food producers with specific impacts on food producer supplying pre-packed foods to consumers.
There were a number of key changes to the way in which information is conveyed to consumers. The labelling format assumed a very specific structure. Much of the regulation is self-evident but other aspects have been harmonised.
There are a number of items that need to be included on your food label:
- Title & Description
- Food business contact details
- Ingredients in the product (QUID compliant)
- Standardised allergen highlighting
- Use by or Best Before dating
- Nutrition data
The new regulations require text to be no smaller than a specific size. This is defined as the minimum height of the text on your label should be no smaller than 1.2mm on the letter “x”. As a general rule, a 7 point font will achieve this but should be checked.
Title & Description
The title of the product should be clear and evident to the consumer when they view the product. As a food business, you would do this anyway but the regulation just formalises the need to do that.
Food Business Contact Details
This regulation was in place anyway with British regulations. Your label needs to include the origin of the product and the contact information of the company responsible for the production of the food product.
This is imperative to ensure food security in the event of infection entering the food chain. The authorities need to be able to trace the route of a foodstuff through production to the consumer in the event of an infection. There must be enough information to identify the producer so authorities can trace food origins.
The ingredient listing must be comprehensive and include the composition of each ingredient element. For example, you cannot just say that a sandwich contains “Bread, Mayonnaise and Chicken”. You need to detail the composition of the bread, mayonnaise and the chicken.
i.e. Not Bread, Chicken, Mayonnaise
White Bread [WHEAT Flour [WHEAT (GLUTEN) Flour, Calcium Carbonate, Iron, Niacin, Thiamin], Water, Yeast, Salt, SOYAA Flour, Emulsifier (Mono- and Di-Acetyl Tartaric Acid Esters of Mono- and Di-Glycerides of Fatty Acids), Preservative (Calcium Propionate), Spirit Vinegar, Rapeseed Oil, Flour Treatment Agent (Ascorbic Acid).], Chicken [Chicken Breast, Rice Flour, Potato Starch, Cornflour, Dextrose, Stabiliser (Sodium Triphosphate), Brown Sugar, Salt, Rapeseed Oil.], Mayonnaise [Rapeseed Oil (78%), Water, Free Range Pasteurised EGG (6%), Spirit Vinegar, Free Range Pasteurised EGG Yolk (1.5%), Sugar, Salt, Lemon Juice From Concentrate, Flavouring (MUSTARD), Stabiliser (Xanthan Gum), Antioxidant (Rosemary Extract).]
Additionally, your ingredient listing should comply with QUID regulations. QUID means Quantitative Ingredient Declaration. Specifically, you should identify the percentage of an ingredient named in the title of the products. So for example, a chicken sandwich would need the chicken percentage mentioning.
Overcoming this would be quite complex to the letter of the law, so Nutridata Lite and Nutridata Pro both list your ingredients in full QUID order and express the percentage of every ingredient in the product.
i.e. White Bread (44%) [WHEAT (GLUTEN) Flour [WHEAT (GLUTEN) Flour, Calcium Carbonate, Iron, Niacin, Thiamin], Water, Yeast, Salt, SOYAA Flour, Emulsifier (Mono- and Di-Acetyl Tartaric Acid Esters of Mono- and Di-Glycerides of Fatty Acids), Preservative (Calcium Propionate), Spirit Vinegar, Rapeseed Oil, Flour Treatment Agent (Ascorbic Acid).], Roast Chicken Breast (25%) [Chicken Breast, Rice Flour, Potato Starch, Cornflour, Dextrose, Stabiliser (Sodium Triphosphate), Brown Sugar, Salt, Rapeseed Oil.], Mayonnaise (11%) [Rapeseed Oil (78%), Water, Free Range Pasteurised EGG (6%), Spirit Vinegar, Free Range Pasteurised EGG Yolk (1.5%), Sugar, Salt, Lemon Juice From Concentrate, Flavouring (MUSTARD), Stabiliser (Xanthan Gum), Antioxidant (Rosemary Extract).], Tomato (8%), Lettuce (6%), Cucumber (6%)
Standardised Allergen Highlighting
The new regulations require all 14 allergens be identified in the ingredient listing. This is done by differentiating the allergens from the body text. Nutridata does this by converting the allergens to UPPERCASE text (as can be seen in the examples above).
Nutridata is pre-loaded with hundreds of common allergenic ingredients. When you load an ingredient and list the composition, Nutridata will ‘parse’ the text and change any allergens it finds into UPPERCASE and identify (if necessary) the allergen. For example, Tune will be converted to TUNA (FISH). Wheat will be converted to WHEAT (GLUTEN).
The allergen list is fully editable by the user so you can tailor it to your specific needs.
Use By & Best Before dating
You need to add a Use By or Best Before date to your product label. Use by dating should be used on products that become dangerous from infection. Best Before dates are used on products that are still edible after a period of time but are generally, not going to be toxic if consumed.
Generally, dairy, meat and other ‘wet’ foods will need a Use By date. Dry foods such as biscuits, bread, cakes and crackers can have a Best Before. If you are in any doubt, contact your local trading standards office.
The amount of product in the pack should be clearly labelled on the product. Where it is abundantly apparent, this does not need to be a weight. For example, a sandwich is self-evidently a sandwich. 5 doughnuts are self-evidently 5 dougnuts.
Other products may benefit from being sold with their weight. Nutridata can determine the weight of a product from the recipe you set out.
The most onerous change in responsibility as a result of EU Food Information to Consumners Regulations is the need to add nutrition information to products.
Not all food producers need to do this. In the UK, food businesses with a turnover under £1.1m or less than 10 employees are generally exempt. You should check with your local trading standards team to see if you are exempt or not.
If you produce food for sale off-site from where it is made, and you meet the criteria regarding business size, you are likely to have to add nutritional information to your labels.
What nutrition data is required?
The key items that are required are:
- Energy in kJ and kcal
- Saturated Fat
It is a common misconception that Fibre is required too. This is not the case bu Nutridata does allow you to add fibre.
The nutrition data for you product must be described in the order of the list above. You cannot list the nutrition values in any other order.
You can also list additional nutrition values but Nutridata is only designed to deliver the mandatory items and fibre.
Obviously, calculating all of these values is a very arduous task. Nutridata makes this process easy by doing it for you based on your recipe. When you load your ingredients into your local ‘pantry’, you are asked to add the nutrition information per 100g. This data is used as the basis for calculating the nutritional values for your products.