EU Food Information to Consumers Regulations

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:

  • Legibility
  • Title & Description
  • Food business contact details
  • Ingredients in the product (QUID compliant)
  • Standardised allergen highlighting
  • Use by or Best Before dating
  • Quantity
  • Nutrition data

Legibillity

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.

Ingredient Listing

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.

Quantity

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.

Nutrition Information

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
  • Fat
  • Saturated Fat
  • Carbohydrates
  • Sugar
  • Protein
  • Salt

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.

You can buy Nutridata Pro or Nutridata Lite directly from this website or ask for a free trial by filling the form below:

Natasha’s Law – what you need to know

Natasha’s Law is the name given to a set of regulations regarding food labelling for the food industry. It is named after Natasha Ednan-Laperouse, a young lady who tragically died from an allergic reaction to a baguette containing poppy seeds.

The law was enacted after extensive lobbying by Natasha’s parents, to prevent such an unnecessary death from happening again.

The law comes into effect in October 2021. It pertains to pre-packed foods sold on the same premises as it was made.

Natasha’s Law is effectively a widening of the scope of EU Food Information to Consumers (EU FIC) regulations brought in under EU Directive 1169/2011.

That regulation requires that all pre-packed food sold off-site should have full ingredient listing and nutrition data on the packaging. There is a prescribed format for the ingredient declaration too.

Natasha’s Law requires the same labelling as EU FIC, but without the need for nutrition data. This means that all pre-packed food must include a properly formatted ingredient declaration and any of the 14 allergens must be highlighted.

What is a properly formatted ingredient declaration?

The ingredient declaration must include:

  • List of ingredients
  • Allergens highlighted
  • In Quantitative Order (QUID)

Ingredients:

The ingredient declaration must include a full listing of all the constituent ingredients within a product. For example, you cannot just say a sandwich includes bread, mayonnaise and tuna, it must include the ingredients within the bread, the mayonnaise and the tuna.

Allergens:

The allergens within the ingredients must be highlighted and the method of highlighting must be described in the listing. You can use any method of highlighting but Nutridata will convert any allergen into UPPERCASE as this will work with all labelling software.

If uppercase text is the method then a statement at the start of the ingredient listing should read as follows:

Ingredients (Allergens listed in UPPERCASE):

Quantitative Order (QUID):

The law regarding quantitative declaration is somewhat technical. For the sake of this blog post, all that we need to know is that the ingredient listing should be in quantitative order.

How can Nutridata help?

Nutridata has been developed especially to help both businesses affected by EU FIC regulations and the new Natasha’s Law regulations.

If you only sell pre-packed food for sale on the same site as the pre-packed food was made, Nutridata Lite software will cover your needs. This version is ‘cut down’ to process ingredient listing, allergens and QUID.

If you sell pre-packed foods to be sold off-site, then you need to include nutrition data and you will need to use Nutridata Pro. This version offers the same functions as Nutridata Lite but adds nutrition calculations and cost calculations to your products and recipes.

The data handling you need to do to meet Natasha’s Law is all handled within the software. All you need to do is follow the steps to create your products. Those steps are quite simple:

  • Add your pantry ingredients with their constituent components
  • Create recipes from your ingredients, noting by weight how much of each ingredient constitutes the receipe
  • Create a Product from your recipe (basically adding a title, barcode and any other pertinent information such as shelf life, storage instructions or other warnings).

Once you have done that, Nutridata does the rest of the work for you.

  • Nutridata will re-order your ingredients so the largest constituent is first and the smallest is last.
  • It will then determine the percentage for each ingredient in the recipe.
  • It will parse your ingredients and force any of the 14 allergens into upper case.
  • It will write the full ingredient declaration for you to add to your labels.

The software works on a website so is compatible with all operating systems. It works with Windows, Mac, Linus and even on iPhones, iPads and Android phones and tablets.

The data the software produces can be exported for use with your labelling software or system. It exports data as an Excel Spreadsheet from which you can work.

Nutridata works especially well with Label Direct Labelling Software. We offer a range of thermal printers to suit all business sizes from small outlets up to large-scale wholesalers.

You can start a free trial of Nutridata by filling in the form below. The trial version will last for 30 days and is 100% functional with the exception of download function.

How to calculate nutrition data

You need to know how to calculate nutrition data because the EU directive 1169/2011 came into full effect on the 13th of December 2016. The first phase of this directive came into effect in 2014 on December 13th but the second requires nutrition data.

Natasha’s Law comes into effect in October 2021. This requires all pre-packed foods to be fully labelled with their ingredients in QUID order and all allergens must be highlighted in accordance with the EU Directive 1169/2011.

This begs the question of how to calculate nutrition data?

The new regulations require allergens to be highlighted within the single ingredient list for the product but ingredients also need to be stated in quantitative order. Quantitative order simply means the largest constituent ingredient must be indicated first. Then the second-largest and so on. The percentages of these ingredients should also be included.

Technically, you only need to quantiatively indicate the ingredients specified in the the product description. For example, a “Cheese” sandwich only needs the proportion of cheese indicating.

There are several ways highlighting ingredients can be achieved; Users can use bold text, underline text, coloured text, or italic text. You can also indicate in a combination of these methods. For simplicity, we recommend using UPPERCASE text instead as this is easier to implement.

There are 14 allergens that must be indicated on labelling if they are present within the ingredients of the product. These include wheat or oats or any other cereal containing gluten and also include milk, eggs, fish, crustaceans, molluscs to name a few.

Text Size Rules

Another aspect of the legislation was to harmonise the legibility of text on food labels.

Historically, the text could be incredibly difficult to read as manufacturers crammed as much information into as small a section of the label as possible so as to maximise the marketing potential of the rest of the label.

The new regulations require that all text must be legible with a specific height of the letter “x” in the font no smaller than 1.2 millimetres. In layman’s terms, that means that the standard Arial or Times New Roman font needs to be 6.5 points and size.

Nutrition Data

The second phase of the regulations from December 2016 requires that nutrition data is supplied with all pre-packaged food so that consumers can make choices regarding the nutrition within the food they buy.

As a minimum, the law stipulates that this information must be conveyed to the customer per 100 grams.

It is also possible to convey the information additionally per serving so, for example, a sandwich would constitute a serving so a food producer could provide the information based on the entire sandwich.

The food producer can also indicate nutrition values in a portion, for example, a biscuit or a small piece of chocolate.

But the food producer must also provide the information in a per 100g format in all instances.

Nutrition Data Calculations

In order to calculate the nutrition values of prepackaged food for sale to the public food production businesses need to know the nutrition values for the constituent ingredients within their product.

Perhaps the best way to demonstrate how to calculate nutrition data is to give an example; a ham and mustard sandwich.

A ham and mustard sandwich might consist of four ingredients

  • bread,
  • ham,
  • mustard,
  • and margarine or butter to make a sandwich.

Each of these ingredients will be incorporated along the lines of a recipe; that is to say, there will be a specific weight of each product to make up a standard product.

Food manufacturers need to start with the basic data for the nutrition for each of the ingredients – as mentioned, the legislation requires that nutrition data is provided per 100 grams.

As all manufacturers are required to do this, most food producing companies should be able to obtain that information directly from the packaging of the products that they buy in or by speaking with their supplier.

In our example, the food producer could tabulate the data from the constituent ingredients into a table. The information that must be conveyed includes energy in both kilojoules and kilocalories; they must also convey total fat, saturated fat, carbohydrates, sugar, protein, and salt – all in grams.

Food producers can also indicate monounsaturated fat, polyunsaturated fats, polyols and starch (which are carbohydrates) and fibre if they wish to do so but these are optional.

The order of the nutrients is specific and must be adhered to comply with the regulations.

Once the table of data is prepared per 100 grams for all of the ingredients, the food producer needs to understand the weight of each product used in the recipe to make the sandwich. In this example, the food producer would need to know the weight of two slices of bread (let’s say 60 grams), the ham they use (e.g. 30 grams), 10 grams of mustard 5 grams of margarine.

Once this has been done a simple calculation is applied to each of the constituent ingredients to determine how many calories, how much fat, saturated fat etc. is present in the recipe. The calculation will be to divide the per 100g nutrition data by 100 then multiply that by the weight of that constituent in the ingredient.

E.g. If 100g of ham is 350 calories, divided by 100 is 3.5 calories per gram. 3.5 calories per gram x 30 grams used in the recipe is 105 calories.

Once this is complete, the food manufacturer will have an accurate indication of the total nutrition data for the ham and mustard sandwich by simply adding the values for each constituent ingredient together as a total for the recipe.

And that is how to calculate nutrition data using Microsoft Excel or Open Office Calc.

Right now, food manufacturers across the UK are facing a huge challenge in achieving the objectives set out in the regulations and they need to address them very quickly if they have not already.

In order to help food businesses across the UK, Positive ID Labelling have developed Nutridata Nutrition Calculation Software that allows food users to input their constituent ingredients, create recipes and then create and product data to mee the EU Regulations.

Nutridata software automatically calculates nutrition data for food producers and exports it in an Excel spreadsheet. This can be used with our labelling software or can be used by graphic designers to alter information on labels printed by label manufacturers.

Contact us on the form below to start your free trial or buy here

The 14 Allergens

Foods containing the following allergens must be highlighted in an ingredient list:

  • Cereals products containing gluten (Wheat, Barley, Oats, Kamut, Spelt)
  • Celery (and celeriac)
  • Crustaceans (Shrimp, Lobster, Scampi etc)
  • Eggs
  • Fish
  • Lupins
  • Milk
  • Molluscs (Welks, Oysters, Mussels)
  • Mustard
  • Nuts (Tree nuts: Brazil Nuts, Cashews, Cob nuts, Hazelnuts, Macadamia, Pecans, Queensland nuts etc.)
  • Peanuts
  • Sesame (Tahini)
  • Soya
  • Sulphites and Sulphur Dioxide (if more than 10mg/kg or 10mg/litre)