Nutrition Labelling Deadline Approaches

tick tock tick tockIn December 2016, the EU Food Information to Consumer regulations (or EU FIC) will come into force in full, requiring nutrition data to be included on all pre-packaged food labelling. Are businesses ready for this change or are they going to be caught short?

The EU 1169/2011 Directive required a swathe of changes to food labelling in the processed and pre-packaged food industry. It is such a wide ranging change the EU gave 5 years for it to be implemented and that 5 year deadline arrives on 13 December 2016.

The first phase of the regulations came into effect on 13 December 2014 and has been largely implemented without much difficulty by the food industry. It covered identification, legibility, ingredient and allergen listing, durability and other matters that were already in place in the UK’s own 1996 regulations.

Phase one harmonised and unified food labelling under one set of rules, making it easier for food businesses to comply. That being said, there are many disparate directives that can impact on the labelling of any specific product and it is far from easy for food producers to ensure they are meeting their obligations.

The second phase of EU FIC requires pre-packed and processed foods to be labelled with defined nutrition data. For small businesses, there are few viable solutions to help them meet their obligations to the Brussels machine.

The EU FIC specifies that food businesses include a minimum of the following nutrient indicators per 100g/100ml on their products:

  • Energy (kcal and kJ)
  • Fat (g)
  • Saturated Fat/Saturates (g)
  • Carbohydrate (g)
  • Sugar (g)
  • Protein (g)
  • Salt (g)

The data must be placed at least on the “back of pack” but may be duplicated in full on the “front of pack”. If the business would rather, they can limit the front of pack data to just energy, but they cannot pick and choose, it is nothing, just energy or a reduced list; Energy, Fat, Saturated Fat, Sugar, Salt.

Food business can also include other specific nutrient data in the back of pack data on their products. As with the minimum, these nutrients must appear in a specific order, be reported in specific units and within the same field of view as all other nutrient data.

The additional nutrients are:

  • Mono-unsaturates (Fat) (g)
  • Poly-unsaturates (Fat) (g)
  • Polyols (Carbohydrates) (g)
  • Starch (Carbohydrates) (g)
  • Fibre (g)

It is also possible to mention vitamins and minerals but only from the approved listing found in the appendices of the 1169/2011 Directive.

Of course all data shown on the labels must be legible in accordance with the regulations too. That legibility standard is set in a typically complex appendix stating that a font should have an “x” height of not less than 1.2mm. To normal mortals using normal fonts (Arial or Times New Roman), that is a font size of 6.5 points.

Solutions

There are three ways food businesses can go about solving their obligations:

  1. Send their products for expensive and time consuming laboratory analysis.
  2. Download and decipher the approved CoFIDS database to calculate their nutrition data.
  3. Alternatively, buy one of the few software solutions to calculate nutrition data for them and export that to their labelling system.

Assuming most food businesses have neither the time nor money to entertain the first two options, this leaves the need for the industry to embrace the software solutions being offered to them.
These offer a practical, affordable and technically satisfying solution to the pen-pushers of the Brussels juggernaut.

How does the software work?

The basic premis for the software solutions are simple.

Step One: Once you know the nutrition data for a given quantity of a foodstuff (e.g. 100g), you can calculate any nutrition data for any other quantity of that same foodstuff by simple factoring.

Step Two: if you know the quantity of all the individual foodstuffs that you use in your recipe, you can repeat step one then add them together to give nutrition data for your recipe.

Step Three: Once you know the nutrition data for your recipe in full, you can factor that back to an accurate nutrition table for 100g/100ml of that product.

It’s just maths!

The difficulty faced by food producers is that their recipes are unique to them and they may use a combination of constituent ingredients that are not in the CoFIDS dataset.

To overcome this, the software solutions allow users to add their own products into a secondary library alongside the CoFIDS data set.

For example, if a producer is using a lesser known wholesale brand of mayonnaise in their products, they can add that mayonnaise brand to their own private library for use in their labels. In doing so, the food producer adds the nutrition data and lists the ingredients that themselves are labelled on the product.

Once the constituent ingredients are all present in the private and/or CoFIDS data libraries, the user can create a recipe to represent that product. The recipes can include few or many constituent ingredients and the user simply indicates how many grams of a foodstuff are used in the recipe to create the overall product. Once complete, this can be named and saved and even re-used to create a variant of a recipe (e.g. Ham Sandwich used to create the variant Ham & Egg Sandwich or Ham & Salad Sandwich).

Implementing the data:

Each food producer will have their own labelling solution in place and this will need to be changed but the print industry has a role to play in helping food producers meet the change.

The impact for small businesses using thermal print solutions could be limited whereas larger operators will have substantial on-costs atop the burden of gathering the data.

For smaller producers, it is common place to use a small direct thermal or thermal transfer printer to create labels using a pre-designed stock label. These players are going to see the least impact on their business as it is possible to link the output of the nutrition calculation software directly into label databases. In effect, they will only need to redesign a template layout for their labels to implement the change.

For larger producers using fully pre-printed labels, the cost implications could be massive with a need to re-design label layouts, add new typography as well as pay for expensive printing plates to be made to manufacture the new labels.

Digital print solutions are a growth area in the label print industry that no longer needs expensive printing plates. Digital not only enables customers to change designs at the drop of a hat but also exploit shorter print runs to test re-designs for marketing purposes or to run competitions.

This regulatory change may persuade more food manufacturers to seek out digital printing solutions from the label press industry.

Getting Help

The onus of the law is upon food producers. As ever, ignorance is no defence from the bureaucratic onslaught.

Your local County Council Trading Standards Department should have help on their website to assist you meet the regulatory burden.

You can find more information about the EU FIC regulations in a variety of publications through the EU machine itself at:

http://ec.europa.eu/food/safety/labelling_nutrition/index_en.htm

and there are additional resources provided by other for and not for profit organisations. This can be located by searching for “1169/2011 regulations”, “EU FIC Regulations” or “Food Labelling Regulations” using your web browser and search engine.

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