The Food Safety Authority of Ireland (FSAI) has today (17th July 2012) published an “Overview of Changes to Food Labelling Introduced under the New Food Information Regulation”. The information booklet provides a short simple guide to the main changes to be brought about by Regulation (EU) No 1169/2011.
The new rules, which in the main will apply from 13th December 2014, are quite complex and require food businesses at all stages of the food chain to be familiar with them. Obligations to ensure that food complies with the EU Regulation and all applicable national legislation are placed on food businesses such as retailers as well as on the manufacturers and producers that are responsible for labelling the foodstuff.
The Regulation refers to ‘food information’ which means information concerning a food and made available to the final consumer by any means including “modern technology tools or verbal communication” as well as traditional product labels.
With some minor revisions, the mandatory particulars are the same as set out in current labelling legislation. The main changes brought about by the Regulation are well-known at this stage and include minimum font sizes, origin labelling for certain meat products, changes to the information that must be in the same field of vision and the method of labelling allergens. Arguably the single biggest change is the requirement for a mandatory nutrition declaration which applies from 13th December 2016.
Certain foodstuffs are exempt from parts of the Regulation including the provision of a nutrition declaration and food businesses should check to see whether exemptions apply to some or all of their products.
There is no doubt that the new law presents significant challenges and opportunities for the food industry. Food businesses should begin taking steps to determine how the Regulation will impact on them and plan to make any necessary changes. This will include a review of all current labels and assessing what work needs to be done so they will be legally compliant when the new law takes effect. Technical, regulatory and marketing teams will need to work together with legal advisers to ensure that revised labels still contain all the key brand and promotional information alongside mandatory food information.