EU No 1169/2011 applies to all food and drink products to be marketed in the European Union. It entered application on 13th December 2014 with the obligation to provide nutrition information applying from 13th December 2016.
Key labelling changes included:
- Minimum font size for mandatory information
- Presentation of allergens in the list of ingredients
- Mandatory allergen information for loose and pre-packed for direct sale goods
- Requirement of certain nutrition information for majority of prepacked processed foods
- Mandatory origin information for fresh meat from pigs, sheep, goats and poultry
- Labelling requirements for online, distance-selling
- List of engineered nanomaterials in the ingredients
- Specific information on the vegetable origin of refined oils and fats
- Clear indication of "formed meat" or "formed fish"
- Clear indication of defrosted products.
Recognising the changing pattern of food consumption, the Food Information for Consumers (FIC) Regulation also applies to products sold via the internet (distance selling). It introduced an obligation for those marketing non-packaged or loose products to have information available to inform the consumer of any potential allergens present.
In addition to the generic rules in place with the FIC Regulation, it is important to assess the product-specific legislation in place across many product areas.
What role does Food Labelling play in driving consumer behaviour?
In December 2014, the TNS Study was published. It was designed to explore the impact of food labelling in relation to consumer purchasing decisions in the specific areas which were beyond the original scope of EU FIC Regulation. Conclusions from the TNS Study showed the following impact food information had on consumers’ decision making:
- Overall introduction of trans fatty acid levels did not lead to healthier choices
- ‘May contain’ was effective in driving more cautious choices among allergy affected consumers.
- A misunderstanding of ‘best before’ is likely to be contributing to food waste
- Country of Origin labelling of primary ingredients did not appear to have a positive effect on healthier food choices
- Alcohol labelling: Calorie and healthy limit information appeared to impact behaviour
Looking across the EU, several initiatives are being instigated by individual Member States with an increase in Country of Origin Labelling (COOL) labelling trials being the most popular.
Current Member State Initiatives include:
- National Country of Origin Labelling (COOL)
- Presentation of nutritional information
- Additional information on alcoholic products
- Review of date marking in relation to food waste
The EU FIC Regulation has led to a major review of all food and drink labels with the final mandatory nutritional labelling requirements applying from December 2016. Key questions remain for policy makers seeking to influence consumer purchasing decisions in the design of food labels: What is enough information? Are symbols clearer than words?
The contribution that the new labelling presentation will play in reducing overweight and obesity levels across Europe is currently unclear. Research indicates the date of minimum durability is considered by consumers to be one of the most valuable pieces of information on pack, and for those with special dietary needs, the additional information provided is considered helpful.
Challenges lie ahead as we approach Brexit and ask what the future may look like. How will the various Member State initiatives impact future labelling? How can we improve the health of the nation and at the same time facilitate trade in a harmonised way at on a global level?
- European Commission https://ec.europa.eu/food/safety/labelling_nutrition/labelling_legislation_en
- TNS Study into consumer behaviour and decision making relating to food labelling (Dec 2014 ) https://ec.europa.eu/food/sites/food/files/safety/docs/labelling_legislation_study_food-info-vs-cons-decision_2014.pdf
- Food Standards Authority Ireland study into Consumer Attitudes to Labelling. file:///C:/Users/sarah/Downloads/Consumer_Attitudes_Labelling_Dec_09%20(1).pdf
- European Food Information Council Global Update on Nutrition Labelling http://www.eufic.org/images/uploads/files/ExecutiveSummary.pdf
- European Flabel Research program on Nutritional Labelling http://www.flabel.org/en/
- Department of Health Technical guidance on nutritional labelling https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/595961/Nutrition_Technical_Guidance.pdf
- BRC Drink awareness https://brc.org.uk/news/2017/uk-retailers-unveil-revised-alcohol-label-to-encourage-more-responsible-drinking
- WRAP review of date labelling and storage guidance http://www.wrap.org.uk/sites/files/wrap/Technical%20report%20dates.pdf