Consultation Document

Transcription

1 Consultation Document The following draft guidelines have been produced by the British Sandwich Association and Monmouth County Council under the Primary Authority scheme and are being circulated to the industry and enforcement bodies across the UK for comment before a final version is produced later this autumn. Please note that Defra has been asked to clarify the use of the term Use by End of which appears in this draft. The closing date for receipt of comments is 1 st November 2013 Reponses should be sent to The British Sandwich Association, 18c Moor Street, Chepstow NP16 5DB or by to jim@sandwich.org.uk GUIDANCE NOTES ON THE LABELLING OF SANDWICHES CONTENTS 1. Introduction 2. General Labelling Requirements 3. When is Labelling Required? 4. Manner of Marking or Labelling 5. Names of Products 6. Ingredients Lists 7. Nutritional Labelling/Nutrition Claims 8. Other Claims 9. Additive Declarations 10. Date Marking 11. Allergen Information 12. GM Ingredient Declaration 13. Other Legal Requirements Annex A: Food Names Guidance Annex B: FSA Advice on the Labelling of Sandwiches Containing Meat Ingredients August 2006 Annex C: Allergens Schedule Annex D: Labelling examples 1

2 Definitions: Manufacturer a business that makes sandwiches at one or more central locations which are then sold through third-party owned outlets. Central Production Unit a site where sandwiches are manufactured for retail through the business own retail or catering outlets Sandwich Bar where sandwiches are made on site or at a central production unit owned by the same business for direct sale to the end consumer. Sandwich Retailer a business that sells sandwiches which are bought in for resale from a manufacturer 1. Introduction 1.1 This guidance has been prepared by The British Sandwich Association and Monmouthshire County Council under the Primary Authority Scheme for use by enforcement officers solely in relation to advice on labelling to be given to producers and sellers of sandwiches (e.g. filled rolls, baps, baguettes, French sticks, pittas, ciabattas, wraps etc.). This guidance is not intended to cover other products such as quiches, pizzas, pies etc. 1.2 This guidance primarily relates to compliance with legal requirements. However, it also includes best practice advice which appears in blue in the text. Best practice guidance is intended to provide greater clarity for consumers, however, compliance with best practice guidance is not a legal requirement. 1.3 This guidance takes account of the new Food Information Regulations established by the European Commission (Consumers Regulation (EU) No. 1169/2011) which comes into effect from 13 th December General Labelling Requirements Responsibilities The business or person whose name the food is marketed under is responsible in law for the food information provided on the label. So, if a sandwich is made by a manufacturer but sold under the name of a retailer or brand name, the responsibility for ensuring the accuracy of the label rests with the retailer or brand owner. The manufacturer would, however, remain responsible if the product is sold under its own name or a brand name it owns. 2

3 2.1 Generally manufactured pre-packed sandwiches are required to be labelled with the following information: (a) The name of the food** (b) A list of ingredients (c) QUID declarations (where appropriate), normally within ingredients list but can also be next to the name of the food (d) A date mark (which can also act as the lot mark) (e) Storage advice (if appropriate) (f) Instructions for use (if appropriate) (g) The name and address of the operator or business responsible for the food information (h) A list of additives (if appropriate) (i) Identification of irradiated ingredients (if present) (j) Identification of genetically modified ingredients (if present) (k) A list of specified allergens (if present) (l) A nutritional declaration [ NOTE: ** where the term name of the food appears throughout this document this refers to the true nature/legal name of the food]. 2.2 When sandwiches are sold pre-packed whether manufactured or made on the premises - they must state the name of the food in such a way as to clearly indicate its true nature and to distinguish it from products with which it could be confused. It may, in addition, bear a marketing or fancy name [e.g. BLT ] but care must be taken not to mislead consumers by over simplifying names. It is generally considered good practice to state an appropriate description (such as Bacon, Lettuce and Tomato) alongside the marketing or fancy name to avoid any confusion. 2.3 The name given to the product must be its true legal or, in the absence of a true legal name, its customary name. Where no such name exists, the name given to the product must provide the key information that consumers need to make their choice. This needs to include the presence of major ingredients (e.g. meat, cheese etc) and characterising ingredients (e.g. sun dried tomatoes, mayonnaise etc.) that could govern consumer choice. 2.4 It is likely to be considered misleading if the name of the food omits to declare the processed nature of major ingredients that might affect the consumer s assessment of character and quality. 2.5 Care must be taken with illustrations on labels or packs that these do not mislead consumers. For example, a generic illustration of mixed salad, including a tomato, might be considered misleading if the sandwich within did not contain tomato. 3

4 3. When is Labelling Required? 3.1 Full labelling (i.e. that set out in paragraph 2.1 above) is necessary in relation to pre-packed sandwiches produced by a manufacturer but sold through a third party outlet and which are sold in their original packaging. 3.2 Reduced labelling (the name of the food; declaration of additive categories/gm/irradiated ingredients/allergens) may be used where sandwiches are: (i) Produced, packed and sold within the same retail premises; or (ii) Produced and sold non pre-packed within the same premises; or (iii) Produced at a central location and sold (pre-packed or non pre-packed) by staff directly employed by the same business via shops, vans or office delivery rounds; or (iv) Produced and delivered non pre-packed to a retail premise (e.g. from a central bakery to retail premises owned and run by the central bakery) and then sold non pre-packed from those premises. 3.3 Limited labelling is required where sandwiches are made and sold within the same premises (e.g. a canteen or sandwich bar). However, any descriptive/menu names applied must be accurate and, where applicable, an indication of any irradiated and/or genetically modified ingredient must be given together with allergen information (see paragraph 12.3). Note: it is a new requirement under the EC regulations that allergen information must be provided for foods sold nonprepacked or prepacked for direct sale. 3.4 Vending machines selling sandwiches must have a menu with the name of the food as well as the basics set out for limited labelling (3.2) unless this information can be clearly read on the product pack from the outside of the machine. The sandwiches themselves will be pre-packed and must be fully labelled. 3.5 Whilst some sandwiches require limited labelling under the regulations any names or descriptions applied must comply with the general provisions of the Food Safety Act 1990 and other trading standards legislation which prohibit false and misleading labels, descriptions (including verbal descriptions) and descriptions in advertisements. [ NOTE: The term pre-packed is defined in the Food Labelling Regulations 1996 as put into packaging before being offered for sale in a way such that the food, whether wholly or partly enclosed, cannot be altered without opening or changing the packaging and is ready for sale to the ultimate consumer or to a catering establishment. Similarly pre-packed for direct sale is defined as pre-packed by a retailer for sale by him on the premises where the food is packed or from a vehicle or stall used and operated by those working for him ]. It is generally considered good practice for retailers and manufacturers to provide as much information as possible on labels to help consumers make a reasoned choice. 4

5 Where reduced labelling is used, retailers should ensure that those selling the sandwiches direct to the consumer are fully briefed on information (e.g. ingredients, allergens etc.) to enable consumers some of whom may have allergies with all the information they require to make a proper selection. It is good practice for staff to have access to a reference folder or similar checklist so that they can handle customer inquiries accurately. 4. Manner of Marking or Labelling 4.1 For all fully labelled sandwiches, the required information must be marked: (i) on the packaging; or (ii) on a label attached to the packaging; or (iii) on a label that is clearly visible through the packaging. 4.2 For sandwiches (other than those sold at catering establishments) which are required to have reduced labelling, the information must be marked: (i) on a label attached to the food; or (ii) on a label, ticket or notice that can easily be seen and read at the place of sale by an intending purchaser. 4.3 This required information must be marked in a conspicuous place, be easy to understand, indelible, clearly legible and not hidden, obscured or interrupted by other written or pictorial matter. It is also a requirement that in the case of packaged sandwiches this information must be printed in characters using a font size where the x-height is equal to or greater than 1.2mm. In the case of packs or containers where the largest surface area is less than 80 cm 2, the x-height of the font can be equal to or greater than 0.9 mm 4.4 Under the FIR the previous field of vision requirements have been amended, It is now a requirement that the following shall appear in the same field of vision: 1. The name of the food 2. The net quantity (not applicable in the case of sandwiches) Good Practice would be to continue to include the name of the food, date mark and storage conditions within the same field of vision, as outlined in the FSA Clear Food Labelling Guidance - 5

6 5. Names of Products 5.1 The name of the food is a key labelling requirement for all foods and can take the form of: (i) (ii) (iii) a name prescribed by law (in practice this is only likely to apply to sandwiches containing certain seafood, fish and meat products as ingredients); where there is no name prescribed by law, a customary name may be used (i.e. names that have become commonly understood by consumers and established over time such as BLT bacon, lettuce and tomato); or where no customary name exists, a name that is sufficiently descriptive to inform the consumer of the true nature of the food and to enable it to be distinguished from products with which it could be confused. 5.3 Most sandwiches will fall into category (iii) and require a descriptive name. Further guidance on the true names of sandwiches and of sandwiches with meat ingredients is set out in Annexes A and B. 6. Ingredients Lists 6.1 Where a list of ingredients is required, the list must be headed by the word Ingredients and the contents must be listed in descending order by the weight of each ingredient at the time the sandwich was prepared. Because of the manual nature of some elements of sandwich making, it is generally accepted that some of the quoted ingoing quantities will be subject to variation. Sandwich producers, however, should control ingredients proportions as accurately as is reasonably practicable given the size and scale of the business and the available technology. 6.2 The name used for an ingredient (excluding brand names) must be the name that could be used as the name of the food if that ingredient itself was being sold as a food. 6.3 Compound ingredients are ingredients that are themselves made up of more than one ingredient e.g. bread, chicken roll, sausages, mayonnaise. 6.4 The full list of ingredients of a compound ingredient needs to be incorporated in the product ingredient list. This can be done by stating the compound ingredient name followed by, in brackets, its ingredient list or by omitting the compound ingredient name and giving one combined ingredients list. Some compound ingredients can be listed as generic names only (e.g. mixed cheese or flour see Schedule 3 of the Food Labelling Regulations 1996 for further details). 6

7 (i) 6.5 There are some special exemptions for a few ingredients if they are present in amounts of less than 2% of the product as sold. These are: * ingredients for which their composition is prescribed in EC Law (i.e. honey, jam) * herbs and spices or mixtures of both * foods which do not require an ingredients list (e.g. cheese, butter) For these ingredients only the compound food name and any additives or allergens they contain need to be listed. 6.6 Quantitative Ingredient Declarations (QUID) within ingredients lists must be made when the following criteria apply: (ii) The ingredient is included in the name of the food and is usually recognised under that name by the consumer (e.g. Ham and Cheddar Sandwich) except in relation to some ingredients such as mustard, mayonnaise etc. or where variation in quantity would not influence consumer choice; or The category of ingredient is included in the name of the food (e.g. Cheese Salad Sandwich); or (iii) An ingredient/category of ingredient is given emphasis on the label in words, pictures or graphics (e.g. made with extra sun dried tomatoes); 6.7 QUID should be the average or typical figures based on the weight of the ingredient at the stage at which the sandwich is being assembled expressed as a percentage. The % declaration usually appears in the ingredients list but may alternatively appear either in or immediately next to the name of the food. 6.8 If ingredients have been irradiated this fact must be declared either on the product or by means of an accompanying notice. The wording to be used is either irradiated or treated with ionising radiation. Similarly, if an ingredient is present in the form of nano-materials, this fact must be indicated in the list of ingredients. 7. Net Quantity Although the EU Regulations require that net quantities should be declared on products, it is accepted by the UK Government that it would be impractical to provide weights on sandwiches due to the way they are made, provided that consumers can clearly see from the pack what they are purchasing. 7

8 7. Nutrition Labelling/Nutrition Claims 7.1 It is a requirement of the Food Information Regulations that the following mandatory nutrition information must be provided on manufactured pre-packed products as a minimum expressed as per 100g or 100ml. The information may also be provided as per portion (e.g. half a pizza) and/or per consumption unit: a) Energy value b) Fat content c) Saturates d) Salt content e) Carbohydrates f) Sugars g) Protein This information would normally appear within the ingredients list on the back of the pack in a pre-packed sandwich. In addition to the mandatory information listed above, legislation allows for voluntary supplementary nutrition information to be given on the amounts of one or more of the following: a) mono-unsaturates b) polyunsaturates c) polyols d) starch e) fibre f) any of the vitamins or minerals present in significant amounts as allowed in current EU legislation, expressed as a percentage of the reference intakes in relation to per 100 g or per 100 ml. The mandatory nutrition declaration and the list of supplementary nutrients must be: in the same field of vision, presented together in a clear format and in the following order; energy, fat, saturates, carbohydrates, sugars, protein and salt. The information must be presented in tabular format with the numbers aligned, if space permits, were space is limited the information must appear in linear format 8

9 The legislation also allows for some of the mandatory nutrition information to be repeated in the principle field of vision (i.e. Front of Pack ) in the one of the following two formats a) energy value alone; or b) energy value plus amounts of fat, saturates, sugars and salt No other information is allowed. The information provided must meet the following criteria: Energy should be declared on its own or as energy + 4 (fat, saturates, sugars and salt) and must always be presented per 100g. The information can be provided per 100g only; per 100g and per portion; or per portion only (only where the declaration is of energy +4. Where information is provided per portion only for the four nutrients (energy + 4), the absolute value for energy must be provided per 100g/ml in addition to per portion. Energy levels can be calculated through analysis of the product by the manufacturer; from a calculation based on the known/actual values of the ingredients; or a calculation from generally established and accepted data. In the sandwich industry analysis of the finished product is generally accepted as the best approach because of the complex mix of ingredients used. Percentage reference intakes (%RIs) can be given on a per 100g/ml and/or per portion basis. (RIs are the recommended intake of a nutrient for an average person according to the EC). Where % RI information is provided on a per 100g basis, the statement Reference intake of an average adult (8400kJ/2000kcal) is required to be displayed on the label. Energy values must be expressed both in kilojoules (kj) and kilocalories (kcal). Voluntary front of pack nutrition labelling cannot be given on its own - it must be provided in addition to the full mandatory ( back of pack ) nutrition declaration, which comprises energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1) and (3) of the EU FIC). Energy values must not be included in the colour coding but should appear against a white background. It is considered good practice to provide this information on the front of the pack, usually in a traffic light format which can be clearly understood by consumers. The British Sandwich Association supports the Department of Health recommendation for a red, amber and green colour coding traffic light system on the front of packs. 9

10 Percentage reference intakes (%RIs) can be given on a per 100g/ml and/or per portion basis. (RIs are the recommended intake of a nutrient for an average person according to the EC). Where % RI information is provided on a per 100g basis, the statement Reference intake of an average adult (8400kJ/2000kcal) is required to be displayed on the label. Energy values must be expressed both in kilojoules (kj) and kilocalories (kcal). Voluntary front of pack nutrition labelling cannot be given on its own - it must be provided in addition to the full mandatory ( back of pack ) nutrition declaration, which comprises energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1) and (3) of the EU FIC). Energy values must not be included in the colour coding but should appear against a white background. Descriptions such as High, Medium or Low (HML) together with the colours red, amber or green respectively, can be used to reinforce the nutritional information It is considered good practice for sandwich makers and retailers to display calorie information on the front of packs or at point of sale, if at all possible. However, care must be taken to ensure that the information provided conforms to acceptable tolerances so as not to mislead consumers. In sandwich bars calorie information may be provided on shelf-stickers, menu boards or written menus at point of purchase. 7.2 Wherever nutrition information is stated, the amount of each nutrient must also be given. 7.3 Where sandwiches are offered for sale to the final consumer or offered for consumption by mass caterers, or where foods are packed on the sales premises at the consumers request or for direct sale, allergen information must be provided. In addition, if a nutritional claim is made about a product, a nutrition labelling declaration should be made. This should comprise the amount of energy and the amount of any nutrient about which a claim is made. All this information must be readily available to consumers, either on a label attached the product/displayed on shelf-talkers associated with the product or on a menu board/ information sheet displayed at point-of-sale. 8. Other Claims 8.1 Nutrition and health claims made on foods are tightly regulated to ensure that consumers are not misled by unsubstantiated, exaggerated or untruthful claims Regulation EC No. 1924/2006 defines how nutrition and health claims can be made in labelling, advertising, promotional campaigns and other commercial communications. 10

11 Full nutrition information must be provided on pack whenever a nutrition or health claim is made Claims may be made (and any other promotional information given) provided that they are true and not misleading. Care should be taken in relation to the use of marketing terms such as fresh, fresh today, freshly made etc. Advice on the use of these terms has been provided by the FSA in a document entitled Criteria for the use of the terms fresh, pure, natural which can be accessed at: dancenote 8.2 The FSA guidance states that expressions such as freshly cooked, freshly prepared, freshly baked, freshly picked should have no other connotation than the immediacy of the action being described. Where such expressions are used, it is recommended they are accompanied by an indication (e.g. of the date or time period freshly made this morning ) of when the action being described took place. 8.3 The terms fresh today should only be applied to products sold a maximum of 24 hours from the time of production and freshly made should only be applied to products made and sold within 12 hours of placement for sale. 9. Additive Declarations 9.1 Manufactured pre-packed sandwiches must indicate the presence of additives by stating the category names followed by the specific additive name or E number in the ingredients list. Sequestrants are now also included within this requirement. 9.2 Non pre-packed and pre-packed for direct sale sandwiches (i.e. those which can have reduced labelling) must indicate the presence of any of the following categories of additives using the category name: antioxidant, colour, flavouring, flavour enhancer, preservative and sweetener. This can be done on the label or by means of a specific notice to this effect displayed in association with the food and/or at the point of sale. There is no requirement in these circumstances to indicate the individual additives. 10. Date Marking 10.1 Fully labelled manufactured pre-packed sandwiches (other than those prepacked for direct sale) are required to carry a date mark, this is a use by or best before date A use by must be applied to products with fillings that are highly perishable and from the microbiological point of view likely, after a short period, to constitute a 11

12 danger to the public if not eaten within a short period. Examples would include egg, meat, fish, pates, soft cheese etc Whilst a best before date might be applied to sandwiches with less perishable fillings (such as jam), it is generally considered to be good practice in the industry to use the term use by for all sandwiches In practice sandwiches will generally require a use by date. As a guide, if any ingredient being used has a use by date this will trigger this form of date marking. It should be noted that sale after the expiry of the use by date is deemed to be unsafe under EC 178/2002/ Alteration of a use by date is a prosecutable offence. The use by date of any sandwich must never exceed the use by date of any of its ingredients. Furthermore, if an ingredient supplier states a use by date after ingredient packs have been opened, this is the date that must be observed The date mark must state the date up to and including that which the product will remain safe to eat in terms of the day and month e.g. Use by 31 December. If the product has to be stored in a certain way in order to remain safe to eat on up to that date then storage conditions must be given (e.g. keep refrigerated ) and/or a reference to the maximum storage temperature 10.6 The Food Standards Agency has agreed that there is no objection to the usual trade practice of using the format Use by End Of. This form of words is important with such a short shelf-life product which might otherwise be misconstrued and product removed early from shelves, causing excessive and unnecessary food waste Sandwich makers should be able to prove through shelf-life testing that the Use-by date they have stated is appropriate to the date they have given the product. 11. Allergen Information 11.1 Under the provisions of EC Regulation 1169/2011 any food containing an allergenic constituent, with the exemption of some derivatives, must be clearly marked in the ingredient list in a type that distinguishes it from other ingredients. This can be done by way of a different font, style or background colour so long as it stands out from the rest of the list. Allergen information may not be repeated elsewhere on the labelling other than in the ingredients listing. In situations where no ingredient list is required, products should be clearly marked with the word contains and then the name of the allergen. Signposting to the allergen information within the ingredients list is permitted (e.g. a statement that reads Allergy Advice see ingredients in bold ) 12

13 The above are not necessary if the name of the sandwich clearly states the ingredient or substance concerned (e.g. Cheese and Tomato) The list of allergens and derivatives is set out in legislation is provided in Annex C In determining what needs to be declared, where prepared ingredients and compound foods are brought in from suppliers, these are required to be fully labelled under the legislation. However, sandwich makers are advised to check with suppliers that these do not contain any of the prescribed allergens, particularly where ingredients are coming from outside the EC. It is generally considered good practice for sandwich businesses to include this requirement as part of their procurement procedures It is also important to follow good manufacturing practice to avoid cross contamination with allergenic ingredients. Where the possibility of cross contamination cannot be avoided additional warnings of the possibility may be advisable Under the Food Information Regulations allergen information must be provided wherever sandwiches are provided whether for sale or catering purposes. It is generally considered good practice for this information to be provided at the point of choice, either on the pack, on a shelf card/label or on a menu. It is considered the retailer or caterer s duty of care to make sure that the information is clearly visible and available for allergen sufferers. 12. GM Ingredient Declaration 12.1 Genetically modified foods are those which contain genetically modified organisms (GMOs) or ingredients derived from GMOs. In all sandwiches the presence of any such ingredients must be declared to the consumer wherever and however they are sold. There are prescribed forms of words which must be used For fully labelled manufactured pre-packed sandwiches containing GMOs or GMO ingredients either the words contains genetically modified organisms or contains genetically modified X must appear on the label. In addition where the sandwich bears an ingredient list the specific ingredients which are GMO or derivatives must be indicated by the words genetically modified or produced from genetically modified X. These statements must follow the name of the ingredient or be associated (e.g. linked with it by an asterisk) For sandwiches with reduced labelling and sandwiches sold via catering establishments the appropriate indications i.e. genetically modified or produced from genetically modified X will need to be given on an associated notice or label or 13

14 in a menu indication. This information needs to be product specific. A general notice to ask staff for information is not sufficient. 13. Other Legal Requirements 13.1 The Food Safety Act 1990; parts of the Trade Descriptions Act 1968; the Consumer Protection from Unfair Trading Regulations 2008 and EC Regulation 178/2002 prohibit false or misleading labels, descriptions and advertisements. This includes cover menus, price lists, blackboards and verbal descriptions. These are in addition to the specific requirements of the Food Labelling Regulations It is particularly important to ensure that the images or graphics on labels and packs do not mislead consumers, particularly in situations where generic labels/packs are being used. It is the sandwich maker s responsibility to ensure that packs/labels do not mislead. 14

15 Annex A: Food Names 1. General Principles 1.1 Bread: From the nature of their preparation and presentation the consumer is usually visually able to determine when white wheat flour bread has been used and so it is not generally necessary to specify this type of bread in the name of a sandwich. However, for other types of bread where the nature of the bread is not visually clear and can easily be confused, the type of bread and/or the species of grain used should be included in the full name (e.g. malted brown bread, oatmeal bread etc.). [NOTE: Wholemeal and Wheatgerm have specific meanings as defined in the Bread and Flour Regulations FSA have produce guidance on these Regulations which can be accessed at: Compositional Standards: Certain ingredients have legal compositional standards set out in the Food Labelling Regulations 1996 themselves or in other legislation such as the Meat Products Regulations Where there is a compositional standard there are often reserved descriptions for products meeting a specified composition. In these circumstances the reserved description/name should be used as part of the name of the sandwich. Examples of such ingredients include many meat products, such as corned beef, sausages, and burgers as well as cheeses such as Cheddar and Gloucester. It should be noted that these names may only be used for products meeting these compositional standards. 1.3 Protected Names: Some names have a protected status under PDO/PGI/TSG legislation which can cover origin, method of production, and composition. The protected name may only be used where a product meets all the conditions of the protection and must be used as the name. PDO relates to protected designations of origin; PGI relates to protected geographical indications; and TSF relates to traditional speciality guaranteed. 1.4 Name of the Food: There is no requirement for the name to reiterate the ingredients list but the name should accurately describe the product and inform the consumer about the key value or characterising ingredients. As a general rule the way in which ingredients are named by ingredient suppliers will act as a guide to how the sandwich itself should be described. 1.5 Ingredient Names: These should not be changed or enhanced. For example: * brown bread should not be described as wholemeal * margarine and other fat spreads should not be described as butter * cheese substitutes should not be described as cheese * processed cheese should not be described as cheese 15

16 * cured pork shoulder should not be described as ham * chicken roll should not be described as chicken * ham containing added water should not be described as dry cured. 2. Processes: Best Practice Guidance Where an ingredient has been subject to a characterising treatment or process care needs to be taken to indicate this accurately and in a manner which cannot mislead. For example: * steam cooked and flash roasted meats should be described accurately ( e.g. cooked and roasted beef) and not be simply described as roast * reformed ham must be described must not be described as traditional * ham, chicken or turkey containing added water, hydrolysed proteins and starch etc. must be described as such (e.g. processed ham, reformed ham) and not simply as ham, chicken or turkey. * ingredients treated with smoke solution/smoke flavour should be described as smoke flavoured and not simply as being smoked without further qualification. 16

17 Annex B: Summary of FSA Advice to LACORS on the Labelling of Sandwiches Containing Meat Ingredients August 2006 For both pre-packed and non pre-packed sandwiches, apart from where sandwiches are made and sold at catering establishments, a true nature name of the food is legally required. It is best practice for the true nature name of the food to be stated next to the fancy name. This is consistent with the FSA Clear Food Labelling Guidelines. Where the true nature name of the food is not placed next to the fancy name, or is not sufficiently prominent to be easily seen, then best practice is for the fancy name to be more informative to provide sufficient information for consumers to make a reasoned choice. It is considered best practice for catering establishments to be similarly explicit on any menus, tickets or notice boards. It is also a legal requirement to make the following clear on labels: Contains added water - where water amounts to over 5% of the meat product (e.g. ham with added water ) Contains added ingredients of animal origin from a different animal species to that of the meat (e.g. chicken with pork protein, ham with milk protein ). State when meat is reformed (e.g. reformed ham, chicken roll, processed ham ) 17

18 Annex C: Allergens Schedule 1. Cereals containing gluten (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridised strains); except for (a) wheat-based glucose syrups including dextrose# (b) wheat-based maltodextrins# (c) glucose syrups based on barley (d) cereals used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages. 2. Crustaceans 3. Eggs 4. Fish; except for (a) fish gelatine used as a carrier for vitamin or carotenoid preparations (b) fish gelatine or isinglass used as a fining agent in beer and wine 5. Peanuts 6. Soybeans, except for: (a) fully refined soya bean oil and fat# (b) natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soya bean sources (c) vegetable oils derived from phytosterol esters from soya bean sources (d) plant sterol ester produced from vegetable oil sterols from soya bean sources. 7. Milk (including lactose); except for (a) whey used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages (b) lactitol 8. Nuts, namely almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoisis (wangenh) K.Koch), brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia) 9. Celery 10. Mustard 11. Sesame seeds 12. Sulphar dioxide and sulphites (at concentrations of more than 10 mg/kg or 10mg/litre expressed as SO²) 13. Lupin 14. Molluscs 18

19 # The exception only applies to products derived from these products in so far as the process they have undergone is not likely to increase the level of allergenicity assessed by the European Food Safety Authority for the relevant product from which they originated. 19

20 Annex D: Model Label/Notice Examples References: EC Food Information Regulation No 1169/ PDF Food Labelling Regulations 1996, as amended by the Food Labelling (Amendment) Regulations 1998 and the Food Labelling (Amendment) (No. 2) Regulations 1999 DEFRA Food Information Regulations 2013 Guidance to compliance /consult-fic-guidance pdf Nutrition Labelling Step-by-step guide to creating a front of pack nutrition label /FINAL_VERSION_OF_THE_2013_FOP_GUIDANCE_-_WEB.pdf 20