Provision of Food Information to Consumers A manufacturer s perspective Neil McGowan, 4 th December 2012
Kerry Foods Brands
Back to Basics» European Commission blue sky seminar Rotterdam, 2006 :» What do consumers really want from food labels?» (1) Name; (2) Ingredients; (3) Best Before Dates; (4) Instructions for Use; (5) Brand information for re-purchase» Consumers think that information should be as complete as possible but think that too much information is given.» Industry was confused by a multitude of out of date, complex Directives» Challenge for Regulators was to try to solve these conundrums
Objectives Easier to Export Harmonisation Consumer Understanding Simplification Give consumers the facts Easier to Navigate & Comply
EU Process 6 years later Pressure from all interest groups Compromises were made Key decisions delayed A REGULATION OR A POLICY DOCUMENT?
The EU MUST develop. Type Topic Req d Deadline Rules On Origin of primary ingredients when Yes different from COO Dec-13 Report On Origin of meat as an ingredient Yes Dec-03 Report On Origin of certain other foods Yes Dec-14 Report On Trans Fat Labelling Yes Dec-14 Rules On Legibility Yes Exp d December 2014 Rules On Portion Size Yes No date Rules On GDA for specific population groups Yes No date Report On Additional forms of presentation Yes Dec-17 Rules On Suitability of foods for Vegetarian/ vegans Yes No date
The EU MIGHT develop.. Type Topic Req d Deadline Rules On declaring Negligible nutrients No No Date Rules On Date of minimum durability No No Date Rules On the use of symbols No No Date Rules On net quantity for certain foods No No Date No No Date Rules Provision of information by other means Rules Presentation of nutrition declaration No No Date Rules Conversion factors for vitamins and minerals No No date
Labels can t do everything EU LABELLING RULES READY AT LAST
Requirements.. Current Regulations 1. Name of the food 2. List of ingredients 3. Allergens 4. Quantity of certain ingredients 5. Net quantity 6. Date of minimum durability 7. Special storage instructions or conditions of use 8. Name and address of seller in the EU 9. Place of origin of the foodstuff if its absence might mislead 10. Instructions for use where necessary 11. Alcoholic strength New Regulations 1. Name of the food 2. List of ingredients 3. Allergens 4. Quantity of certain ingredients 5. Net quantity 6. Date of minimum durability 7. Special storage conditions and/or conditions of use 8. Name and address of seller in EU 9. Country of origin or place of provenance where provided for in Article 26 10. Instructions for use 11. Alcoholic strength 12. Nutrition declaration
Font size» Minimum font size for most packs» x height of 1.2mm approx. font size 8.5 9» Some exemptions for smaller packs» Does font size or good packaging design help legibility?» What about multilingual packs
Nutrition Information» Mandatory on Back of Pack Mandatory» Table with energy and the amounts of fat, saturates, carbohydrate, sugars, protein and salt Energy Fat» Fibre out & Sodium changed to Salt Of which Saturates Carbohydrates» Information must be in 100g and can be also given by portion (rules around portions) Of which sugars» Many ways to label nutrition information Protein Salt
Voluntary Nutrition Information» GDA s were introduced on a voluntary basis by the food industry across the EU in 2006» High uptake of GDA in Ireland by most retailers and most manufacturers 90% of Retail own brand, 85% of Brands» Front of Pack nutrition labelling not mandatory in any format» Current GDA s not a perfect fit Energy values in kilojoules & per 100g
Interpretation» How do I highlight allergens in the list of ingredients?» How is the primary ingredient interpreted?» What s the largest surface area?» How do you define pre-packed for direct sale?» How will the regulation be enforced in my export markets?» What about slow moving lines and long shelf life products?» Where did I leave that guidance note?
Recommendations» Regulation 1169/2011 is a step forward and over time will benefit industry» However, it is crucial to have certainty on the specifics as soon as possible» A common understanding of the new rules by Regulators throughout the EU» A pragmatic approach to enforcement» An Irish Labelling Working Group with Regulators, Retailers, Manufacturers and SME s?
Conclusions» A regulation that is far from finished..» Many implementing measures» Many interpretation issues» Already 1 year into 3 year transition period» Uncertainty for companies» When in doubt. don t order packaging beyond December 2014!