Presentation on theme: "General Food Labelling Review A UK Industry Perspective Clarity and Legibility Michael Hunt Food & Drink Federation (UK)"— Presentation transcript:
1General Food Labelling Review A UK Industry Perspective Clarity and Legibility Michael Hunt Food & Drink Federation (UK)
2The growing pressure on label space Classic tension between label space and amount of legally required informationLabelling Directive highly successful, clear and balancedSome key additions made such as for allergen ingredient labellingOthers of less obvious importanceAdditionally requirements from other legislationEnvironmental pressure to reduce packaging
3Development of UK food labelling requirements Up to 1930sBroad principles on safe food and preventing fraud.Specifics on labelling with:customary name or a registered trade markquantityLittle (voluntary) labelling on composition.Commodity standards on preserved milks.Range of pre-packaged foods wideningMore ingredients available
4Development of UK food labelling requirements 1943False labelling and advertising offence (nature, substance and quality)Minister of Food to make regulations on pre-packing, advertising and composition.During 1940sAbout 20 compositional standards introduced for a range of foods.Several commodity codes of practice were introduced that linking composition to product names of, e.g. soft drinks, drinking chocolate, fish pastes and spreads, canned soups, flour mixtures and vinegar.
5Development of UK food labelling requirements 1946Various terms defined (retail sale, pre-packed, label).Particular requirements for pre-packed foods included:Name and address of the packer or labeller (or registered trademark)Designation of single ingredient foodsFor compound foods, common or usual name (if any) of the food and designation of each ingredient in descending order of weightNeed not declare waterMinimum quantity markingRules for claims on vitamins and minerals.Some foods wholly or partly exempt.
6Development of UK food labelling requirements 1970 – Requirements significantly extended. Mainly:Many more terms definedProduct naming in more detailIngredient listing amplified: dried products, mixtures of fruit and vegetables, compound ingredients, and permitted food additives.A few generic descriptions allowed (e.g. vine fruits, fruit acids, emulsifying salts, edible oil or fat)More claims controls regarding energy, calorie, protein, vitamins, minerals, and slimming claims. Medicinal and restorative claims banned.Detailed provisions applied to ‘manner of marking’ legally required information: visibility, positioning, colour and letter height.
7Development of UK food labelling requirements 1980 – Labelling Directive 79/112/EEC implemented, including:Product naming refined (trade marks, brand names and fancy names no longer substitutes)Addition of: date marking, storage conditions, conditions of use, origin labelling (if needed), instructions for useIngredient listing more detailed. Added water to be declaredPartial exemptions: small packages; food for direct sale; food sold loose‘Manner of marking’ provisions less onerous.Definitions of ‘additive’ and ‘processing aid’Category names for permitted additives plus E numbers or names.Conditions applied to use of certain words and descriptions e.g. butter, cream, dietary, flavour, milk, alcohol-free etc.Some exemptions for foods with EU vertical directives.
8Development of UK food labelling requirements 1984 – Further EC provisions introduced on:Indications of physical condition or treatment.Restrictions on claims on Parnuts foods, food for babies and young children, and on diabetic, slimming, medicinal, protein, vitamin, mineral, polyunsaturates, cholesterol and energy claims.1994Nutrition labelling (90/496/EEC). Application voluntary unless nutrition claim made but “commercially required”
9Development of UK food labelling requirements – more EU provisions added, including:QUIDAdditional labelling for:foods containing sweetenerspolyols consumption warningfoods packaged in certain gasesglycyrrhizinic acid in confectionery and drinkscaffeine in high caffeine drinksnon-heat treatment of raw milk.More detailed ingredient listing (removal of 25% rule)Allergen labellingDefinition of “meat”GMO labellingSome requirements from vertical legislation remain
10Clarity and Legibility Newer factorsMultilingual labelling:now firmly-established in EU market.not always optionaleconomic advantagecosts of not being able to do itLegal requirement to minimise packagingAny more or less information requirements from EU review?Needprinciples on priority information to be includedan agreed approach on visibility and clarity
11FSA Guidance on Clear Labelling Key aspectsGrouping of informationPrint size and clarityIncreasing printable area2005 survey of complianceMany products (87%) not complying with guidance, but with littleor no effect on clarityConfirms clarity has multi-factorial basis and its assessment is somewhat subjective.Indicates that detailed legal specification is not appropriate.Suggests that wide agreement on guidance is appropriate, to enhance consistency of approach.
12Consumer Food Labelling Requirements 2006 FSA research on food labelling requirementsTo determine:what information consumers want and need to seewhat should be provided on packswhat could be delivered some other wayResultsHigh priority information, to dominate front of pack was chiefly:Brand name or brand identifier (product recognition top priority)Name of foodNet quantityDatemarkSome form of illustration
13Consumer Food Labelling Requirements “Overall the findings indicate that there will be a benefit in encouraging industry to conform to certain principles in grouping and separating information while retaining their own design styles, and taking some specific information off pack.”
14Key issues for clarity and legibility Presentation of statutory information on pack to achieve easy visibility;Font size and colour/contrast to achieve clear legibility;
15Going Forward This is a collaborative issue: Legislators: To preserve some information exemption for small and irregularly shaped packs etcto adopt principles to protect the label from all but priority information requirementsNot to over-specify legibility criteriaIndustry with other stakeholders to consider EU level consensus guidance on key factors in label legibility, to support the legal principles of ‘easily visible’ and ‘clearly legible’All parties to bear in mind the cost/benefit implications