Food Labelling Workshop
‘Facts on FIC’ workshop, October 14th in the Kingsley Hotel, Cork, Ireland
On Tues 14th October I had the privilege of organising a food labelling workshop entitled ‘Facts on FIC’ in association with the famous Food Industry Training Unit at University College Cork (UCC). We were bowled over by the interest in the topic with over 90 delegates turning up at the Kingsley Hotel on the day.
UCC’s Director of Technology Transfer, Dr. Tim Roche opened the workshop and spoke of the importance of regulatory compliance in the Food industry not just as a means of staying in business but also with a view to innovating, entering and competing in new markets.
My job as chair for the first the first half of the program was made very easy by our panel of excellent speakers, which comprised of Maree Gallagher (Food Lawyer, MGA), Edmond O’Sullivan (Veterinary Inspector, Cork County Council) and Ita White (Food Safety & Quality Trainer/Consultant with Teagasc).
Maree gave an overview on FIC legislation and what has changed: e.g. Minimum font size, display of Allergen information, name of the food, some additions to durability date, country of origin labelling, mandatory nutrition labelling (in 2016) and emphasized most importantly that the Food Business Operator is responsible for the accuracy of all labelling on their premises.
Edmond spoke on origin labelling and highlighted the differences between ‘Origin’, ‘Country of Origin’ and ‘Place of Provenance’. Origin labelling is currently mandatory for beef, fish, honey, olive oil, fresh fruit and vegetables. After 1st April 2015, origin labelling will be mandatory for meat taken from the carcass of poultry, swine, sheep and goats.
Ita updated us on Nutritional Labelling requirements, both mandatory and voluntary under FIC. Among other key points she highlighted that vitamins may only be declared in foods if they are present in ‘significant amounts’ (≥15% of the daily reference intake per 100g/100ml of product) as listed in FIC, Annex XIII. You can no longer suggest a food has special characteristics when the same characteristic or nutrient is shared by all similar foods. Reference Intakes are replacing Guideline Daily Alowances. Ita also touched on the UK Traffic light labelling system which is currently under litigation proceedings.
After a well-earned coffee break Joanne Lorriman (Senior Environmental Health Officer (EHO), Cork) gave us an overview of what to expect when an EHO calls. She reminded us all that from 13th December 2014 foods placed on the market must comply with FIC Regulation 1169/2011. For prepacked food products the labelling has to be applied as stated in the regulation. However for non-prepacked foods Member States are allowed to adopt national measures on how allergen information can be provided. She spoke of the draft Irish Statutory Instrument (S.I.) on Allergens, which was pending and only published yesterday (S.I. No. 489 of 2014). In this S.I., allergen information must be written (verbal communication alone no longer enough) and presented or made available at the ‘point of presentation, the point of sale or the point of supply’. This SI has a wide scope affecting the presentation of allergen information in restaurants, hotels, canteens, schools, hospitals, food stores, markets and also covers food packed on site at the consumers request and packed for direct sale. The enforcement options are also outlined in the SI, they are similar to current enforcement (sampling of food, removal of suspect food) with the addition of inspection of a ‘relevant thing’ (pack or display label) or making copies or photographing of a ‘relevant thing’, a compliance notice.
The next speaker was Lucille O’Connor (FIC Project Co-ordinator, Musgrave Retail Partners). She told us that ‘any food producers, who have not supplied the correct information to Musgrave’s or their local store or whose labels are non compliant after 13th December will have their product taken of the shelves’. She emphasized the importance of understanding your own print lead times and to plan and book your label print runs now to ensure a smooth transition through the packaging changeover. Musgrave’s give a lot of support to their retail partners and have been very proactive in informing their suppliers (this was presentation no. 31 for her on this particular topic!!!).
I wrapped up the proceedings with a talk entitled ‘roadmap on how to get there’, in which I attempted to pull all the information of the day together and formulate a plan of action going forward.
To recap for those of you who weren’t there, or who fell asleep: first you need to know if your business needs to provide full labelling (i.e. all of the 12 mandatory particulars), or if it is exempt. To help you decide consider the following:
A) If you are a retailer who sells loose foods, food packed on site for direct sale to the consumer or packed at the request of the consumer then you are exempt from full labelling, only partial labelling required.
B) If you are an ingredient supplier who’s product label is not directly in contact with the customer then you need partial labelling and accompanying documentation with full labelling information so the retailer can fulfill his/her obligation when labelling on site.
C) If you are packing in one unit for sale in another unit then you have to comply with the regulation and provide full labelling on each prepacked food product.
Food business operators are responsible for the accurate labelling of all pre-packed food products in their store.
If your product needs full labelling to comply with the regulation then you need a plan of action: Here are some practical things you can do In-house:
1) Assign a person to manage FIC label review- compile SKU list, gather supplier information, check for information gaps
2) Prepare for the FIC deadline on 13th December by ensuring all your staff are aware of the 14 allergens. Start making an ingredient list of every product in your store and identify if any of the 14 allergens are present in the products.
3) Review labels against the 12 mandatory particulars outlined in the regulation
4) Remember there is a minimum font size necessary for all the 12 pieces of mandatory information. Nutrition labelling is not mandatory until Dec 2016, however, if you are making a nutrition or health claim or if you already have a nutrition label on your product it must be updated to FIC by Dec 2014.
5) Check with suppliers that information has been updated, request email updates
6) If supplying into multiples check their requirements and deadlines both in-store and online
7) Create updated label info for each product
8) Check print size and label design with labelling company
9) When repackaging- check lead time with printer/ labelling company
External Support is also available from:
1) Consultants providing Label Review Service
2) FSAI technical support,
3) Your local EHO
The feedback from the workshop was very positive with everyone voicing that they had either learned something new or that the talks had enforced information that was previously assumed.
A heartfelt thanks to all involved especially Mary McCarthy Buckley and her staff in the Food Industry Training Unit, UCC. Photographs below courtesy of David Waldron, UCC.
Food Information to Consumers EU Regulation 1169/2011
FSAI Nutrition & Health Claims 2014
S.I. No. 556 of 2014. European Union (Provision of Food Information to Consumers) Regulations 2014.
S.I No. 489 of 2014 Health (Provision of Food Allergen Information to consumers in respect of non-prepacked food) Regulations 2014.
FSAI Guidance on Allergen declaration for Non prepacked Food
Food Industry Training Unit Brochure