UK labelling regulations

With just over four months to go until the main elements of the Food Information to Consumers EU 1169/2011 Regulation (FIC) are due to come into effect in the UK, analysis of the industry’s journey toward compliance has revealed that larger brands are showing more visible progress than smaller brands.

In the second in a series of quarterly reports, GS1 UK commissioned a snapshot of progress by analysing a basket of 20 products including confectionery and flour based products. It was also apparent that confusion remains over what is required by some parts of the regulation.

The following trends were noted from the research:

·Two tiers of readiness are emerging – generally speaking larger brands have made considerable progress toward compliance. This is perhaps to be expected as large companies have more resources to assign to FIC, but also more product lines so may have to start earlier. This is in contrast to smaller brands (including imported products) where progress is not so visible; however, this is not to say work is not currently underway by smaller brands, just that it has not yet been completed.

·Nutrition information labelling exemptions are causing confusion – FIC makes nutrition information mandatory on food labels; previously this was only the case if a nutrition claim was made in the product marketing. Some aspects, such as the reordering of nutrients in the mandatory nutrition panel, appear to be fairly well known, but there are a number of exceptions where nutrition is not legally required by the FIC at all and these seem to be less well understood. Nutrition is not a mandatory requirement on unprocessed meat or produce (such as a box of fruit) for example, and if a product label is under a certain size exemptions may apply.

·There has been a shift to presenting ingredients as a single list – it was notable that the inclusion of compound ingredient declarations beneath the main ingredient lists, a style that was becoming the standard, was not in evidence. This might be a possible effect of the increased font size for mandatory information meaning space on a label is at a premium. This represents a more space-efficient way of presenting such information, and can reduce the space required by up to 50 per cent on more complicated products.

·Declaring voluntary information requires careful thought – there is a clear distinction in FIC between ‘back of pack’ nutrition (the mandatory information) and that repeated on the ‘front of pack’, which is voluntary. Some still wish to display nutritional information on the front of pack for marketing purposes, but the placement is important as it has to appear in what is referred to as the ‘principal field of vision’ – the part of the pack most likely to be seen at first glance by a consumer at the time of purchase. How a particular product is stacked on a shelf may impact the principal field of vision so voluntarily repeating nutrition information requires careful thought.

FIC also places an obligation on retailers to provide all the mandatory label information (excluding expiry dates) to potential customers through distance selling channels, such as websites. This means that brand owners need to present the label data and associated images in a format that retailers can easily integrate into the systems that populate their websites. At present we are seeing this process happening too slowly, and have concerns of a backlog emerging that may lead to businesses having to join lengthy processing queues and facing delays in making updated products available through the associated digital channels.

Gary Lynch, CEO of GS1 UK says: “There were encouraging signs from this survey, which revealed some general improvements on the findings from the last one undertaken in April. However, the larger brands have made far more visible progress than the smaller brands and we are concerned about possible bottlenecks at the printers toward the end of the year. We recommend all suppliers of food and drink products make FIC compliance across all channels a priority or they risk not being able to sell their products legally after 13 December.”

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