Food Naming, Origin Labelling, Date/Lot Marking & Instructions
In an effort to maintain product transparency and correct representation, any food product should adopt a legal or otherwise customary name. If not possible then a descriptive name should be given.
Products legally manufactured under a name may be marketed accordingly but shall be accompanied by a description positioned nearby to inform consumers of the food's real nature. The name of the food cannot be replaced with a brand name, 'fancy' name or a name protected by intellectual property.
Name should only be excluded if the name of food produced in one EU country and marketed in another country has a meaning so different to cause misrepresentation and not sufficiently describe the product.
Any name should also be paired with a reference to the food's physical condition or specific treatment it has undergone such as powdered, freeze-dried, or concentrated. Certain food categories for example minced meat; require classification through measuring attributes relating to specific descriptive terms such as lean.
Products that imply they have been made of a whole piece of meat or fish but are constituted with multiple pieces must include the phrase 'formed meat' and 'formed fish'. Furthermore, preparations named or taking the appearance of joints, cuts or slices that include more than 5% of water in the final product must indicate the presence of added water.
In order to raise awareness of food sources, incoming EU labelling legislation goes further to say that origins should be known by the consumer. Either as the country or the place of provenance, it is mandatory to indicate this in certain situations:
- Namely, when information or presentation on pack would otherwise mislead consumers into thinking the origin is elsewhere
- Where the country of origin or the place of provenance is different to the primary ingredient.
- Current mandatory indication of beef (fresh, chilled or frozen) has been extended to include pig, sheep, goat and poultry amid consumer concerns. Expressions to be considered are the: place of birth, place of rearing and place of slaughter.
- Other than meat, the reviewed regulation requires the origin of milk, or dairy products using milk as an ingredient to also have origin indicated.
- Unprocessed foods, single ingredient products and ingredients that make up over 50% of food must also have origin indicated.
As per displaying mandatory information, text is subject to minimum font sizes and placement of indication is to be in the principal field of vision. Even where origin information is voluntary displayed to promote quality, the presentation should be compliant.
A food product's durability is to be displayed not only for quality purpose but also to identify when a product becomes unusable and potentially dangerous for consumption. The date indication is split into 2 categories:
- 'Best before'
- Appropriate for most foods were a period of time shows how long a food is expected to remain in optimal condition also known as 'shelf life'.
- 3 months or less – 'best before' followed by date in days and months.
- More than 3 months – 'best before' followed by date in month and year.
- More than 18 months – 'best before end' can be followed by just year.
- 'Use by'
- To be used for highly perishable food products where length of storage is directly related to food safety.
- The term 'use by' followed by the day and the month (year optional).
- Must be accompanied by storage conditions to be satisfied in order to achieve indicated life.
In relation to frozen meats, fish and preparations it is now required to display the time of first freezing in the format of 'Frozen on…'.
It is essential for any date markings to follow minimum font sizes. The term 'best before' or 'use by' must be seen in the principal field of vision and followed by either the actual date indication or an instruction on where to find it elsewhere on pack, for example, 'Best Before End: See Bottom of Jar'. Best practices to maximise clarity should be followed with a separate area displaying information at a high contrast. Where applicable, it is best to either spell out months in full or abbreviate for example, Jan/Aug, over using numbers to ease communication.
It is mandatory to display instructions for use especially when food is unusable without following them, requiring a task, such as cooking that must be completed before consumption. Likewise, it is important to display any storage instructions once package has been opened along with a time period for consumption.
Lot coding is another requirement that enables the tracing and tracking of packed foods along the supply chain and can be expressed individually or be incorporated into the date marking. Unnecessary emphasis should not be given to these markings and care should be taken to avoid confusion with numbers or letters representing origins and dates.
Information sourced from:
EU Regulation 1169/2011 (FIC)
Food Standards Agency – Clear Food Labelling Guide