Reduced requirements apply to food offered for sale without pre-packaging and to food packaged on site at the request of the consumer. In the EU, common food additives are given a three- or four-digit identification code, called an E number. Although it is common in the EU to identify food additives by their E number, in the US, additives must be referenced by their common name. „Sodium caseinate would be declared as such in the list of ingredients on a U.S. food label,“ says Culhane. „On an EU food label, it would be said `E469.`“ Annex III of EU food law contains additional mandatory labelling requirements for certain types or categories of food. The standard US label does not comply with EU labelling requirements. 13. December 2014, the new EU Regulation 1169/2011 enters into force and introduces new obligations and amendments to existing regulations.

The FIC Regulation establishes new horizontal labelling requirements and repeals Directive 2000/13/EC on labelling, Directive 90/496/EEC on nutrition labelling and Directive 2008/5/EC on warnings. The new food labelling rules apply to all food products supplied to final consumers (all companies involved in the production and catering of food and its online and offline marketing). According to the new Food Regulation, non-prepackaged foods should bear allergenic labelling. The origin of the main ingredients must now always be indicated if it does not correspond to the country of origin or declared place of provenance of the food. Where prepacked foodstuffs are placed on the market at a stage prior to sale or when they are supplied to Community processing organisations, this information should only appear on the commercial documents submitted. The name under which the product is sold, the date of minimum durability and the contact details of the manufacturer and packer shall be indicated on the outer packaging of the food. From 1 April 2020, new EU rules entered into force, obliging food businesses to label food with the country of origin or place of provenance of the primary ingredients. These requirements, set out in Commission Implementing Regulation (EU) 2018/775, apply alongside the existing rules of the EU Regulation (No 1169/2011) on food information (FIC). According to the new Regulation on the provision of food information to consumers (FIC), the origin of the main ingredients must be indicated if they differ from the origin of the food, in order not to mislead consumers and to harmonise the display of nutrition information on food. Labelling, presentation and advertising of foodstuffs This can be done either by indicating on the packaging where a main ingredient originates, e.g.

EU, third country or Member State, or by indicating that the main ingredient does not come from the country/place of provenance of the food. The presentation of this information must comply with the technical requirements of the FIC and the new regulations and must be displayed in the same field of vision as the indication of the country of origin of the product. This may mean that the packaging becomes quite cluttered. Food businesses may choose to remove or amend origin or provenance claims where they have been made voluntarily, where the inclusion of the new information compromises the aesthetics of the packaging or the commercial benefits of including indications of origin. Under EU and/or national legislation, certain foods may also have to include specific warnings about, for example, ingredients that are not recommended for consumption by children (e.g. caffeine). Other requirements exist with regard to additives, flavourings, food enzymes, alcoholic beverages and sweeteners. The label shall be drawn up in a language understandable to the final consumer. This is usually the official language of the country in which it is marketed. Foods containing meat are subject to special requirements. There are conditions for the use of the meat grade name in the labelling of foods containing meat as an ingredient.

Before the name is authorised, maximum limits shall be set for the fat and connective tissue content of products. The layout includes a minimum font size for mandatory information, a standard allergen presentation and required nutritional information. „It provides clearer information on some important nutritional properties of processed foods – energy, fat, saturated fat, carbohydrates, sugar, protein and salt,“ the European Commission`s website says. The placing on the market of foodstuffs which comply with the legislation may be prohibited only in the case of non-harmonised national provisions justified on grounds such as the protection of public health, the protection of industrial and commercial property and the fight against fraud. According to Carol Culhane, president of International Food Focus Ltd, a business development company specializing in regulatory compliance services for the food industry, one method isn`t necessarily easier for consumers to digest: it all depends on where you grew up and what you`re used to. Detailed information on the new labelling requirements can be found in the GAIN report „How to comply with new EU food labelling rules“, in the GAIN report „New food labelling rules published in the EU“ and on the following websites: The new EU food law has highlighted three aspects of a food: food quality, safety and security. A company may have good quality controls, but the safety aspects of a food have some changes that are important. With some products, it may not be easy to determine if there is a main ingredient and can lead to a somewhat strange result. For example, more than 50% of the ingredients in a chicken and chorizo cake could be flour, making it a major ingredient, but chicken and chorizo can also be main ingredients. Other products may not have a main ingredient. For example, products such as multiple fruit juices and cereals cannot trigger the requirement due to the number of ingredients they contain and the fact that none of their ingredients are usually associated by the consumer with the name of the food.

With this in mind, it can be useful for food manufacturers to document the reasons for their decisions, especially if they are finely balanced.