BY
Elisa Savietto
IN
Labelling obligation for food: This information must appear on the packagingLabelling obligation for food: This information must appear on the packaging
- The EU Food Information Regulation has been in force since 2014.
- Food companies are responsible for product labelling.
- The product name, best-before date, filling quantity, manufacturer's address and the listing of nutritional values, ingredients and allergens are obligatory for all foods.
- For some foods, further labelling is mandatory: for example, information on origin, warnings and alcohol content.
Knowing what's in it: that's what product information on labels and packaging is all about. Much of the information on food products is now mandatory. Some information, however, is only required for certain products. In this article we explain what information food labels and packaging must contain according to the law.
Mandatory food labelling: the basics
Within the EU, the Food Information Regulation (LMIV) has been in force since 2014. It contains uniform standards for the minimum information that must be provided on food packaging. The aim behind this is to ensure better health protection for consumers. Therefore, even the basic information required is quite extensive.
Definition: Food packaging
Packaging for food belongs to the group of food contact materials - this group includes all items made of different materials with which the food comes into contact during production, packaging, storage and preparation. There are clear legal regulations on ingredients and constituents that may endanger health and affect smell and taste. Likewise, the approved items made of plastic, regenerated cellulose and other materials are officially monitored.
Food designation
The specific designation of the foodstuff contained must be noted on all printed food packaging. Unlike product names, which are usually invented for sales reasons, food names clearly indicate what a product is exactly.
Example: A product bears the name "Banana Dream". Without further information, however, it remains unclear whether it is a fruit puree, a soft drink or something else entirely. Only the product name, such as "banana-flavoured milk drink made from skimmed milk", can tell.
The exact name depends on the type of product. For some types of products there are statutory regulations (for example for fruit juices, honey or milk). Deviations from these are not permitted. The GMP guidelines must also be observed.
In the absence of regulations, there are two options:
- On the one hand, the manufacturer can use the customary name. This means a designation that is understood by the consumers of the country in which the product is sold without further explanation.
- On the other hand, a self-selected description of the product is permissible, which describes the food or its use. The condition is that the description enables consumers to identify the exact nature of the food and to distinguish it from products with which it might be confused.
List of ingredients
With the list of ingredients, manufacturers inform consumers how a product is composed: ingredients, additives, flavours and enzymes. The list of ingredients is only required for foods that consist of more than one ingredient. The individual ingredients are listed in descending order, with the ingredient with the highest percentage by weight listed first.
Ingredients which themselves consist of ingredients (for example the salami of a frozen pizza) must be broken down into their individual components. It is permissible both to include the individual components by weight in the list of all ingredients and to name the compound ingredient and list its components immediately below in brackets.
The breakdown is not required for compound ingredients if they make up less than two percent of the product and the composition is not legally defined. Here, a reference to the ingredient (e.g. "chocolate" or "jam") is sufficient. The exception to the rule: allergens must always be labelled.
Additives such as colourings, emulsifiers or preservatives must be noted with their class name, their special designation or, if applicable, their E-number - such as "thickener E 412". Additives and enzymes that are not allergens and no longer have a technological effect in the end product or have been removed are exempt from the labelling requirement.
Allergen labelling
Information on allergens is an important criterion for allergy sufferers and people with food intolerances when buying food. In order to make it clear whether a food is safe, the 14 main allergens must be listed on food packaging - regardless of whether they are contained as an ingredient or only in traces. This concerns:
- Cereals containing gluten (with mention of the ingredient: wheat, rye, etc.)
- Nuts (with mention of the ingredient: almonds, hazelnuts, etc.)
- Peanuts and sesame seeds
- Milk(including lactose)
- Crustaceans, fish and molluscs
- Mustard and celery
- Soya beans and lupins
- Eggs
- Sulphur dioxide and sulphites (in concentrations above 10 mg/kg or 10 mg/l expressed as SO2).
Allergens must be specially highlighted (underlined, bold or coloured). And even if no list of ingredients is required for a food, allergens must be indicated. Labelling is not required for foods whose name clearly indicates the allergen, such as peanuts.
Best before date or use by date
The best-before date indicates the date up to which the manufacturer guarantees that a food (unopened and stored correctly) will retain its specific properties such as smell, taste and nutrients.
The date must be referred to with the phrases "best before" or "best before end". The exact date format depends on how long the food has a shelf life:
- less than three months: day and month
- three to 18 months: month and year
- more than 18 months: year only
The use-by date must be indicated for perishable foodstuffs that pose a health risk after only a short period of time. The wording "to be consumed by" refers to the last day on which the food may be consumed. The day and month must be indicated.
The exact location of the best-before and use-by dates on the printed packaging is not regulated by law. If the date is printed in a different place than the information formula, attention must be drawn to this - for example by "see lid".
Nutritional values
The energy content (often also called calorific value) is mandatory on all food packaging. In Germany, this is usually given in two units: in kilojoules (kJ) and in kilocalories (kcal). However, only the kilojoule unit is mandatory. The unit of the kilocalorie is outdated, but may still be stated additionally.
Likewise, all food packaging must contain the quantities of the following six nutrients (per 100 grams or 100 millilitres):
- Fat
- saturated fatty acids
- Carbohydrates
- Sugar
- Protein
- Salt
Net quantity
Packaging comes in various shapes and sizes. Many of them are also opaque. It is therefore often difficult for consumers to guess how much content is actually contained in a customised package. Therefore, the net quantity must be indicated on all food packaging - depending on the food as weight (gram/kilogram) or volume (millilitre/litre).
- Goods that weigh less than five grams are exempt from the labelling requirement.
- In the case of concentrated products (e.g. for soups and sauces), the number of litres/millilitre of the prepared product must be indicated.
- For some foodstuffs, the net quantity can be replaced by a piece count, for example for various types of fruit and vegetables.
Name and address of the food business
In order to be able to trace a food in case of complaints, the name and address of the food business must be indicated on all primary or secondary packaging.
Further mandatory information for certain foods
Type your textFor certain foods, there are additional labelling requirements that go beyond the minimum information mentioned above:
Information on storage or use
In the case of foods whose shelf life depends on certain conditions of storage or use, appropriate information must be given on the packaging.
An example of this is foods such as dairy products that must be stored at certain temperatures. In this case, the labelling may read as follows: "unopened and refrigerated at + 8 °C at least until".
Freezing date
Packaging for meat and meat products as well as for unprocessed fishery products must be marked with a freezing date if the goods are frozen. In the case of multiple freezing, the date of the first freezing must be indicated.
Instructions for use
Instructions for use are obligatory for ready-to-serve meals such as frozen pizzas and must not be presented only pictorially. This means that the instructions must always be given verbatim.
Indications of origin
In addition to the name and address of the producer, a number of food packages must provide information on the origin of the food.
- For packaged, unprocessed meat (beef, pork, poultry, sheep and goat), it must be stated in which countries the animals were raised or slaughtered - for beef also the country of birth.
- For eggs, information on origin, husbandry and freshness is mandatory.
- For most fresh fruit and vegetables, the country of origin must be stated.
- For honey, it must be stated where the mixture comes from: from EU countries, from non-EU countries or from both, i.e. both EU and non-EU countries.
- For fresh and processed fish, as well as for crustaceans and molluscs, the catch area and, if applicable, the production method must be indicated.
Identity mark for animal products
For animal products, an identity mark is necessary to enable the surveillance authorities to trace the product back to the producer.
Botanical origin for vegetable oils
If a food contains vegetable oils or fats, the botanical origin must be mentioned in the list of ingredients. This means that the plant species from which the oil or fat was obtained must be named. Example: "rapeseed oil" or "vegetable fat (coconut)".
Alcohol content
In the case of beverages containing more than 1.2 per cent alcohol by volume, the alcohol content must be indicated - in the immediate vicinity of the product name and the filling quantity.
Information on imitations
When using imitation foods (e.g. surimi, analogue cheese, glutinous meat), the substitute used must be indicated in the immediate vicinity of the product name. The font size must be at least 75 percent of the font size of the product name.
Warnings
Some foods contain substances that may be hazardous to health, for example in the case of excessive consumption or for certain groups of people. Labelling is therefore mandatory for:
- Azo dyes
- increased caffeine content
- glycyrrhizic acid and its ammonium salts
- polyhydric alcohols
- inedible sausage casings
- Phytosterols
