United Kingdom food labelling regulations

The law in the UK on food labelling is multifaceted and is spread over many reforms and parliamentary acts, making the subject complex. It must comply with the relevant rules in the European Union, for which the main law relating to food labelling is Regulation (EU) 1169/2011, which is implemented in the UK in the Food Information Regulations 2014,[1] the Food Information (Wales) Regulations 2014,[2] the Food Information (Scotland) Regulations 2014[3] and the Food Information Regulations (Northern Ireland) 2014.[4]

General rules

There are general rules applying to any food product:

• Name – It must inform the customer the nature of the product. It may also be necessary to attach a description to the product name. However, there are certain generic names which must be only used for their conventional uses. Muesli, Coffee, and prawns are among those exceptions.
• Ingredients – All ingredients of the food must be stated under the heading 'Ingredients' and must be stated in descending order of weight when present at more than 2% in the product. Ingredients making up less than two percent may be declared in any order at the end of the declaration. Moreover, certain ingredients, such as preservatives, must be identified as such by the label 'Preservatives', a specific name, e.g. "sodium nitrite", and the corresponding European registration number colloquially known as an "E number", e.g. "E250". When ingredients are themselves made of a number of sub-ingredients (e.g., mayonnaise), these must be declared as well in the ingredient declaration. If ingredients or additives contain one of the listed 14 EU allergens, these must be explicitly named in the list. For example: 'Preservative: E220 (Sulphites)'.
• Nutritional Information– Although it is not a legal requirement to declare Nutritional information on the product, if the manufacturer makes claims that the product is 'Low in Sugar', it must be supported with nutritional information (normally in tabulated form). However, as a rule, it is recommended to declare nutritional information as consumers, more than ever, are investigating this information before making a purchase. Moreover, there are two European nutritional labelling standards which must be adhered to if nutritional information is shown.
• Medicinal or Nutritional Claims – Medicinal and Nutritional claims are tightly regulated. Some are only allowed under certain conditions, while others are not authorized at all. For example, presenting claims the food product can treat, prevent, cure diseases or other 'adverse conditions' are prohibited. While claiming the food is reduced in fat or rich in vitamins require the food to meet compulsory standards and grades. In addition, the terms must be used in a form specified in regulations.
• Date Tagging – There are two types of date tagging:
  • Use by Date – 'Use by date' must be followed by a day and/or month which the product must be consumed by. This is to be applied on perishable foods that usually would be kept cold: fish, meat, dairy products, and 'ready to eat' salads.
  • Best Before Date – 'Best before date is used as an indicator of when the product will begin to degrade from optimal quality; this includes when the food becomes stale, begins to taste 'off' or decays, rots, or goes mouldy. There are also regulations on which type of best before date must be applied:
    • Best before + Day for foods with a shelf life of up to 3 months.
    • Best before end (BBE)[5] + Month for foods with more than a 3-month shelf life.
    • Best before end (BBE) + Year for food with more than an 18-month shelf life.
• Storage Conditions – If there are any particular storage conditions for the product to maintain its shelf life, these must be pointed out. However, as a rule, it is recommended to always describe the necessary storage conditions for a food product.
• Business Name and Address – In addition to the business name and address, it is necessary to indicate the manufacturer or packager if independent to the main business and the seller is established within the European Union.
• Place of Origin – The food is required to specify its place of origin, especially if the name or trademark is misleading. An example of this is if the product is called 'English Brie Cheese' when it is produced in France.
• Instruction for Use – This is only necessary if it is not obvious how to use or prepare the product, in which case the consumer's own initiative must be used.
• Presentation – The label must be legible and easy to read. Also, it must be written in English but, the manufacturer may also include other languages.
• Batch identifier, such as Lot Mark or Batch Code – It must be possible to identify individual batches with a lot mark or batch code. The code must be prefixed with the letter 'L' if it can not be distinguish from other codes however, the date mark can be used as a lot mark. Manufacturers must bear in mind that the smaller the size of a batch, the smaller financial consequences in the case of a product recall.
• Sectioning – All of the following must be in the same field of vision:
  • Product name
  • Date mark
  • Estimated net weight or quantity
  • Alcohol strength (if applicable).
• Standard specification - Indicate the level of the standard compliances which the product are manufactured and packaging are completed against and the specification limits if the standard is not publicly available, especially for those of:
  • Microbial limits
  • Heavy metal limits
  • The limits of pesticide residuals
  • The limits of preservatives, artificial flavouring and colouring, etc.
• Food additives - The items should be presented by their approved names (i.e. domestically), functional classes, and numbers of International Numbering System (INS) or equivalent.[6]

• Allergens - Certain common allergens must be declared explicitly in the ingredient declaration and a summary list of allergens may be added nearby for added clarity for the consumer. These include allergens present in the actual recipe's ingredients, but also those from additives and processing aids when residues may be present in the product. There are fourteen sources of allergens that need to be mentioned when they or their derivatives are present in a product:[7]
  • Celery
  • Cereals containing gluten
  • Crustaceans
  • Eggs
  • Fish
  • Lupin
  • Milk (including lactose)
  • Molluscs
  • Mustard
  • Nuts (specifically: almonds, Brazil nuts, cashews, hazelnuts, macadamias, pecans, pistachios and walnuts)
  • Peanuts
  • Sesame seeds
  • Soybeans
  • Sulphur dioxide and sulphites

See also

Acceptable daily intake Animal welfare Genetically modified food controversies Fair Packaging and Labeling Act (US) Federal Food, Drug, and Cosmetic Act Feed additive Food additives Food allergy

Food irradiation Food labelling Food safety Health claims on food labels Identifier Mandatory country-of-origin labeling of food sold in the United States The Non-GMO Project Nutrition facts label Olericulture

Packaging and labeling Pomology Produce Regulation of the release of genetic modified organisms Serial number Track and trace Viticulture

References

1. Food Information Regulations 2014.
2. The Food Information (Wales) Regulations 2014.
3. The Food Information (Scotland) Regulations 2014.
4. The Food Information Regulations (Northern Ireland) 2014.
5. "Tesco customer in a pickle over labelling". BBC. 25 June 2019.
6. The Government of the Hong Kong Special Administrative Region, Centre for Food Safety. "Labelling Guidelines on Food Allergens, Food Additives And Date Format". Retrieved 2 April 2009.
7. "Guidance on Allergen and Miscellaneous Labelling Provisions" (PDF). Food Standards Agency.

External links and further reading

• Labelling notes from the UK Food Standards Agency
• Official EU Food Law texts and guidelines
• "Labels and Other “Krafty” Stuff"