General Food Labelling Review A UK Industry Perspective Structure and Scope of Food Labelling Legislation Eva Hurt Food

1. General Food Labelling ReviewA UK Industry PerspectiveStructure and Scope of Food Labelling LegislationEva HurtFood and Drink Federation17th July 2007

2. The Role of the Food Label • The label is the central communications tool of manufacturers with their consumers on • General Product and Food Safety information • Brand values • Promotions  Consumer understanding is key, in particular, to delivering the product and safety information

3. The Role of the Food Label • Industry believes the principal role of the label is basic information about nature and use of the product  Additions and changes to Labelling Regulations have instead led to a proliferation of requirements • Requirements stem from variety of legal texts • Often not easy to locate latest version of legislation • All agree: • Simpler labels would be more consumer friendly • Simpler labelling legislation would be more user friendly

4. Consumer Information Challenges • More complex supply and production • Wider range of more elaborated and sophisticated food products • Complex market networks and multilingual labels • Increasingly consumers “want to know”  How can labelling be improved for the benefit of all parties?

5. EU Food Labelling Review • Industry welcomes the proposed simplification • Industry welcomes the differentiation between “information designed to protect and that designed to inform consumers”  Legislative requirements for on-pack labelling should primarily be directed at the former • Industry agrees that a distinction has to be made between the provision of information and labelling of product • How apply prioritisation of information in practice?

6. Labelling Solutions - how to reduce the burden? • Simplify and clarify the scope of labelling legislation • Make the legislation easily accessible • Bring all horizontal requirements together in 1 text • Find a practical means to readily access specific vertical requirements.

7. Labelling Solutions – how to reduce the burden? • Remove completely requirements that duplicate information on the label, • e.g. “with sweeteners” when it will be labelled in ingredients • warning about phenylalanine when aspartame declared in the ingredients • Consider removing items which do not convey useable or meaningful information to consumers, e.g. declaring use of packaging gas, irradiated ingredients, health mark

8. Labelling Solutions: How to reduce the burden? • Only require essentials to identify: • Name/nature of product • Net quantity • Ingredients (including allergen obligations) • Durability indication and storage instructions • How to prepare • Origin (as per current requirements) • Lot code • Contact details

9. Alternative Means of Information • Recognise that all other information currently provided may continue to be given voluntarily on or off label - and will often be provided due to • Consumer demand • Market trends • The means of off-label information should not be specified but be allowed to develop as technology permits, demand requires and as appropriate for optimum consumer information • It will have to meet general requirements of validity of commercial information

10. Key benefits Consumer benefits: • The majority of consumers will benefit from less cluttered key information on the product label • Minority interests can be catered for specifically by other means whereby consumers will be able to obtain targeted information and establish a dialogue with the producer (e.g. through leaflets, websites, carelines)

11. Key benefits Industry benefits • Legislation will be more user-friendly • Legislation will be more enforceable • Higher compliance will be achieved

12. Summary A Fresh Regulatory Approach • Reduce the on-pack mandatory requirements to a minimum • All other provisions should be voluntary • Additional information can be provided on the label or by alternative means