The labeling of a food product has a strategic and fundamentally important role towards the consumer, as it not only makes him aware and informed about the purchase, allowing him to choose the product according to his needs, but also because it is excellent marketing tool for the enterprise.
By labeling we mean “the set of mentions, indications, trademarks or trade marks, images or symbols which refer to the food product and which appear directly on the packaging or on a label affixed to it or on the closure or on signs, rings or bands tied to the product itself, or on the documents accompanying the food product”.
All the ingredients that make up the finished product, including additives, flavors and food enzymes must be present and legible on every food label. Each ingredient must follow specific rules: in fact, if for some it is only possible to indicate the category to which they belong (e.g. spices), for the others it is necessary to provide more detailed indications.
From this we can deduce how important the presence of clear and understandable labels is for consumers, in order above all to avoid the purchase of products that are not suitable for their nutritional needs, as well as to more easily identify the best products on the market.
The European Union regulated the matter for the first time with the enactment of Directive 79/112/EEC of 18 December 1978, relating to the “approximation of the laws of the Member States concerning the labeling and presentation of food products intended for the consumer, as well as the related advertising”.
In Italy, Legislative Decree 109/92 gives the general provisions that apply to all pre-packaged, loose and pre-wrapped foods that are intended for sale in Italy. To this general rule are added other specific ones for certain types of food products (oil, wine, honey, cocoa, beef, etc.).
Following a complex regulatory process, on 25 October 2011, the European Parliament and the Council adopted EU Regulation 1169/2011 “relating to the provision of food information to consumers”. Nonetheless, the Italian legislator, instead of issuing a new rule, continued to make changes to Legislative Decree 109/1992, preserving its value as a framework law, with reference to the labeling of food products.
EU Regulation 1169/2011 applies to all food business operators (FBOs) and at all stages of the food chain, when the food is destined for the final consumer and facilitates the achievement of the 4 main EU objectives:
ensure a high degree of consumer protection;
ensure the free movement of safe and wholesome food;
ensure information’s right regards food consumption;
allow consumers to make informed choices about food and avoid practices that could mislead them.
Some information must be reported on food product labels, specifically:
name of the food;
list and quantity of ingredients;
Allergens or substances that cause intolerances;
net amount of food;
minimum retention period or expiry date;
particular storage conditions and/or conditions of use;
name or business name of the FBO responsible for the product and its safety;
country of origin or place of provenance, when applicable;
instructions for use, in cases where they are necessary for an adequate use of the food;
actual alcoholic strength by volume, for beverages that contain a quantity of alcohol by volume greater than 1.2%;
nutrition declaration.
Now let’s see specifically the meaning of these terms:
The name of the food is the product name under which a product is marketed, it is the most important mandatory indication and must always be present. The denomination of the food does not correspond to the company brand nor to the trade name.
Article 17 of the Regulation specifies that the name of the food corresponds to its legal name. Failing this, the name of the food is its usual name; where a usual name does not exist or is not used, a descriptive name is given. Furthermore, with the name of the food, an indication relating to the physical state in which the food product is found or to the specific treatment it has undergone is offered, if the omission of this information could lead to confusion in the buyer. An exception is for products which, by definition or custom, are marketed with a name that recalls the particular treatment to which they are subjected, and which therefore do not require the indication of the treatment.
The list and quantity of ingredients (called QUID) corresponds to the declaration of the quantity of the latter used to make the food product.
The list of ingredients contains all the ingredients present in the product, in order from the most abundant to the lowest percentage.
The indication of the quantity of an ingredient or a category of ingredients is required in cases where:
– The ingredient appears in the product name or is associated by the consumer with the product name. If more than one characterizing ingredient appears in the product name, the % for each of them must be specified. Let’s take as an example the “Tiramisu with coffee cream”, in this case it will be necessary to specify both the cream % and the coffee %.
-The % of the ingredient is essential to characterize a certain food product and to distinguish it from other foods with which it can be confused, due to its denomination or appearance.
– When the ingredient is listed on the label (even if it does not appear in the product name, such as biscuits with chocolate chips, the % in chocolate must be specified) or images are shown that depict only a part of the product, perhaps the most valuable (in this case it is necessary to indicate the QUID for the parts of the product depicted). The fact remains that the provision does not apply if the image illustrates a suggestion of how to serve the product at the table or if it represents all the ingredients of the product without highlighting one in particular.
Some food products are exempt from the ingredients list declaration, in this case the QUID must be indicated in the product name or immediately next to it. For food products for which an ingredient list is required, the QUID can be reported both in the product name and in the ingredients list.
As far as allergens are concerned, the presence of these substances in foods must always be declared on the label, both in the case of pre-packed and non-pre-packed products; this reporting is essential in order to protect the health of consumers, and failure to apply this information will lead to companies withdrawing the product in question from the market.
The list of substances that cause allergies or intolerances is indicated in regulation (EU) 1169/2011, there are 14 of them but I will mention only a few as an example:
Cereals containing gluten and products thereof, except:
– wheat-based glucose syrups, including dextrose;
– wheat-based maltodextrins;
– barley-based glucose syrups;
– cereals used for the manufacture of alcoholic distillates, including ethyl alcohol of agricultural origin.
Shellfish and shellfish products.
Eggs and egg products.
Fish and fishery products, except:
– fish gelatin used as a support for vitamin or carotenoid preparations;
– gelatin or isinglass used as a fining agent in beer and wine.
Milk and milk-based products (including lactose), except:
– whey used for the manufacture of alcoholic distillates, including ethyl alcohol of agricultural origin;
Nuts and products thereof, except for nuts used for making alcoholic distillates, including ethyl alcohol of agricultural origin.
Celery and celery products.
Sulfur dioxide and sulphites in concentrations higher than 10 mg/kg or 10 mg/litre in terms of total SO2 to be calculated for the products as proposed ready for consumption or reconstituted according to the manufacturers’ instructions.
Shellfish and shellfish products.
These substances must be highlighted with a distinctive character (bold, capital letters, etc.) compared to the characters used for the other ingredients. It is up to the OSA to choose the most appropriate way for representation, globally evaluating the packaging in question and choosing an appropriate highlighting method.
The minimum durability term (TMC) is the date until which the food product retains its specific properties, clearly under suitable storage conditions. Its determination is up to the producer or packager (for imported products it is up to the first seller established in the European Union). The TMC must be indicated with the words “best before”, if the date indicates the day, month and year, or “best before end” (for stable, not very perishable products); the expiry date, preceded by “best before” refers to easily perishable products, which should not be consumed after that date. These expressions are followed by the date or by an indication of the point on the package where it appears.
The indication of the country of origin or place of provenance is mandatory:
1) in the event that the omission of this indication could mislead the consumer as to the real country of origin or place of provenance of the food, in particular if the information accompanying the food or contained in the label taken together they could otherwise suggest that the food has a different country of origin or place of provenance;
2) for pork, sheep, goat and poultry meat;
3) when the country of origin or place of provenance is indicated and it is not the same as its primary ingredient: the same is to be indicated or to be indicated different from that of the food.
“country of origin: country in which the last substantial processing or working took place”.
A commodity whose production has been contributed by two or more countries,
it originates in the country in which the last substantial, economically justified processing or working took place in an undertaking equipped for this purpose, which ended with the
manufacture of a new product or has represented an important phase of the manufacturing process.
The actual alcoholic strength by volume is a mandatory indication on the labeling of beverages containing more than 1.2% alcohol by volume (wine, beer, spirits, etc.). In food products other than beverages, the alcoholic strength by volume must not be mentioned, although alcohol must be indicated in the list of ingredients (for example, in confectionery).
The alcoholic strength must be indicated in the visual field where the denomination of the drink and the net quantity also appear.
The nutritional declaration includes the following mandatory indications: Energy, Fats, of which saturated fatty acids, Carbohydrates, of which sugars, Proteins, Salt.
In addition, a statement indicating that the salt content is due solely to naturally occurring sodium may appear, where appropriate, immediately adjacent to the nutrition declaration.
The mandatory information is therefore seven in all and the last one is salt, not sodium as required in the previous regulations. This simple rule makes it possible to immediately verify the correctness of the nutritional indications with respect to the methods provided for by the previous regulation.
The information must all be presented in the same visual field, in a tubular or, in the absence of space, linear format, furthermore each information must be reported in a clear and visible format.
It is also possible to insert additional optional information on the label, which are: monounsaturated fatty acids, polyunsaturated fatty acids, polyols, starch, fibres, mineral salts or vitamins.
The energy value and the quantities of nutrients:
refer to the food as it is sold;
they are expressed according to the units of measurement indicated in the Regulation;
they are expressed per 100 g or per 100 ml of the product in question.
In addition to the form, the values can be expressed as percentages of the reference intakes and accompanied by the additional statement ‘Reference intakes of an average adult’.
The indication is mandatory on all pre-packed foods (packaged and intended for the consumer). Therefore, for those not pre-packed, the nutritional declaration is optional and can be limited to the energy value alone accompanied by the amount of fat, saturated fatty acids, sugars and salt.
However, there are cases of exemption, specified in the Regulations. The nutritional indication is not mandatory:
in the case of packaging or containers the largest surface of which measures less than 10 cm2;
for foods listed in Annex V;
for beverages with an alcohol content of more than 1.2% by volume. In this case, if it is decided to report the nutritional declaration, it can be limited to the energy value only.
Nutritional Claims
Claims are defined as “any message or representation, not mandatory, based on Community or national legislation, including figurative, graphical or symbolic representations in any form, which affirms, suggests or implies that a food has particular characteristics”. There are two types of indications: Nutritional (if the indication concerns some particular nutritional/beneficial characteristics of the food) e.g. “-40% sugar”; On health (if the claim concerns the existence of a relationship between the food in question and health).
EU Reg. 1924/2006 establishes that only claims approved by the European Commission (and even earlier by EFSA) can be used and must be based on scientific data. Therefore, the producer who wants to indicate particular characteristics of his product in the packaging can only use the claims admitted by the Commission; alternatively, it can propose to the Commission itself to authorize its own claim that complies with the general requirements.
Flabel project
The FLABEL project (“Food labeling to advance better education for life”) is the EU-funded project that aims to provide updates on food labeling, it is also the first EU-funded research project on labelling.
The project will investigate the effects of labeling on consumers, to try to better understand how it affects our purchasing choices. The nutritional information on food labels is already available on most of the food products we buy, even if the effect of this information on consumers is not clearly known to date.
The product categories examined were: 1) sweet biscuits, 2) breakfast cereals, 3) pre-packaged frozen ready meals, 4) fizzy soft drinks, and 5) yogurt.
The first results obtained from the project were that:
Nutritional information is widely present in the five product categories. On average, 85% of the products evaluated contain the nutritional information on the back of the package.
Sweden and the Netherlands are the only countries where there are logos with health messages such as Healty choice clover.
Furthermore:
– Less than a third of consumers say they have looked for the nutritional information on the packaging.
– More than 60% of respondents looked at the front of the package without therefore seeing the back, while less than 15% look at other parts. It follows that since the nutritional information is predominantly on the back of the packs, they go unnoticed by most consumers.
-On average, European consumers spend around 35 seconds handling individual products.
The mission is to find a balance between simple and clear information, but at the same time complete from a nutritional point of view, which represents a challenge for the researchers involved in the project, as well as the creation of a set of guidelines on best practices for nutrition labelling.