© IGD 2012

Industry Nutrition Strategy Group February 2012

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Introduction to food labelling

What is the purpose of food labelling?• Provide consumers with information about their food, helping them to make

informed decisions about which food to buy• It is important that this information is accurate and not misleading

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Introduction to food labelling (continued)

Who is responsible for food labelling in the UK?• The responsibility for food labelling legislation and policy in the UK is split across

government departments:– The Department for Environment, Food and Rural Affairs (DEFRA) is

responsible for labelling legislation in England that is principally non-safety, and for the coordination of labelling policy across Government

– The Food Standards Agency (FSA) is responsible for labelling and standards that are principally safety-based

– The Department of Health is responsible for nutrition labelling policy in England

Responsibility for food labelling varies across UK regions:• For Scotland and Northern Ireland, all domestic labelling and standards legislation

is the responsibility of the FSA• In Wales responsibility for general labelling requirements rests with the FSA and

responsibility for nutrition labelling lies with the Welsh Assembly Government

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Labelling legislationFood labelling is subject to strict requirements set out in European legislation. To comply with legislation, basic labelling provisions for pre-packaged foods must include:•The name of the food (legal or customary name not the brand name)•A list of ingredients•Quantitative declaration of ingredients (QUID) may be required if the ingredient used is mentioned in the product name or emphasised by product information e.g ‘chicken’ in chicken pie•The appropriate date mark•Any special storage conditions, conditions of use or preparation instructions•The name or business name and an address or registered office of either or both of –

(i) the manufacturer or packer, or(ii) a seller established within the European Community

•Particulars of the place of origin or provenance of the food if failure to give these might mislead a purchaser to a material degree as to the true origin or provenance of the food•The weight or volume of the food

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Labelling legislation (continued)

Ingredient list

STORE IN A COOL DRY PLACE

Made in the UK by The Manufacturer, Customer Services Department, FREEPOST ABC, Postcode AB1 1AB

Storage conditions

Name and address of manufacturer

500g e

Best before: 12 Feb 2011

Wheatmeal biscuitsIngredients: Wheat flour (54%), Palm Oil, Wholemeal Wheat Flour (16%), Sugar, Partially Inverted Sugar Syrup, Raising Agents (Sodium Bicarbonate, Tartaric Acid, Malic Acid), Salt, Dried Skimmed Milk

Name of food

Weight of food

QUIDDate mark

Basic requirements for a food label:

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Labelling legislation (continued)Nutrition labelling

• The EU Regulation published in October 2011 on the provision of food information to consumers (Food Information Regulation) is mandatory and pre-packed products already providing nutrition and ingredient information will need to implement the following changes.

– All packs with an area >25cm2 will require nutrition information

• Where nutrition information is provided it must comply with the regulation and shall include: energy, total fat, saturates, carbohydrate, sugars, protein and salt

• Previously nutrition information was provided as either:i) energy, protein, carbohydrates and fat, (known as a 'Group 1' or 'Big 4' declaration) or

ii) energy, protein, carbohydrates, sugars, fat, saturates, fibre and sodium (known as a 'Group 2', 'Big 4 + little 4' or '4 + 4' declaration)

The transition period for implementing the new labelling format must be complete by December 2014

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Ingredients list

Current legislation requires pre-packed food to be labelled with a list of ingredients

Order of Ingredients• Ingredients are listed in descending order by weight (with the ingredient present

in greatest quantity first), as determined at the time they were used in the preparation of the food

Quantity of ingredients • If an ingredient is mentioned in the name of the food (such as ‘chicken’ in chicken

pie), or is emphasised on the label in words (e.g. ‘made with real cream’) or pictures, or is usually associated with the food (as lamb is with shepherd’s pie), the amount contained in the food will be given as a percentage. This should appear either next to the name of the food product, or in the list of ingredients at the relevant point

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Ingredients list (continued)

Additives• An additive will be listed by the principal function it serves (e.g. emulsifier),

followed by its name or E number• Where an additive has been given an E number, this means that it has passed

safety tests and has been approved for use in the UK and in the rest of Europe. This includes substances which occur naturally in foods and are used as additives.

Compound ingredients • Where an ingredient is made up of several other ingredients, all the individual

ingredients will be given in the ingredients list either instead of, or in addition to, the name of the compound food

Foods that do not need to provide a list of ingredients• Single ingredient foods such, as butter and flour, do not need to give a list of

ingredients, nor do alcoholic drinks (above 1.2% vol.)

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Ingredients list (continued)

Quantity declaration (QUID)

Compound ingredient

Ingredients Pork (70%), Water, Rusk (Wheat Flour, Salt, Raising Agent: Ammonium Bicarbonate). Potato Starch, Pork Gelatine, Wheat Flour, Salt, Dextrose, Ground Spice (Pepper, Nutmeg), Emulsifiers: Sodium Di- and Tripolyphosphate; Preservative: Sodium Sulphite; Antioxidants: Ascorbic Acid, Citric Acid; Extracted Spice (Pepper, Capsicum, Ginger, Mace, Nutmeg, Coriander, Sage). Filled into pork protein casings.

Additives

Example of a typical ingredient list

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Allergen labelling

• Labelling helps consumers avoid foods which could provoke an allergic reaction or food intolerance

• EU legislation (EU Directive 2000/13/EC) requires that 14 allergenic food ingredients, and derivatives, be declared on prepacked foods. These include:

*Includes Brazil nuts, hazel nuts, almonds and walnuts. Pine nuts and coconuts are not classed as nuts so they are not listed as allergens. If these are present as an ingredient in the product they will be listed in the ingredients list

• It is worth noting that peanuts are not true tree nuts, so must ALWAYS be declared separately from true tree nuts

•Cereals containing gluten •Molluscs•Celery •Mustard•Crustaceans •Nuts from trees*•Eggs •Peanuts•Fish •Sesame•Lupin •Soya•Milk (including lactose) •Sulphites > 10ppm

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Allergen labelling (continued)

• Note: some highly processed ingredients that no longer contain allergenic proteins are exempt e.g. wheat based glucose syrup, fully refined soybean oil

• Where more than one ingredient or processing aid is derived from the same allergen e.g. skimmed milk powder and caseinates (both from milk), it would be necessary to make it clear for each ingredient concerned.

• Additionally any allergenic ingredients should be highlighted in a way that clearly distinguishes it from the rest of the list of ingredients.

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Allergen labelling (continued)

Gluten• The composition and labelling of foods for people intolerant to gluten is governed

by EU legislation• The gluten content of any food labelled “gluten free” must not exceed 20 mg/kg• Very low gluten claims can be made on foods, made from wheat, rye, barley

and/or oats (or their crossbred varieties), that are specially processed to reduce the level of gluten to <=100 mg/kg

• These rules mean that the phrase 'suitable for coeliacs' can only be used alongside the terms 'gluten free' or 'very low gluten' and cannot be used on its own

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Date marking

There are two types of date marking, ‘best before’ and ‘use by’:Best before • Used for most foods and indicates the period for which a food can reasonably be

expected to retain its optimum condition quality (eg it will not be stale)• The best before date is shown as the day, month and year in that order

• Alternatively: For food expected to keep for 3 months or less, the best before

date may be shown as the day and month For foods expected to keep for more than 3 months but no

longer than 18 months, the date mark may be shown as ‘best before end’ followed by the month and year

For foods expected to keep for more than 18 months, the date mark may be shown as ‘best before end’ followed by the date in terms of the month and year or the year only

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Date marking (continued)

Use by• The use by date is for food safety. These foods have a shelf life of a relatively

short period, after which their consumption would present a risk of food poisoning• The use by date is the date up to and including when the food may be used safely

(eg cooked or processed or consumed) if it has been stored correctly– For example, ‘use by 10 May’ means use by midnight on 10 May

• Once a food with a use by date on it has been opened, any instructions for use should be followed

– For example ‘eat within three days of opening’

• The use by date overrides any instruction on use of the food once opened. – For example, if the food is opened the 9 May, and the use by date is 10 May, the food

should not be consumed beyond midnight on 10 May even if it says to eat within 3 days of opening

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Date marking (continued)

Other date marks• Best before and use by are the only forms of date marking required by

law and are for use by consumers• Best before and use by dates should not be confused with retailer

markings such as ‘sell by’ or ‘display until’ which are instructions to shop staff

Freezing food• If a food can be frozen, its life can be extended beyond the use by date• However, any instructions on the pack must be followed. For example,

– ‘freeze on day of purchase’ – ‘cook from frozen’ – ‘defrost thoroughly before use and use within 24 hours’

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Front of pack nutrition information• Nutrition information can be provided on the front of food packaging to give consumers

a quick guide to the nutrient content of the product. • In October 2011 an EU Regulation on the provision of food information to consumers

(Food Information Regulation) was published, stating that in addition to mandatory back of pack nutrition information, front of pack nutrition labelling may also be used.

• Two systems for front of pack labelling have been in existence since before development of the Food Information Regulation. These may change in the future. The two systems are: Guideline Daily Amounts (GDAs) and traffic light colour coding.

Calories in one portion or serving of the food

The percentage of your Guideline Daily Amount of calories that a portion of this food gives you

Guideline Daily Amounts (GDAs)•GDAs tell you the amount of calories, sugar, fat, saturated fat (saturates) and salt a portion of that food provides

•The information given on the front of pack is the quantity in grams of each nutrient provided by a portion of the food, and this quantity expressed as a percentage of the Guideline Daily Amount for that nutrient

GDAs are a guide, not a target, and are based on an ‘average person’. Men and women have different requirements. GDAs are based on the requirements for an average woman

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Front of pack nutrition information (continued)Traffic light colour coding• Traffic light labelling is designed to show you ‘at a glance’ whether a

food is ‘high’, ‘medium’, or ‘low’ in fat, saturated fat (saturates), salt and sugar

Red: highAmber: mediumGreen: low

• More green traffic lights indicates the healthier choice• An amber traffic light is not high or low, so you can eat foods with all or

mostly amber lights most of the time• A red traffic light means the food is high in fat, saturated fat, salt or

sugars and these are the foods we should limit• The colour coding is based on the content per 100g of the product. You

may eat a lot more or a lot less than this depending on the product• ‘Per portion’ colour coding criteria should be used if the serving size is

greater than 100g

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Back of pack nutrition information

• In October 2011 an EU Regulation was published, stating that mandatory back of pack nutrition information must be provided on pre-packed foods.

• Products currently not declaring any nutrition information must implement by December 2016 and products currently providing this information must implement the necessary changes by December 2014.

• The nutrition information presented on the back of food packs must be in the form of a table where space permits.

• This information will always be in the same order and must include energy plus 6 further nutrients.

• Energy is in kcal and kJ per 100g, all other nutrients are given in g per 100g or 100ml of the product as sold

Per 100gEnergy 1500kJ/356kcalFat 7.4gof which: saturates 1.1gCarbohydrates 58.1gof which: sugars 16.8gProtein 9.9gSalt 0.1g

Sodium is no longer permitted although a statement can be added explaining salt can be due to naturally occurring sodium.

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Back of pack nutrition information (continued)

• In addition to this basic requirement some labels may carry information per portion

• For products that require further preparation but without the addition of other ingredients the information as consumed may be presented if appropriate cooking instructions are provided within the handling instructions

• The amount of nutrients can be declared as % Guideline Daily Amounts (GDA)* per portion.

Energy is calculated using the formula:

Kcals=(protein (g) x 4) + (carbohydrate (g) x 4) + (fat(g) x 9) + (fibre (g) x 2)

KJ = (protein (g) x 17) + (carbohydrate (g) x 17) + (fat (g) x 37) + (fibre (g) x 8)

Salt equivalent is calculated as follows:

Sodium x 2.5

*GDA values are provided as Reference Intakes in the Food Information Regulation and the values differ slightly from UK GDAs.

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Back of pack nutrition information (continued)• Other nutrients may be added to the nutrient declaration on a voluntary basis

including polyols, starch, monounsaturates, polyunsaturates, vitamins and minerals

• The new Food Information Regulation (FIR) guidance must be implemented by December 2014 and until then some products may display nutrition information in the following format. Some products may also list the Guideline Daily Amounts* with the % GDA per portion.

Nutrition InformationTypical Values

100g as sold

Per sausage as sold

Per sausage cooked

Guideline Daily Amounts Adults

% of GDA* per sausage

Energy 864kJ207kcal

493kJ118kcal

486kJ116kcal 2000 5.8

Protein 10.2g 5.8g 5.9g 45 13Carbohydrate 13.6g 7.7g 7.6g 230 3 of which sugars 3.1g 1.8g 0.3g 90 0.3Fat 12.4g 7.1g 6.8g 70 10 of which saturates 4.3g 2.4g 2.4g 20 12Fibre 0.4g 0.2g 0.4g 24 1.5Sodium 0.5g 0.3g 0.3g 2.4 13Salt equivalent 1.4g 0.8g 0.8g 6 13

Example: Pork sausages that can be grilled

*GDA values are provided as Reference Intakes in the Food Information Regulation and the values differ slightly from UK GDAs.

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Nutrition and health claims

• Nutrition and health claims made on foods are tightly regulated to ensure that consumers are not misled by unsubstantiated, exaggerated or untruthful claims

• Regulation EC No. 1924/2006 defines how nutrition and health claims can be made in labelling, advertising, promotional campaigns and other commercial communications

• The regulation lays down rules for the substantiation and communication of these claims.

• Full nutrition information must be provided on pack whenever a nutrition or health claim is made.

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Nutrition claims

Content claims e.g ‘contains calcium’, etc• Can only be made if they are on a list in

the Annex to regulation 1924/2006• Only the vitamins and minerals listed in

the Regulation may be added to foods and must be present in sufficient quantity in the food to have beneficial effects

• No nutrition or health claims can be made for micronutrients with levels less than 15% RDA per serving ‘as consumed’

• Nutrition and health claims relating to beverages containing more than 1.2% alcohol are prohibited, except those which refer to a reduction in the alcohol or energy content

Comparative claims e.g ‘increased calcium’, ‘reduced fat’ etc

•May only be made between foods or drinks in the same category that are similar in terms of nutrition content or are alternatives for consumption (e.g. spread/butter) •A comparative claim may only be made with food which itself cannot make the claim•Any such claim, may only be made where the reduction in content is at least 30 % (micronutrients 10% difference; sodium/salt 25% difference)

• Nutrition claims state that a food has beneficial nutritional properties, e.g. ‘low fat’, ‘no added sugar’, ‘high in fibre’, etc

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Health claims

• The European Food Safety Authority (EFSA) is responsible for verifying the scientific substantiation of health claims. The European Commission then decides whether to authorise the claim

• Most health claims are so called ‘generic’ health claims, which means that they are scientifically well-established, e.g. calcium and strong bones. These may be used providing the product meets the conditions of use

• All other claims, including those for children’s development, and for disease risk reduction, must undergo a specific authorisation procedure

• Claims that a food prevents treats or cures a disease (‘Medicinal claims’) are prohibited

• Health claims state that health benefits can result from consuming a given food, e.g. ‘vitamin D aids calcium absorption for strong bones’

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Nutrition and health claims continued

Conditions for the Use of Nutrition and Health Claims• The European Commission will develop ‘Nutrient Profiles’ with regard to levels of

saturated fat, sugar and sodium• Meeting the nutrient profile will be a condition in order to make nutrition or

health claims

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Portion sizeFinding portion size information on food labels• Portion size (also labelled as serving size) is normally given with the nutrition table

on the back of pack• If the product has nutrition information on the front of the pack, portion size may

be shown here tooPortion size information and labelling regulations• EU Regulation on the provision of food information to consumers (Food

Information Regulation) states that mandatory nutrition information must be provided on pre-packed foods. Nutrition information must be given per 100g or 100ml of product and information may also be given voluntarily per portion.

• If the portion size is stated it must be quantified on the label and the number of portions contained in the package must also be stated.

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Portion size (continued)

Portion size guidancePortion size information may also be given elsewhere on pack in addition to the nutrition table. Examples of portion size guidance include:

•This pack contains 4 servings•As a guide we recommend this product provides 2 servings•1 serving = 2 pieces•Suggested serving = a quarter of a pot•A typical serving is 75g

Example of back of pack nutrition information showing portion size•Nutrition table for a product in a 200g pot•Portion size is 50g or a quarter of a pot•Information is shown per 100g, as is the legal requirement, and for one quarter of a pot portion

Per 100g One-quarter of a pot (50g)

providesEnergy 1005KJ/

245kcal505KJ/125kcal

Fat 16.8g 8.4gof which: saturates

2.0g 1.0g

Carbohydrates

13.3g 6.7g

of which: sugars

0.2g 0.1g

Protein 9.2g 4.6gSalt 1.0g 0.5g