Subject matter and scope

The EU Food Information to Consumers Regulation or

'FIC' specifies the content of food information and how it
is provided to consumers and caterers.
'Food information' doesn't only cover information provided by labelling. It also
includes information made available in other ways, such as through electronic
networks or verbal communication.

The specific food information rules apply to food in the final state in which it is
supplied to the caterer or to the final consumer. However, the FIC places a
responsibility on all businesses in the supply chain to pass on food information. This
means the final food products can be provided to caterers and consumers with the
correct information.

The requirement to provide information applies to catering as well as non-catering

sales to consumers. It also applies to catering services provided by transport
undertaking as long as they are departing from within the EU.

With one exception, the specific rules apply only to foods presented to caterers or
consumers in prepacked form. EU member states can decide individually what
information should be provided with food sold loose or prepacked for direct sale in
their territories. The exception is that allergen information must be provided with
such food, although how to do this is for individual member states to decide.

General principles and

responsibilities
 Food information is intended to protect the health and
interests of consumers and to achieve the free
movement of legally produced foods in the EU.
Everyone in the supply chain has some responsibility for providing food information
and making sure it is accurate and not misleading.

General principles
Food information helps consumers make safe, informed choices. Good information
means people can take into account health, economic, environmental, social and
ethical considerations. It also supports the free movement of legally produced foods
in the EU, protecting the honest trader.

Food information (including advertising and all aspects of food presentation) must be
accurate, clear and easy to understand. It must not mislead people about the
characteristics of food, including by suggesting that a food:

 has special characteristics when these are in fact shared by all similar foods,
for example claiming that a pork chop is 'gluten-free' or that orange juice is
'suitable for vegetarians'
 contains a normally expected ingredient when this has, in fact, been
substituted by another

Responsibilities
The business under whose name the food is marketed is primarily responsible for
the food information unless that business is not established in the EU, in which case
the first importer into the EU has the responsibility. However, even businesses that
don't affect the information shouldn't supply food where they suspect the information
is non-compliant.

Any changes made to the food information must not mislead or reduce consumer
protection. They are the responsibility of the business making the changes.

Businesses that supply ingredients or consumer-ready loose food to other

businesses must provide enough information for the recipients to meet the eventual
obligations to caterers and consumers.

When consumer-ready prepacked food is not marketed directly to the consumer, the

required food information can be provided in commercial documents. However, the
legal name of the food, the durability date, the storage/usage conditions and the
business name and address must also appear on the external packaging of
the prepacked foods. This also applies when prepacked food is intended for caterers
to use in dish preparation.

Introduction

A product's name is the most important piece of

information for a potential buyer. It helps people
understand the nature of a food that they are not
immediately familiar with. Because of this, the rules on
how products must be named are prescriptive.
Brand names and names that have been protected as intellectual property (e.g.
registered trade marks) don't replace the need for a name of a food under the terms
of the FIC. Neither do 'fancy names', names mainly used to market a food rather
than give potential buyers absolute clarity about what it is.

A food name used in the EU member state of production and marketing can be used
in other EU member states, with any necessary language translation. However,
the FIC recognises that occasionally products can be named in the same way in
different member states but are significantly different - if these are traded between
member states, the name may need to be qualified by additional description so
consumers aren't misled. Less often, a name used in one member state may be so
inappropriate for the product in another member state that the same name cannot be
used, even with qualifications.

The FIC gives no examples of names that may be subject to these additional

restrictions. Businesses are responsible for identifying when such restrictions may
apply to a name they are using.

Types of names

The FIC identifies three types of names: 'legal names',

'customary names' and 'descriptive names'. A product
must use one of these to satisfy the legal requirement to
provide a name for a food. This will depend on the
circumstances or business choice.
Legal names
A legal name means the name prescribed for a food by specific EU legislation
applying to it (e.g. 'milk chocolate', 'pangasius catfish', 'fat spread X%', 'instant
coffee'). If there is no such legislation, it is the name provided for in member state
legislation where the food is sold. Where a legal name exists, it must be used.

Customary names
A customary name is a name accepted by consumers in the member state or part of
the member state where the food is sold, without any further explanation needed,
e.g. 'Yorkshire pudding'. To become customary, a name will be used habitually for a
number of years for a product of consistent composition and characteristics. Further
examples could be 'liquorice allsorts', 'Battenberg cake', 'flapjack' and possibly
'smoothie' and 'caesar salad'. Whether a name has reached customary status is a
matter of perception and there is no official list of customary names.

It is possible for a customary name to go out of fashion and no longer be sufficiently

meaningful on its own. Again, this is a matter of perception, but 'Mississippi mud pie'
could be an example. The use of customary names, where they are perceived to
exist, is voluntary. A business may choose to use what might be commonly
perceived to be a customary name, for instance on the front of a pack, but still
provide what would be a voluntary descriptive name elsewhere on the pack.

Descriptive names
A descriptive name must be given where a food has no legal name and a customary
name doesn't exist or isn't used. This name provides a description of the food. It can
also include an indication of how the food should be used, if needed. The name
should be clear enough that people understand the food's true nature and can
distinguish it from others that it could be confused with.

Descriptive names should mention the ingredients that give the food its main
characteristics. Also any details of the food's structure or form that clarify what it is.
Pictures of ingredients or finished foods don't contribute towards meeting the
requirement to give an adequate descriptive name.

Accompanying particulars

When choosing a product name, businesses need to

fulfil the general requirement to give potential buyers a
clear idea of the nature of the food. They must judge
what to include based on this requirement. But in a few
particular circumstances the FIC prescribes absolutely
that certain indications must be given as 'specific
accompanying particulars'.
Treatments and conditions
Details of how a food has been treated or its condition should be included in the
name of a food or accompany it (e.g. 'powdered', 'freeze-dried', 'concentrated',
'smoked'). This is needed if its absence could mislead the consumer. A finished food
that has been frozen and thawed before sale must state 'defrosted' to accompany its
name. An exception is if the freezing was a necessary step in production or the
defrosting doesn't diminish the safety or quality of the food.

Irradiation of foods must always be indicated in their labelling.

Use of substitute ingredients

Where an expected ingredient in a food has been substituted, an indication of the
substitute ingredient must be given. It should be close to the name of the product
with reasonable prominence relative to the name.

Products with meat or fish

Meat products, meat preparations and fishery products that contain added proteins
from a different animal species must indicate this in their names. If such a food
appears to comprise a whole piece of meat or fish but actually consists of pieces
joined together, it must be marked 'formed meat' or 'formed fish'.

Meat products and meat preparations that look like a cut, joint, slice, portion or

carcass of meat but contain more than 5% added water must mention added water
in their names. The same applies to fish products that look like a whole fishery
product or a cut, joint, slice, portion or fillet.

Minced meat
Minced meat has to meet certain limits for fat and collagen/meat protein ratio
depending on the species it is from and whether it is described as 'lean'. Values for
these parameters must also be given on the labelling of the minced meat using the
wording 'percentage of fat content under...' and 'collagen/meat protein ratio under...'.

Sausage casings
If sausage casing is not edible, this must be indicated. For instance, chorizo sausage
is often encased in parchment not intended for consumption; it must be marked as
such, even if it is not necessarily harmful if consumed.
Introduction

Making nutrition and health claims about foods - such as

'no added salt' and 'folate contributes to normal blood
formation' - is tightly controlled in EU legislation. There
are lists of permitted specific claims. Those that are not
listed can't be used unless they have been applied for
and are 'on hold', pending a decision on authorisation.
Definitions
Nutrition and health claims on foods are controlled in the EU by dedicated legislation,
Regulation 1924/2006, which is separate from the rest of the general controls on
food information. The Regulation defines 'claim', 'nutrition claim' and 'health claim':

'claim' means any message or representation, which is not mandatory under

Community or national legislation, including pictorial, graphic or symbolic
representation, in any form, which states, suggests or implies that a food has
particular characteristics.

'nutrition claim' means any claim that states, suggests or implies that a food has
particular beneficial nutritional properties due to:

(a) the energy (calorific value) it

(i) provides
(ii) provides at a reduced or increased rate, or
(iii) does not provide, and/or

(b) the nutrients or other substances it

(i) contains
(ii) contains in reduced or increased proportions, or
(iii) does not contain.

'health claim' means any claim that states, suggests or implies that a relationship
exists between a food category, a food or one of its constituents, and health.

A key point is that statements are only claims within the scope of the controls if they
could be construed as implying a benefit for nutrition or health.

The definition of 'nutrition claim' refers to beneficial 'nutrients' and 'other substances'.
These are defined as:

'nutrient' means protein, carbohydrate, fat, fibre, sodium, vitamins and minerals

listed in the Annex to Directive 90/496/EEC, and substances that belong to or are
components of one of those categories.

'other substance' means a substance other than a nutrient that has a nutritional or

physiological effect.

In short, a nutrition claim is a claim about a constituent of a food. A health claim goes
further and relates a food or one of its constituents to health or well-being.

Scope
The Regulation applies to nutrition and health claims, made commercially in
the labelling, presentation or advertising of foods to be delivered as such to the final
consumer or caterers.

Trade marks, brand names or fancy names that may be construed as nutrition or
health claims, and non-specific health claims, are within the scope of the controls.
They can be used if sustained by an accompanying permitted nutrition or health
claim as appropriate.

General principles for all

claims
Some general principles are laid down for all claims.
These are designed to ensure that claims don't bring
into doubt the adequacy of a balanced diet and don't
mislead consumers about the likely benefits of a food.
Claims should not endorse excessive consumption of a food. Neither should they
attempt to drive purchases by alarming consumers about the consequences for
health of a failure to obtain adequate amounts of nutrients.

Control by nutrient profiles

The Regulation incorporates the principle that certain foods should not be permitted
to bear health claims and should be restricted in making nutrition claims on the basis
of the quantities of certain nutrients they contain. These controls are based on
'nutrient profiles', which set limits for nutrients such as fat, saturated fat, sugars and
salt/sodium. The limits act as hurdles to be cleared before claims can be made
without the nutrient profile controls applying.

The nutrient profiles for particular foods are yet to be established and so currently,

while claims must never be misleading, specific nutrient profile controls are not in
place. At present there is no clear timetable from the Commission regarding their
development.

Alcoholic drinks cannot bear health claims, but may bear nutrition claims relating to
low or reduced alcohol levels or reduced energy content. Conditions for the making
of these claims are not set in Regulation 1924/2006, and may be set nationally. In
the UK, conditions are set in the successor legislation to the
Food Labelling Regulations 1996.

General conditions
Claims are only permitted in the following circumstances:
 The claimed benefit is substantiated by scientific evidence that the maker of
the claim can be asked to produce.
 The level of the nutrient is such that the claimed effect will be displayed when
a realistic quantity of the food is consumed.
 The nutrient is in a form available to the body (bio-available).
 The average consumer can be expected to understand the beneficial effects.
 Claims should refer to the food prepared for consumption according to the
instructions given.

Nutrition labelling of prepacked foods bearing nutrition or health claims is mandatory

even where the FIC would otherwise provide an exemption for the food in question.
The declaration should include the nutrient that is the subject of the claim or, where
the nutrition labelling rules do not permit this, information on the content of
the nutrient should be given in the same field of vision as the nutrition labelling.

Nutrition claims

Nutrition claims say something about the level of

a nutrient in a food in a way that implies it is beneficial.
These claims and associated conditions are in a list at
the end of the Regulation and are the only permitted
nutrition claims.
Examples of permitted nutrition claims and associated conditions follow.

'high fibre'
A claim that a food is high in fibre, and any claim likely to have the same meaning for
the consumer, may only be made where the product contains at least 6g of fibre per
100g or at least 3g of fibre per 100 kcal.
 'fat-free'
A claim that a food is fat-free, and any claim likely to have the same meaning for the
consumer, may only be made where the product contains no more than 0.5g
of fat per 100g or 100ml. However, claims expressed as 'X% fat-free' shall be
prohibited.

Vitamin and mineral claims

The conditions for vitamin and mineral claims are based on how much of
the nutrient a product contains compared to 'significant amounts', as referred to in
the FIC. The FIC states that, generally speaking, what constitutes a 'significant
amount' should consider:

 For single portion food and drinks: 15% of the nutrient reference value of

the nutrient in that single portion.
 Otherwise, 15% of the nutrient reference value in 100g/100ml of foods and
7.5% of the nutrient reference value in 100ml of drinks.

These nutrient reference values are also given in the FIC, e.g. 2.5µg for vitamin B12
and 3.5mg for fluoride.

Comparative claims
Comparative claims (such as 'reduced', 'increased' or 'light') are slightly different:
control is based on the extent of the difference in nutrient content between the
product making the claim and similar products. The extent of the difference must be
stated in the product's labelling and must be at least 30% for most nutrients, but only
25% for 'reduced sodium' or 'reduced salt' and only 10% of the nutrient reference
values for reduced vitamin or mineral claims.

Health claims
 Health claims link a food or one of its constituents to
health. The Regulation identifies different types of health
claim: general function, novel general function, reduction
of disease risk and those referring to children.
Consequently, the controls are more complex than they
are for nutrition claims.
General conditions
The use of a health claim triggers the need for further statement(s) in the labelling,
presentation or advertising of the food in question. These relate to the general
importance of a healthy diet and lifestyle, the pattern of consumption required, and
any cautions against consumption by certain people or excessive consumption.

Claims that make reference to a rate or amount of weight loss are not permitted. Nor
are those that include endorsements by doctors, health professionals and
associations other than national associations of medical, nutrition or dietetic
professionals and health-related charities.

Types of health claims

 Well-established general function

These refer to the role of a nutrient in physical or mental functions, including in

weight control by reducing the sense of hunger or the availability of energy from the
diet. They are based on established science and are well understood by the average
consumer, e.g. 'thiamine contributes to the normal function of the heart'. Over 200 of
these claims have been approved and the conditions for their use were published in
May 2012 in Commission Regulation (EU) No 432/2012.

 Novel general function claims

There is a separate application and approvals procedure for general function claims
based on newly generated scientific data or where protection of proprietary data is
sought. So far, four health claims have been approved under this procedure, e.g.
'Cocoa flavanols help maintain the elasticity of blood vessels, which contributes to
normal blood flow'.

 Reduction of disease risk or referring to children

 The application process for approval of these claims is more rigorous than for
general function claims and limited numbers have so far been approved. An example
of an approved reduction of disease risk health claim is: 'Barley beta-glucans has
been shown to lower/reduce blood cholesterol. High cholesterol is a risk factor in the
development of coronary heart disease'.

An example of an approved health claim referring to children's development and

health is: 'Docosahexaenoic acid (DHA) intake contributes to the normal visual
development of infants up to 12 months of age'.

 Non-specific health claims such as 'healthy' or 'superfood' can only be used

on products which legitimately carry an approved health claim of one of the above
types.

EU register of permitted
claims and non-authorised
health claims

The Commission has established an EU register of

nutrition and health claims made on foods, which is
available online.
The register includes:

 the permitted nutrition claims and their conditions of use

 the authorised health claims, split into their different types
 the non-authorised health claims, split into their different types, with the
reasons for their non-authorisation
 The register can be freely searched at: http://ec.europa.eu/nuhclaims/?
event=search.

Ingredients lists:
exemptions and basic rules

Most prepacked foods should be marked with a list

of ingredients. The legislation is very clear about how
this should be done.
A list of ingredients should carry a heading consisting of or including the word
'ingredients'. Ingredients are then listed in descending order of their weights at the
time they were used in the production of the food. The precision of
an ingredient name should be informed by the name that would be required if it was
sold on its own as a food, although in certain cases the use of less precise, 'generic'
names is permitted.

Products not requiring an ingredients list

Certain foods don't need to be marked with an ingredients list, such as:

 unpeeled, uncut fresh fruit and vegetables

 carbonated water, if described as carbonated
 basic vinegar, cheese, butter, fermented milk and cream containing no non-
essential ingredients
 single-ingredient foods named so that the nature of the ingredient is clear
 alcoholic drinks
 Constituents not required to be included in ingredients lists
The following ingredients don't need to be listed:

 Those components of an ingredient that were temporarily isolated during

product manufacture but reintroduced in their original proportions, such as egg
yolk and egg white used separately in a product but declared as 'egg'.
 Non-functional carryover additives and enzymes.
 Additives, enzymes and other substances used as processing aids.
 Carriers for additives, enzymes, flavourings and nutrients.
 Water used up in reconstituting concentrated or dried ingredients.
 Water as part of a liquid medium that is not normally consumed.

Further rules and flexibility

For particular ingredients or combinations of ingredients there is flexibility around
listing in descending order by weight or grouping ingredients.

The listing of additives, flavourings and compound ingredients has particular rules.

Quantitative indications
 The legislation requires the quantity of
certain ingredients in prepacked foods to be indicated as
a percentage.
The indication can be given with the name of the food or in the ingredients list.
The ingredients this applies to are those:

 appearing in the name of the food or usually associated with that name by the
consumer (e.g. the meat in a 'shepherds pie')
 emphasised over other ingredients on the labelling in any way, e.g. by being
pictured
 characterising a food where the nature of the food may otherwise be unclear
as the result of the name used (e.g. a foreign name) or the food's appearance

Exemptions
A quantitative indication will not be required for an ingredient already quantified on
the label under other provisions:

 where its drained net weight is given

 where a statement of its quantity is required under product-specific provisions
(e.g. the fruit in jam)
 where the ingredient is a vitamin or mineral included in the nutrition
declaration

There is also an exemption for ingredients that play a minor role in consumer choice.
These ingredients may be mentioned in the name of the food, but the variation in
their quantity is not a decisive factor for the nature of the product (e.g. the potato in a
beef and potato pie).

Further exemptions concern:

 ingredients added for flavouring in small quantities (taken to be up to 2% in

the UK)
 ingredients specifically permitted to be present in somewhat varying quantities
(e.g. mixtures of vegetables)
 ingredients that are sweeteners or sugar, and are mentioned using one of
these names in the food's name as a statutory requirement
Calculation
Where foods lose moisture during processing, the quantitative indication should be
calculated as the weight of the ingredient divided by the finished weight of the
product, i.e. taking into account only the residual water in the product. Where this
would lead to a value of more than 100%, the weight of the ingredient used to
prepare 100g of the finished product should be stated instead.

Indications for volatile ingredients should be calculated from ingoing amount and

finished product weight.

Indications for ingredients that are in concentrated or dehydrated form can be on the

basis of the pre-concentrated or pre-dehydrated form.

Indications for ingredients in foods that must be reconstituted can be on the basis of

their proportion in the reconstituted product.

Allergen labelling

The legislation identifies 14 substances or products

which, when intentionally used as ingredients, must be
given special emphasis within ingredients lists because
 of their potential to cause allergic or intolerance
responses.
The 14 substances or products caught by the obligation, which also applies to
products made from them except in the case of sulphur dioxide and sulphites, are:

 cereals containing gluten (namely: wheat, rye, barley, oats, spelt, kamut or
their hybridised strains)
 crustaceans
 eggs
 fish
 peanuts
 soybeans
 milk
 tree nuts (namely: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil
nuts, pistachio nuts, macadamia or Queensland nuts)
 celery
 mustard
 sesame seeds
 sulphur dioxide and sulphites when the concentration of total sulphur dioxide
in the whole prepared food is above 10mg/kg or 10mg/litre
 lupin
 molluscs

Means of declaration
The allergen name, as listed above, should be given and emphasised in ingredients
lists. Emboldening may be preferred, but this is not stipulated. Where there is
no ingredients list a 'contains...' statement should be made.

Where the allergen is referred to in the name of the food, this alone satisfies the
requirement.

Additional allergen advice statements can refer consumers to the ingredients list but
not give the names of the allergens.

Food sold loose must be accompanied by allergen information.

Exemptions
Following risk assessment, some allergen derivatives have been exempted from the
requirement, such as wheat-based glucose syrups and fully refined soybean oil.

Otherwise there are no exemptions. As it is food safety information,

allergen labelling overrides any exemptions from declaration provided for elsewhere.

Cross-contamination
The legislation controls only intentionally used allergens. 'May contain...' statements
are uncontrolled and permitted.

Absence-of-gluten claims
Claims that a food is 'gluten-free' or 'very low gluten' are specifically controlled
whether the food is sold prepacked or loose. Gluten-free foods can have no more
than 20ppm gluten. Foods containing ingredients that have been processed to
reduce their gluten content can be labelled 'very low gluten' when they contain no
more than 100ppm gluten. The terms 'suitable for coeliacs' and 'suitable for most
coeliacs' can supplement the terms 'gluten-free' and 'very low gluten' respectively.

'No gluten-containing ingredients' may be used where cross-contamination is

controlled but some risk may remain.

For more detailed information on allergens, visit the FSA's food allergy online training
at http://allergytraining.food.gov.uk/.

Introduction and derivation

of values
 Most prepacked foods must carry nutrition labelling from
13 December 2016. Exemptions are mainly for minimally
processed foods and those with little nutritional value.
Nutrition information already being provided must be
compliant from 13 December 2014. The EU FIC also
includes rules on the provision on voluntary 'front of
pack' nutrition information.
Derivation and accuracy of values
The declared values must be averages based on:

 Manufacturer's analysis of the food.

 Calculation from the known or actual values of the ingredients used.
 A calculation from generally established and accepted data.

The term 'average value' means a value that best represents the amount of
the nutrient and allows for natural variability, seasonal variability, patterns of
consumption and other factors that may cause the actual value to vary.

The nutrients and energy value must be for the food as sold. However, nutrition
information may be given for the food after preparation if sufficiently
detailed preparation instructions are provided.

The energy value must be calculated using conversion factors set out in the FIC, for
example, one gram of fat will provide 37 kilojoules (kJ) and 9 kilocalories (kcal).
Tolerances and rounding
It is important that the actual nutrient content does not deviate substantially from
labelled amounts. As a result, the European Commission has published guidance
setting tolerances for declared nutrient values.

The measured value for nutrients should be within the tolerances for the declared
value during the entire shelf life of the food. The tolerances set for the nutrition
declaration on foods other than food supplements include the uncertainty of
measurement associated with a measured value. The tolerances apply either side of
the declared value. Separate tolerances are established for vitamins and minerals in
foods by addition or in food supplements, and when nutrient levels are used to
support claims.

Negligible amounts
The Commission guidance considers the amounts of nutrients that can be regarded
as negligible and can be declared as '0' or '<x g' as follows:

Fat, carbohydrate, sugars, protei
≤0.5g per 100g/ml "0g" or "<0.5g"
n

Saturates ≤0.1g per 100g/ml "0g" or "<0.1g"

Salt ≤0.0125g per 100g/ml "0g" or "<0"

Alternatively, where the energy or nutrient level is negligible, the information may be

replaced by a statement such as 'Contains negligible amounts of...' in close proximity
to the nutrition declaration.

The basic declaration

The mandatory nutrition declaration must be clearly
presented in a specific format and give values for energy
and six nutrients. The values must be given in the units
indicated below (including both kJ and kcal for energy)
per 100g/ml, and the nutrition declaration must meet the
minimum font size requirements.
The mandatory seven
The mandatory nutrition declaration is:

Energy kJ and kcal

Fat g

of which:
g
Saturates

Carbohydrat
g
e

of which:
g
sugars

Protein g

Salt g
Salt is calculated by determining the total sodium (naturally occurring and that
deriving from added salt and sodium-based additives, for example some raising
agents) and multiplying by 2.5. A statement indicating that the salt content is
exclusively due to the presence of naturally occurring sodium may appear in close
proximity to the nutrition declaration.

Forms of expression
The amounts of the mandatory seven must be expressed per 100g or 100ml. In
addition, they may be expressed per portion and/or per consumption unit, which
must be easily recognisable by the consumer. The portion or unit used must be
quantified on the label in close proximity to the nutrition declaration, and the number
of portions or units contained in the package must also be stated.

The mandatory seven may also be expressed as a percentage of the established

reference intakes per 100g or per 100ml and/or per portion and/or per consumption
unit. Where % RI information is provided per 100g or per 100ml, the statement
'Reference Intake of an average adult (8400kJ/2000kcal)' must appear in close
proximity.

Format and positioning

Mandatory nutrition information must appear on the package or on a label attached
to the package. Unless space does not permit, it must be presented in tabular format
with the numbers aligned, rather than in linear format. The mandatory nutrition
declaration must appear on a package or label in characters using a font size where
the x-height is a minimum of 1.2 mm.

If the largest surface area of a package or container has an area of less than 80cm 2,
then the minimum 'x-height' is 0.9 mm. If the largest surface area of a package is
less than 25cm2, then the product is exempt from nutrition labelling.

The basic declaration

The mandatory nutrition declaration must be clearly
presented in a specific format and give values for energy
and six nutrients. The values must be given in the units
indicated below (including both kJ and kcal for energy)
per 100g/ml, and the nutrition declaration must meet the
minimum font size requirements.
The mandatory seven
The mandatory nutrition declaration is:

Energy kJ and kcal

Fat g

of which:
g
Saturates

Carbohydrat
g
e

of which:
g
sugars

Protein g

Salt g
Salt is calculated by determining the total sodium (naturally occurring and that
deriving from added salt and sodium-based additives, for example some raising
agents) and multiplying by 2.5. A statement indicating that the salt content is
exclusively due to the presence of naturally occurring sodium may appear in close
proximity to the nutrition declaration.

Forms of expression
The amounts of the mandatory seven must be expressed per 100g or 100ml. In
addition, they may be expressed per portion and/or per consumption unit, which
must be easily recognisable by the consumer. The portion or unit used must be
quantified on the label in close proximity to the nutrition declaration, and the number
of portions or units contained in the package must also be stated.

The mandatory seven may also be expressed as a percentage of the established

reference intakes per 100g or per 100ml and/or per portion and/or per consumption
unit. Where % RI information is provided per 100g or per 100ml, the statement
'Reference Intake of an average adult (8400kJ/2000kcal)' must appear in close
proximity.

Format and positioning

Mandatory nutrition information must appear on the package or on a label attached
to the package. Unless space does not permit, it must be presented in tabular format
with the numbers aligned, rather than in linear format. The mandatory nutrition
declaration must appear on a package or label in characters using a font size where
the x-height is a minimum of 1.2 mm.

If the largest surface area of a package or container has an area of less than 80cm 2,
then the minimum 'x-height' is 0.9 mm. If the largest surface area of a package is
less than 25cm2, then the product is exempt from nutrition labelling.

Repetition on front of pack

 The energy value and amounts of certain nutrients may
be voluntarily repeated. This highlights nutrition
information of importance to public health and helps
consumers make healthier food choices.
What can be repeated?
Energy and certain nutrients in the mandatory nutrition declaration may be repeated
in the 'principal field of vision'. Declaration options are:

 Energy (kJ and kcal) alone or

 Energy (kJ and kcal) and fat, saturates, sugars and salt (Energy+4)

Forms of expression
The voluntary declaration may be presented per 100g or 100ml only or per 100g or
100ml plus per portion and/or consumption unit. If information on energy+4 is
presented, the amounts of the four nutrients can be given per portion and/or
consumption unit only, but the energy value must be expressed both per 100g or
100ml and per portion and/or consumption unit.

The portion and/or consumption unit must be quantified in close proximity to the
nutrition declaration.

Format and positioning

Voluntarily repeated nutrition information must appear in the principal field of

vision. This is the part of a package most likely to be seen at a first glance by
the consumer at the time of purchase. The consumer will be able to

immediately identify a product in terms of its character or nature and its brand

name (if applicable). In practice, this may be the front of the pack.

The minimum font size requirement of 1.2 mm x-height applies and it appears

from the drafting of the FIC that this minimum size applies to this declaration

even when a pack's largest surface is less than 80cm 2, which triggers a general

reduction in minimum font size to 0.9mm x-height.

Additional forms of
expression (AFE)

Nutrition information may be expressed in other ways,

for example colour coding of nutrients. However, the use
of AFE must meet certain tightly defined criteria, for
example they must be based on sound and scientifically
valid consumer research.
Criteria for acceptance
The energy value and the amount of nutrients may be given by other forms of
expression - presented using graphical forms or symbols as well as words or
numbers. However, the forms of expression must meet the following criteria:
 They are based on sound and scientifically valid consumer research and do
not mislead the consumer.
 They are developed as a result of stakeholder consultation.
 They aim to facilitate consumer understanding of the contribution or
importance of the food to the diet.
 They are supported by scientifically valid evidence of understanding of such
forms of expression or presentation by the average consumer.
 In the case of other forms of expression, they are based on harmonised
reference intakes or on generally accepted scientific advice.
 They are objective and non-discriminatory.
 They do not create obstacles to the free movement of goods.

Government recommendations and notification requirements

Member States may recommend to businesses the use of one or more additional
forms of expression or presentation, but must inform the European Commission.
Member States must monitor the use of AFE on their territory and may require
businesses that label foods with additional forms of expression to notify the
competent authority.

Recommended additional form of expression in the UK

Four UK governments have published guidance on creating a front of pack nutrition
label. It supports the Health Ministers' recommendation on the use of colour coding
as an additional form of expression.

A front of pack label developed in accordance with the guidance contains:

 Energy (kJ and Kcal) per 100g or 100ml and in a specified portion
 Amounts of fat, saturates, sugars and salt in a specified portion
 Portion size information
 % RI information based on the amount of each nutrient and energy value in a
portion
 Red, amber and green colour coding of the nutrients (not energy)

The descriptors "High", "Medium" and "Low" can also be used.

Alcoholic drinks and non-
prepacked foods

Businesses may provide, on a voluntary basis, nutrition

information for alcoholic beverages and non-prepacked
foods. The EU FIC provides for limited elements of the
nutrition declaration to be declared for such products.
Alcoholic drinks
Alcoholic drinks containing more than 1-2% by volume of alcohol (ABV) are exempt
from mandatory nutrition labelling pending a European Commission report
on labelling of alcohol.

A voluntary energy (kJ and kcal) declaration alone may be made on alcoholic drinks
on a per 100ml basis. The information may additionally be given per glass (i.e. per
portion). Alternatively, a full nutrition declaration on a voluntary basis may be given
per 100ml and can additionally be given per portion. There is no requirement to meet
the specific minimum font size nor to use the tabular format.

Non-prepacked food
Nutrition information is not required to be provided for food sold non-prepacked.
However, if it is provided voluntarily it can comprise the energy value alone or the
energy value and the amounts of fat, saturates, sugars and salt (energy+4), or, of
course, the full mandatory seven (energy+6).

When the information comprises energy value alone or energy+4, it may be provided
per 100g or 100ml only, per 100g or 100ml and per portion or consumption unit, or
per portion and/or per consumption unit only.

For information on energy+4 per portion and/or consumption unit alone, there is no
requirement to express the energy both per 100g or 100ml and per portion, as would
be the case for 'front of pack' labels.

There is no requirement for nutrition labelling for non-prepacked food to meet the

specific minimum font size. It does not have to appear in the tabular format nor in a
specific place.

Food information - the FIC

and beyond

As well as the information requirements in the FIC,

some products must meet further requirements given in
product-specific legislation. The FIC doesn't affect the
detail of this information but sets out principles to ensure
it is relevant, beneficial and clear.
The term 'mandatory food information' covers both the requirements laid out in
the FIC and the extra requirements for particular products.

This all-encompassing mandatory food information includes, for instance, the cocoa

solids declaration on chocolate, the fruit and sugar declarations on jam, and the
quality-related class information on poultry, meat, eggs and some fruit and
vegetables. There are some general rules in the FIC for the information:
 It should cover the areas of: the characteristics of the food, the protection of
consumers' health, the safe use of the food, the nutritional characteristics of the
food.
 In distance-selling transactions it should all be available before the purchase
is concluded (other than the durability date).
 Where food is non-prepacked, it should nevertheless be passed along the
supply chain.
 Where food is prepacked, it should be marked on the package or an attached
label.
 It should be easily visible, clearly legible, indelible, and not hidden, obscured,
detracted from or interrupted by other material (but requirements from product-
specific legislation are not subject to the specific minimum font size requirement of
the FIC - see the page on Legibility).
 It must all be in a language easily understood in the area where the food is
marketed.

FIC mandatory particulars

 The FIC provides a list of basic items of information to
be provided with prepacked food for caterers or
consumers. Some items are only required in particular
circumstances and there are also specific exemptions
for particular foods or circumstances.
Mandatory particulars
The list of 'mandatory particulars' for a prepacked food comprises:

 a name of the food

 a list of ingredients
 an indication of intentionally used allergens or allergen derivatives
 a quantification of particular ingredients (a 'QUID' indication)
 a net quantity statement (usually weight or volume)
 a 'best before' or 'use by' date
 storage conditions and/or conditions of use where necessary
 name and address of the business taking responsibility for the food
information
 an origin statement (for some products and/or in some circumstances)
 instructions for use where necessary
 an alcoholic strength by volume statement for beverages with an alcohol by
volume above 1.2%
 a nutrition declaration

Exemptions from certain mandatory particulars

There are several exemptions from the above mandatory particulars for particular
foods in particular circumstances. These are covered in the individual modules on
each mandatory particular where these exist. But there are generally applicable
small-pack exemptions:

 Food in packaging or containers where the largest surface has an area of less
than 25cm2 is exempt from the nutrition declaration.
 Food in packaging or containers where the largest surface has an area of less
than 10cm2 has only to be marked with a name of the food, allergen labelling, a net
quantity, and a 'best before' or 'use by' date. The ingredients list must also be
provided but this can be by other, off-label means (for example, via a website,
telephone helpline, catalogue, notice or upon request).
 Not covered elsewhere are the exemptions for glass bottles intended for reuse that
are indelibly marked and have no label, ring or collar. These must only have a subset
of the mandatory particulars. EU member states can exempt milk bottles of the
above type from all mandatory information requirements; the UK is taking up this
exemption.

Additional mandatory
particulars

Certain types of food must be marked with additional

particulars. These inform the consumer about the state
or composition of particular foods, or give cautionary
advice where consuming the food could have
consequences for people's well-being.
In some cases, the position of the extra particulars on the label is specified, but the
minimum font size provisions don't apply. Additional particulars are:

 Where special gases have been used during packing to extend shelf life,
'packaged in a protective atmosphere' is required.
 Where sweetener additives have been used, their presence must be indicated
in general terms with the name of the food.
 Where aspartame has been used it must be referred to by name on the label
along with a reference to its component, phenylalanine.
 Where polyols are present by addition at greater than 10%, 'excessive
consumption may produce laxative effects' is required.
 Confectionery or beverages containing glycyrrhizinic acid (due to its addition
or the inclusion of liquorice) may, depending on the level, need to be marked with
'contains liquorice'. This may be followed by 'people suffering from hypertension
 should avoid excessive consumption'. These statements must be after
the ingredients list or, in the absence of a list, with the food's name.
 Beverages with high caffeine, or solid foods with added caffeine, may need to
be marked with the level of caffeine and to indicate unsuitability for children or
pregnant or breast-feeding women. These statements must be in the same field of
vision as the food's name.
 When phytosterols or phytostanols or their esters have been added to foods,
they need to be marked to make this addition clear, to indicate that they are not
intended for people with no need to control their blood cholesterol, and to give
dosage and associated dietary advice.
 Frozen meat, meat preparations and unprocessed fishery products must be
marked with a date of freezing.

Legibility

People need to be able to find and make sense of the

information. Poor legibility undermines the FIC's role in
ensuring that consumers can make informed choices
and use food safely. Provisions in the Regulation aim to
stop this from happening.
Availability and placement
With prepacked food, mandatory information (i.e. that required under the FIC and
any other EU legislation) must be given on the package or on a label attached to it.
Individual Member States can decide how to show any information they require to be
given with food sold loose in their territories (this will comprise at least allergen
information).
Presentation
Items of mandatory information must be conspicuous, legible and indelible, and their
impact not compromised by other written or pictorial material.

The mandatory particulars listed in Article 9(1) of the FIC must be given

in labelling in a way that ensures legibility. The elements of 'legibility' are identified in
the Regulation as aspects including font size, spacing between letters and lines,
typeface, the surface of the material and contrast between the print and the
background. In due course, rules may be established for a number of these, but
the FIC currently specifically controls only font size: it must be of a size where the
lower case 'x' character has a height of at least 1.2mm. This is reduced to 0.9mm for
food in packaging or containers where the largest surface has an area of less than
80cm2.

Weights and measures indications on products of predetermined constant quantity

are subject to separate overriding size requirements in EU weights and measures
legislation.

Field of vision
The FIC is not generally prescriptive about the relative positioning of the mandatory
particulars. However, the name of a food, its weight or volume declaration and its
alcoholic strength statement (for an alcoholic beverage) must be simultaneously
visible on the package, even if on different surfaces. Glass bottles for reuse and very
small packs are exempt from this requirement.

Languages used
All mandatory food information must be given in a language easily understood where
the food is sold. Several languages may be used on a label as long as font size rules
are followed.

Member States may stipulate the use of one or more languages for food marketed in
their territories, but the UK has not done this, although products marketed in the UK
should give mandatory food information in English. Other languages, such as Welsh,
can be used as well as, but not instead of, English.

Distance selling
A supplier and a buyer may not be physically in the
same place at the same time. Specific provisions in
the FIC for food offered for sale remotely, for instance
on home shopping websites, outline when and how to
fulfil food information requirements.
Prepacked food
When a prepacked food is sold remotely, all the information required by EU law for
the food must be available before the buyer completes the purchase. Only the 'best
before' or 'use by' date are excluded from this requirement.

The information must be available on the distance selling platform (e.g. catalogue,

website) or via other free-of-charge means indicated by the supplier (e.g. a free
telephone helpline).

All the Article 9 mandatory particulars must be available at the moment of delivery.

Non-prepacked food
Food information requirements here comprise allergen information and any
information required to be provided under EU member state national rules. When
non-prepacked food is sold by distance selling, these information requirements must
be available before the buyer completes the purchase. Only the 'best before' or 'use
by' date are excluded from this requirement. All the required particulars must be
available at the moment of delivery.

Delivery by automated means

Prepacked foods may be sold via automatic vending machines or automated
commercial premises. In these cases, the FIC Article 9 mandatory particulars only
need to be made available to the buyer at the moment of delivery.
 Food supplements

Food supplements are defined as any prepacked

foodstuffs designed to supplement the normal diet with a
concentrated form of vitamins and minerals, or other
physiologically effective substances. Products are
normally sold in dose form and have their own
specific labelling requirements.
Only permitted vitamins and minerals can be used in the manufacture of food
supplements. These must meet the relevant purity criteria.

Maximum safe levels of particular vitamins and minerals in food supplements have
not yet been established.

Food supplement products that are sold directly to consumers or to caterers must be
named 'food supplement'. They must also be labelled with the following additional
statements:

 The name of the category of vitamin, mineral or other substance with a

nutritional or physiological effect that characterises the product.
 The portion of the product recommended for daily consumption.
 A warning not to exceed the recommended daily dose.
 That food supplements should not be used to substitute a varied diet.
 That the product must be stored out of reach of young children.

The amount of any vitamin, mineral or substance with a nutritional or physiological

effect must be declared:

 in numerical form
 in the relevant units
 as the amount per portion of the product as recommended for daily
consumption on the labelling
 as an average amount based on the manufacturer's analysis

For a vitamin or mineral listed in the nutrition labelling directive, the amount should

also be shown as a percentage of the relevant recommended daily allowance.

Fortified foods

Foods may be voluntarily fortified with vitamins and

minerals. For example, this may be done to restore what
has been lost during manufacture, storage or handling
procedures. Fortification may also be used or required to
give a substitute food a similar nutritional value to the
food it replaces.
Addition of vitamins and minerals
The general rules on fortification are for the voluntary activity and don't apply where
addition is required by law. Nor do they apply to food supplements or to the use of
vitamins and minerals for additive purposes controlled by specific legislation.

Only permitted vitamins and minerals can be added to foods. These must be in a
bio-available form, and an approved vitamin formulation or mineral substance listed
on the label.

To ensure that fortification is beneficial to health, the final food must contain at least
a significant amount of the vitamin or mineral unless the fortification was purely to
restore processing losses and no nutrition or health claim is made. What constitutes
a significant amount of a vitamin or mineral is defined in the FIC.

Labelling
Wherever a vitamin or mineral has been voluntarily added to a product,
nutrition labelling is required. This should include the total amount of vitamin or
mineral in the final food, inclusive of the naturally occurring amount.

Statements about vitamins and minerals must comply with the nutrition and health
claims regulation. Consumers should not be misled on the true nutritional merit of the
food. Any labelling must not state or imply that a balanced diet can't provide
appropriate amounts of vitamins and minerals.

Addition of other substances

Substances other than vitamins and minerals, that have a nutritional or physiological
effect, are within the scope of the general rules on fortification but no controls on
specific substances have yet been imposed. The rules allow such controls to be
developed on a case by case basis as and when the need arises.

Definitions and general rule

For many foods the giving of origin information is

voluntary. However, like all food information provided,
origin indications must not mislead whether they are
being given on a mandatory basis or voluntarily.
Definitions
The FIC identifies the origin of a food as being either its 'country of origin' or 'place of
provenance'. The 'country of origin' is the country from which the product was wholly
obtained or, if production involved more than one country, the country where the
product last underwent substantial, economically justified processing. The 'place of
provenance' is any place where a food is indicated to come from that is not the
'country of origin'.

The FIC makes it clear that the legally required food business name and address

details on a label do not constitute an origin statement.

General rule
Unless required under a specific rule (see page on 'Further mandatory
origin labelling'), an indication of country of origin or place of provenance is only
mandatory for prepacked products in general where, in its absence, the consumer
might be misled as to the true origin of the food. This could arise particularly where
aspects of the labelling of the food (including pictures etc.) might imply for the
consumer an origin which was incorrect. To indicate authentic characteristics the
packaging of a prepacked baguette, for instance, might depict the colours of the
French flag, or a product's chosen name might include a geographical reference, e.g.
'Greek style yogurt', but if the origin of the products was not France or Greece
respectively, then the true origin would need to be stated.

Where origin information is given voluntarily on a label, this must follow the rules as if
it was being given on a mandatory basis, except that the legibility requirements do
not apply (see Mandatory information and legibility module). In terms of label space,
the mandatory food information on a label must be prioritised over voluntary
information, so on a small label a business may find that it is not possible to include
voluntary origin information.

Fresh meat, chilled or

frozen
 The FIC requires that an origin statement be given for
fresh, chilled and frozen meat of pigs, sheep, goats and
poultry when they are sold as such. Beef sold in these
forms is also required to be marked with an origin
statement, but under separate EU-wide specific
beef labelling rules.
An Implementing Act gives further details on the application of this requirement and
in particular on traceability and on exactly what should comprise the label indication
in terms of the places of birth, rearing and slaughter of the animal.

Labelling
The requirement is that the meat in question must be marked with a Member State
or third country of rearing (with additional rules for when rearing has taken place in
more than one country), a Member State or third country of slaughter and
a batch code identifying the meat. The requirement is varied in the following
circumstances:

 Where meat has been obtained from animals born, reared and slaughtered in
the same country, the 'reared in...' and 'slaughtered in...' statements may be
replaced by a single 'Origin...' statement.
 Where several pieces of meat which would require different indications are
packed together, all the Member States or third countries of origin must be listed,
along with the batch code identifying the meat.
 Where, for meat imported from third countries, the place of rearing is
unknown, the indication 'Reared in: non-EU' may be combined with a specific
'Slaughtered in...' statement.

Minced meat and trimmings (as defined) must also be marked with a batch code, but

may be marked with less specific 'reared in...' and 'slaughtered in...' indications
identifying only the 'EU' or 'non-EU'.
 Traceability
The requirement is for a system which ensures a link between the meat and the
animal or group of animals from which it was derived, and ensures the transmission
of the origin information with the meat along the supply chain. The system should
record the arrival at and departure from establishments of animals, carcases and
cuts along the supply chain.

The business making up packs for the consumer or caterer must correlate
the batch codes applied to these with those of their incoming meat. All packs with the
same batch code must have the same origin indications.

'Foreign' primary
ingredients

The FIC requires that when the origin of a whole product

is volunteered and the origin of its primary ingredient is
different, information must also be given about the origin
of that primary ingredient. The application of this
requirement is subject to further rules, yet to be
published, and so the date of its application is unclear.
This provision addresses the situation where, for instance, the origin of a meat ready
meal is stated (e.g. 'produced in the UK'), but the origin of the meat is another EU
Member State or a third country.

Key to this requirement is having a clear idea of what, if any, is a product's

primary ingredient. This is defined in the FIC as the ingredient(s) of a food:

 that represent more than 50% of that food or which are usually associated
with the name of the food by the consumer
 for which in most cases a quantitative indication is required ('QUID' -
see Ingredients: lists, quantities and allergens module)

In a case where the provision applies, either:

 the country of origin or the place of provenance of the primary ingredient must

be given

Or

 the origin of the primary ingredient must be indicated as being different from

that of the food, e.g. 'made in the UK using fruit juices from various countries'

The provision, as it stands, applies to all products for which an origin is volunteered,
but which have primary ingredient(s) from a different origin. Note, therefore, that
where no whole product origin is volunteered, there is no obligation for a
primary ingredient origin to be given even if it was obtained from somewhere distant
from the site of final product manufacture.

The publication of a further Commission Implementing Regulation (an 'implementing

act') detailing further rules is awaited and this will delay the application of this
provision beyond December 2014. The Implementing Regulation may also limit the
scope of the provision to particular categories of food and primary ingredients.

Further mandatory origin

labelling

Origin labelling is mandatory for certain products under

specific legislation applying to them. In due course,
 the FIC may itself introduce further mandatory
origin labelling for particular types of products.
The Commission has produced reports on the practicalities of and consumer attitude
towards the mandatory indication of the origin of meat used as an ingredient. The
reports do not make a recommendation but are for discussion with the Council and
European Parliament. This could lead in due course to legislation requiring
the labelling of the origin of meat whenever it is used as an ingredient in foods.

Further Commission reports are pledged by the FIC into making mandatory the

origin labelling of the following foods:

 types of meat not already subject to a requirement

 milk
 milk used as an ingredient
 unprocessed or single ingredient foods
 ingredients representing more than 50% of a food

It is expected that the reports on milk as such and as an ingredient will be prioritised.

Again, legislation could follow.

Where there are proven links between certain qualities of foods and their origins,
the FIC allows Member States to introduce measures requiring origin labelling,
where this would be valued by consumers. The UK has no plans in this area, and
where such provisions are introduced they must not give rise to trade barriers.

Some foods are required, under product-specific legislation rather than the FIC, to be
marked with origin indications. Such foods include unprocessed beef and beef
products (a requirement introduced following the BSE crisis), prepacked poultrymeat
from third countries, honey, fruit and vegetables, fish and virgin and extra-virgin olive
oils. In many cases the rationale for this is the close link between the origin and the
specific characteristics of the foods.

Protected food names

Introduction
 The EU Protected Food Name (PFN) scheme is
designed to protect foodstuffs and agricultural products
which possess characteristics attributable to the
geographical area, production or processing methods
used. The system covers a wide variety of foodstuffs as
laid down in the legislation but excludes wines and spirit
drinks which are covered by separate similar schemes.
The controls, which are based around the registration of particular names to render
them 'protected', are intended to support agricultural and processing activities
associated with high-quality products. As such, they contribute to the achievement of
the EU's rural development policy objectives.

The quality schemes

Four types of protected names have been established under the general legislation:

 Protected Designations of Origin (PDO) - identify a product as originating in a

particular area which, due to its geography and associated natural and human
factors, imparts particular qualities or characteristics to that product; all the
production takes place in the defined geographical area, which in exceptional
cases can be as large as a whole country.
 Protected Geographical Indications (PGI) - identify a product as originating in
a particular area, which may be a whole country; the product's given quality,
 reputation or other characteristic must be attributable to this area and at least one
of the production steps must take place in the defined area.
 Traditional Specialities Guaranteed (TSG) - identify a product made according
to a traditional practice or produced from traditionally used ingredients; the name
must have been traditionally used to refer to the specific product or identify the
traditional or specific character of the product.

Optional quality terms - these terms must relate to a characteristic of one or

more types of food or to a farming or processing attribute which applies in

specific areas, where the term additionally has a European dimension and

PDOs
adds value to the product compared with similar products.

and PGIs: restrictions and

procedures

Protected Designation of Origin products (PDOs) must

be completely produced in the specified area using raw
materials from that area: Swaledale cheese, Anglesey
Sea Salt or Cornish Clotted Cream. Protected
Geographical Indication products (PGIs) have a
characteristic link to the defined area where at least one
production step must take place: for example, Armagh
Bramley Apples, Melton Mowbray Pork Pie or Rutland
Bitter.
 As an exception, names for live animals, meat or milk can be treated as PDOs when
the raw materials come from a geographical area larger than, or different from, the
defined area. This is acceptable if the production area is defined, there are special,
verifiable conditions there for the production of the raw materials, and the PDO was
recognised before 1 May 2004.

Restrictions on names
Generic terms - where the geographical link has been severed and the name has
become a common name for an EU product – cannot become PDOs or PGIs without
further qualification. Neither can names which could be confused with trademarks,
plant varieties, animal breeds, or names which are already protected (complete or
partial homonyms). Conversely, trademarks likely to be confused with protected
names will be refused where the PDO or PGI was applied for first.

Specification and registering

Before an application for registration of a PDO or PGI can be made, a specification
for the product must be assembled. This must include at least:

 The name to be protected in the original language only

 A description of the product
 The definition of the geographical area and substantiation of the link between
this and the quality/qualities of the product
 Evidence that the product originated in the defined area
 A description of the method of obtaining the product
 The name and address of the body verifying compliance
 Any specific labelling rules

Applications for registration can be made by groups who work with the relevant
product, although individuals can apply under particular circumstances.

Applications must be submitted to the relevant authority in the Member State. The
content of applications is prescribed and must include, for instance, the product's
specification. If, after national consultation, the Member State considers the
application meets the criteria of the scheme, it lodges an application dossier with the
Commission. Following Commission scrutiny, the application is then presented for
EU wide consultation; notice of the success or otherwise of the application is
published following time-limited procedures in the Official Journal (OJ) of the EU.
PDOs and PGIs: labelling
and protection

PDO and PGI names may be used by any business

marketing a product which conforms to the
corresponding specification and which has undergone
the required verification of compliance inspection to
demonstrate this. From 4 January 2016 products
registered under the EU PFN scheme must bear the
relevant Union logo. This must be presented in the
same field of vision as the registered name of the
product. Member States must take steps to prevent the
unlawful use of PDO or PGI names.
Labelling
Until 3 January 2016, registered names must be accompanied either by the relevant
Union symbol or by the words 'protected designation of origin' or 'protected
geographical indication'. Thereafter, the indications 'protected designation of origin'
or 'protected geographical indication' or the abbreviations PDO or PGI may also
appear on the labelling in addition to the relevant Union symbol. The labelling may
also depict the relevant geographical area and refer to the region or Member State
where the area is located.

The Union symbols can be given in colour, using prescribed reference colours, or in
black and white, but from 1 January 2016 black and white can be used only when
black and white are the only ink colours on the package. If the background colour of
the packaging is dark, the symbols may be used in negative format, or if the contrast
with background colours is poor, a delimiting outer circle may be used around the
symbol. The minimum size of the symbols is 15mm in diameter but this may be
reduced to 10mm in the case of small packages or products ('small' is not defined).
There are further specific rules on font and the wording within the symbol in each EU
language.

Where a PDO, PGI or TSG product is being used as an ingredient, the designation
or logo may be used, providing certain conditions are met. These relate to, for
example, the amount of protected name product used, the absence of
comparable ingredients, and clarity - when positioning the logo on the label - that the
whole food is not itself a PDO or PGI.

Protection
Registered names must be protected against usage with or exploitation by products
not covered by the registration. Imitation or evocation by using translations of
protected names, or words such as 'style' or 'type' are not permitted.

Exceptionally, it may be successfully argued that a new protected name jeopardises

an entirely or partly identical name. This existing name may have been used on a
product which has been marketed for at least five years before the registration
application. Where this is the case, a transitional period of up to five years allows the
existing product to continue to be marketed without complying with the conditions of
the registration. This happened to three businesses when 'Melton Mowbray Pork Pie'
was registered and seven businesses when 'Cornish pasty' was registered; they
were granted transition periods of five years and three years respectively.

TSGs
 The aim of the 'Traditional Specialities Guaranteed'
(TSG) scheme is to safeguard traditional products by
facilitating the marketing and communication of their
attributes to consumers. Eligibility depends on the
product name being traditional in terms of
the processing or ingredients used. Names incorporating
only general claims for a range of products cannot be
registered.
'Traditional'
Importantly, 'traditional' is defined as proven usage on the domestic market for a
period of at least 30 years.

Specification and registering

Before an application for TSG registration can be made, a specification for the
product must be compiled. This must comprise:

 The name to be protected

 A description of the product
 A description of the required production method including, where relevant, the
nature of the ingredients to be used
 The key elements establishing the product's traditional character

An interested group of producers will apply for registration at Member State level.
Once the product specification is agreed, national consultation takes place.
Following this, if the Member State concludes that the application meets the
requirements of the scheme, an application dossier is lodged with the Commission.
Following Commission scrutiny, the application is then presented for EU-wide wide
consultation and, following time-limited procedures, notice of the success or
otherwise of the application is published in the Official Journal (OJ) of the EU.

Labelling
Once a name is registered as a TSG, it may be used by any business marketing a
product conforming to the specification and which has undergone the required
verification of compliance inspection to demonstrate this. From 4 January 2016,
products registered as TSGs must carry the TSG logo, which must appear in the
same field of vision as the registered name. Until 3 January 2016, registered names
must be accompanied either by the TSG logo or the words 'traditional speciality
guaranteed'. Thereafter, the indication 'traditional specialities guaranteed' or the
abbreviation 'TSG' may appear on the labelling in addition to the TSG logo.

Protection
Registered names must be protected against any misuse, imitation or evocation or
any other practice likely to mislead the consumer. Member States must ensure that
no names are used on their territories which could be confused with registered
names.

Previous TSG legislation allowed registered names to continue to be used on

products not complying with the specification as long as there was no TSG reference
of any sort on the label. This provision no longer exists under the current legislation.
However, TSGs registered without reservation of the name may continue to be used
until 4 January 2023 - unless a group successfully applies in the meantime for the
reservation to be removed. Such applications must go through the normal Member
State application procedure and must be submitted to the Commission by 4 January
2016.

Optional quality terms

As well as the PDO, PGI and TSG schemes, EU

legislation establishes a scheme for optional quality
terms to help producers communicate the attributes of
their products. Such terms must add value, have a
European dimension and relate to a product, farming
or processing attribute which applies in specific areas.
Terms used to demonstrate compliance with the requirements of marketing
standards, or which are optional reserved terms under such standards, are excluded
from the scheme.
Mountain product
The Optional Quality Term 'Mountain Product' and associated conditions of use were
established in June 2014. This facilitates the communication of the value-adding
characteristics or attributes of products which qualify to use the term.

Other terms
Member States can maintain national rules on other optional quality terms, provided
that these are not in conflict with EU law.

Product of island farming

The Commission is looking into the case for the optional quality term 'product of
island farming'. This would be for products that had raw materials of island origin and
any products processed on islands. Their report looks at the pros and cons of
'product of island farming' as a means to help island producers communicate the
added-value characteristics of their products. The European Parliament and the
Council will consider the report before deciding on whether to legislate for the term.

Enforcement provisions

The EU legislation requires Member States to carry out

official controls to verify compliance with the protected
food names schemes.
Member States must designate authorities to carry out these official controls. This
must cover verification that a product complies with the corresponding product
specification, and monitoring of the use of registered names in the marketplace to
ensure that misuse and imitation are not taking place.
For products originating in the EU, competent authorities or accredited control bodies
can verify compliance with the product specification before the product is placed on
the market. For products originating in third countries, pre-market verification is done
by local public authorities and/or one or more product-certification bodies. The
names and addresses of these authorities and bodies are to be made publicly
available.

Producer groups can also be involved in enforcement activity by monitoring the use
of names and reporting back to the competent authorities. They are entitled to
develop activities that ensure compliance of a product with its specification. Names
and addresses of producer groups must be reported to the Commission and are
made public.

In the UK countries, controls take place at two stages: at producer level to verify
compliance against the relevant specification and at retailer level to ensure
protection of the registered PDO, PGI or TSG name.

There is no specific legislation enforcing the protected food names scheme in the UK
countries. The Consumer Protection from Unfair Trading Regulations 2008, the Food
Safety Act 1990 or the Fraud Act may be used to impose fines or imprisonment on
those found to have breached the rules.

Requirements

Alcoholic beverages must be marked with their alcoholic

strength where this is above 1.2%. Otherwise, only a
reduced number of the FIC mandatory particulars are
required. Additional particulars can be provided
 voluntarily. In most cases, the FIC rules for mandatory
information must be followed when particulars are
voluntarily given.
The actual alcoholic strength by volume should be given(as determined when the
product is at 20°C). For most products, the figure must be given to not more than
one decimal place and be followed by '% vol.'. Permissible tolerances are stipulated
in Annex XII of the FIC. The figure may also be preceded by the word 'alcohol' or the
abbreviation 'alc'. The minimum font size must be used for this. For wine (including
fortified wine) from fresh grapes, the figure must be indicated in whole or half
percentage points and again followed by '% vol.' The figure may be preceded by
'actual alcoholic strength', 'actual alcohol' or 'alc'. The font heights vary according to
volume but should be at least:

 2 mm: 20cl or less

 3mm: over 20cl-100cl
 5mm: over 100cl.

Beyond this, as general requirements under the FIC, beverages with more than 1.2%
by volume of alcohol must be labelled with:

 A legally compliant name.

 Any appropriate allergen information.
 Any appropriate quantitative ingredient information.
 A net quantity indication.
 A durability date for some products.
 Any particular storage conditions.
 A business name and address.
 An origin indication if the need is triggered.

There are additional requirements for spirit drinks and wine in specific

legislation applying to those products.

Beverages with more than 1.2% by volume of alcohol and containing

glycyrrhizinic acid or its ammonium salt at concentrations of 300mg/l or above

due to the addition of the substance(s) or the liquorice plant, must display a

cautionary statement. The statement 'contains liquorice - people suffering

from hypertension should avoid excessive consumption' should accompany

the legally compliant name or, if an ingredients list is voluntarily given, be

given immediately after this list.

Where the concentration of glycyrrhizinic acid or its ammonium salt is

between 10mg/l and 300mg/l, the statement should only be 'contains liquorice'

and this is not required if the term 'liquorice' is already included in the name of

the food or the ingredients list.

 Exemptions

Beverages which have an alcohol by volume above

1.2% have to be marked with their alcoholic strength
under the FIC or specific wine legislation. Otherwise,
such beverages enjoy some exemptions from the
usual FIC labelling requirements.
Nutrition labelling and ingredient listing
No nutrition information need be given for alcoholic drinks. Where given voluntarily, it
can comprise energy value alone, or the full nutrition declaration (energy value plus
amounts of fat, saturates, carbohydrate, sugars, protein and salt).

For the purposes of nutrition labelling of alcoholic drinks, energy conversion factors

of 29kJ/g and 7kcal/g must be used for alcohol (ethanol).

Ingredient listing is not required for alcoholic drinks in the UK.

Date of minimum durability

Many alcoholic drinks are exempt from the need to indicate a date of minimum
durability. These are:

 Wines, liqueur wines, sparkling wines, aromatised wines.

 Products similar to the above but made from fruit other than grapes.
 Fermented beverages other than the above, which have been obtained from
grapes or grape musts.
 Any other beverages containing 10% or more by volume of alcohol.

Nutrition and health claims

The controls on nutrition and health claims for alcoholic

beverages are very restrictive. Health claims are not
permitted at all; the only nutrition claims permitted relate
to energy or alcohol content. In some cases, specific
conditions for these nutrition claims are not set, but the
UK government has defined what conditions should
apply for consistency with parallel claims on other foods.
Special terms are defined for 'non-alcoholic' drinks with
not more than 1.2% alcohol.
Health claims
Health claims (e.g. 'red wine helps to maintain normal heart function') are not
permissible for alcoholic drinks containing more than 1.2% ABV.
 Nutrition claims
The only nutrition claims permitted for drinks containing more than 1.2% ABV are
those relating to low alcohol levels, or to the reduction of the alcohol or energy
content.

Nutrition claims permitted, but with no specific rules in EU or

UK legislation
No specific conditions of use have been set in UK or EU legislation for the following
permitted claims.

'Reduced energy'
The UK view is that the energy should be at least 30% reduced and the extent of the
reduction should be quantified on the label, e.g. 'reduced energy - 30% fewer
calories'. The claim should not include an indication of the characteristic which
makes the food reduced in energy as this is likely to constitute a prohibited nutrition
claim on alcohol. See section 3.3 of the Department of Health guidance.

'Reduced alcohol'
This claim must not be used in a way which misleadingly implies 'low alcohol' (see
below). Best practice would be that the claim is only used where the alcohol has
been reduced by at least 30% and the extent of the reduction is quantified on the
label.

'Light'/'lite'
The UK view is that these terms can be used under the same conditions as 'reduced
alcohol', with an indication that it is a reduction in alcohol which makes the drink
'light'/'lite', e.g. 'light - 30% less alcohol'. Alternatively, the terms can be used to
indicate a reduction in energy under the same conditions as for 'reduced energy'
(e.g. 'light - 30% fewer calories': see above). The labelling should not also imply that
the product is 'reduced alcohol' if this is not the case.

Nutrition claims subject to specific UK legal controls

There are national rules, which will remain in place beyond 13 December 2014, on
the following claims:

 'Low alcohol' or word(s) having similar meaning - not more than 1.2% ABV
 'Dealcoholised' - not more than 0.5% ABV and having undergone a
dealcoholisation process
 'Alcohol-free' - not more than 0.05% ABV
 'Non-alcoholic' – permitted in the composite name 'non-alcoholic wine'

(communion wine) subject to certain conditions

Definition and general

requirements

PARNUTS is the term for foodstuffs for particular

nutritional uses. These have a special composition or
manufacturing process that distinguishes them from
foodstuffs for normal consumption, are suitable for their
claimed nutritional purposes, and are marketed to
indicate such suitability. Clear examples are baby
foods, infant formulae and food for special medical
purposes.
Such foods must fulfil the particular nutritional requirements of one of the following
groups:

 Those whose digestive processes or metabolism are disrupted.

 Those who are in a special physiological condition and as a consequence
would benefit from controlled consumption of certain substances in foods.
 Infants or young children in good health.

The products covered by the first two groups may be characterised as 'dietetic' or
'dietary'. While the passing on of useful information to those with qualifications in
healthcare or nutrition is always permitted, the labelling, presentation and advertising
of PARNUTS foods must not claim or imply that they can prevent, treat or cure
human disease.

Otherwise, the general labelling rules apply to PARNUTS foods, with the following

additional rules:

 The product name must be accompanied by an indication of the product's

special nutritional characteristics (with the indication being outside the general
nutrition and health claims controls), but for food for infants and young children a
reference to the product's purpose must be made instead (e.g. a statement of the
age from which the product is suitable).
 Where the food is not subject to specific PARNUTS rules, an indication of
what gives it its special characteristics, and some nutritional data outside the
general nutrition labelling rules.
 Where the food is subject to specific PARNUTS rules,
any labelling requirements in those rules must be followed notwithstanding
general labelling rules.

Regarding nutrition and health claims, where the PARNUTS legislation has
provisions on these, they take precedence over the general nutrition and health
claim controls. For instance, the specific PARNUTS controls on nutrition and health
claims made on infant formulae constitute the only claims that may be made.

Mandatory PARNUTS labelling to describe the particular nutritional characteristics or

the purpose of PARNUTS foods (see first bullet point above) is also outside the
control of the general nutrition and health claims controls.

Specific measures
 A number of categories of PARNUTS foodstuffs have
prescriptive rules laid down in legislation. These
are infant formulae and follow-on formulae, processed
cereal-based foods and baby foods for infants
and young children, food intended for use in energy-
restricted diets for weight reduction, foods for special
medical purposes and gluten-free foods.
The legislation for the specific PARNUTS foods lays down requirements concerning
composition, mandatory labelling, appearance, advertising and packaging.

For the general labelling requirements for infant formula and follow-on formula,

the labelling must be designed to provide the necessary information about the
appropriate use of the product so as not to discourage breast-feeding. It must not
contain the terms 'humanised', 'maternalised', 'adapted' or any similar
term. Infant formula and follow-on formula must be labelled in such a way for
consumers to clearly make a distinction between the products.

Before placing an infant formula on the market, food business operators must notify

the Department of Health and provide a copy of the product label.

For foods formulated for use in energy-restricted diets for weight reduction, they
must be labelled as 'total dietary replacement for weight control' or 'meal
replacement for weight control'. It is prohibited to label, advertise or present these
products in a manner which refers to the rate or amount of weight loss which may
result from their use.

Foods for special medical purposes (medical foods) are specially processed or
formulated to meet the dietary needs of patients, whose needs cannot be achieved
by modification of the normal diet (including food supplements and fortified foods), or
other food for particular nutritional uses. Like other PARNUTS foods, these foods
must not state or imply they are to prevent, treat or cure disease.

In addition to the mandatory labelling requirements of the EU FIC, other specific

information must be provided:

 They must be used under medical supervision.

 Whether they are suitable for use as the sole source of nourishment.
 Suitability for certain age groups.
 That they pose a health hazard when consumed by consumers who do not
have the diseases, disorders or medical conditions the product is intended for.
 The statement "For the dietary management of 'X'", where 'X' is the specific
disease, disorder or condition for which the product is intended.

Before placing a medical food on the market, food business operators must notify the
Department of Health and provide a copy of the product label.

PARNUTS foods that are specially produced, prepared and/or processed to meet the
special dietary needs of people intolerant to gluten are subject to specific rules
for labelling as 'gluten-free' (must not exceed 20 mg/kg of gluten) or 'very low gluten'
(must not exceed 100 mg/kg of gluten). It is prohibited to label infant formula and
follow-on formula with these claims as the legislation prohibits the use of ingredients
containing gluten in their manufacture.

Changes to PARNUTS
controls

New legislation will be introduced in 2016 replacing the

rules on PARNUTS foods with a new Regulation on
Foods for Specific Groups. The Regulation covers food
for infants and young children (infant formula, follow-on
formula and weaning foods), food for specific medical
purposes, and total diet replacement for weight control.
Under the new approach, food for other population
groups will be regulated as regular foodstuffs under
general food law.
The new EU Regulation will establish compositional and information requirements for
these foods. Currently the Regulation lays down general requirements. In terms
of labelling, there are only general requirements established for not misleading the
consumer or attributing to the food the property of preventing, treating or curing a
human disease.

There are additional requirements for infant formula and follow-on formula which

requires the labelling, presentation and advertising to be designed so as not to
discourage breastfeeding and must not include pictures or text idealising the use.

The legislation laying down the detailed rules for these food categories will apply in
the UK by 20 July 2016. The additional rules to be adopted on labelling, presentation
and advertising will include the authorisation of nutrition and health claims, the
requirements concerning promotional and commercial practices relating
to infant formula and information on appropriate infant feeding practices.

A precise date for the application of these detailed rules is not specified.

The Commission is also to consider by July 2015 the need for controls on 'growing
up milks' and sports foods.

The rules on use of the statements 'gluten-free' and 'very low gluten' will be
incorporated into the EU FIC. Further consideration will be given to how people that
are intolerant to gluten are adequately informed of the difference between a food that
is specially produced, prepared and/or processed in order to reduce the gluten
content and other food that is made exclusively from ingredients naturally free of
gluten.

Voluntary information
 Even when a pack is exempt from particular
requirements of the FIC, these may be given voluntarily.
When this is the case, many of the FIC rules applying to
mandatory declaration must be followed. All voluntarily-
provided information must comply with certain principles
in relation to its fairness and prominence.
Information volunteered by any means to the final consumer about a food must not
be misleading, ambiguous or confusing and, where appropriate, must have a sound
scientific basis. The FIC commits the Commission, with no stated deadline, to
introduce rules to ensure that voluntary information given in the following four areas
complies with these requirements:

 information about possible cross-contamination with allergens

 information about suitability for vegetarians or vegans
 information in the form of sets of reference intakes for specific population
groups beyond the set already given in the FIC
 information on the absence or reduced presence of gluten in food.

Further areas for harmonisation of voluntarily given information may be identified in

due course.

The FIC establishes the clear principle that voluntary information must not be

displayed to the detriment of the space available for mandatory information.

Voluntarily-given mandatory particulars

Specific product types may be exempt from the requirement to give
certain mandatory particulars, e.g. drinks with an ABV above 1.2% are not required
to be marked with an ingredients list and unprocessed products that comprise a
single ingredient or category of ingredients are not required to be marked with
nutrition information. However, when ‘mandatory particulars’ are volunteered, many
of the rules applying to their compulsory provision must be followed. What is not
required is for the presentational rules to be followed; the minimum font size, for
instance, does not have to be respected, other than for the voluntary, front of pack
nutrition declaration. When information is provided on a voluntary basis on food sold
by distance selling, the specific rules regarding its provision before the purchase is
concluded and again at the moment of delivery do not apply.
 National measures

The FIC is an EU regulation, directly-applicable across

all EU Member States.
It is not possible for individual Member States to apply their own national measures
in areas covered (‘harmonised’) by the FIC unless specifically authorised by EU law
and free trade is unaffected. National measures can be applied in non-harmonised
areas but again, free trade cannot be impeded except when additional mandatory
particulars are applied to particular types of foods on prescribed grounds.
The FIC allows Member States to adopt national measures requiring the provision of
food information for non-prepacked foods except that the provision of the mandatory
particular concerning allergens is compulsory.

Member States may adopt national measures requiring additional mandatory

particulars for specific types of foods justified on grounds of at least one of the
following:

 protection of public health

 protection of consumers
 prevention of fraud
 protection of industrial and commercial property rights, indications of
provenance, registered designations of origin and the prevention of unfair
competition.

These grounds could enable additional mandatory origin indications to be introduced

by particular Member States, if there was a proven link between specific qualities of
a food and its origin. The UK has no plans in this area.
The imposition of these mandatory national measures is subject to notification to,
and acceptance by, the Commission, assisted if necessary by a committee of
representatives of the Member States.

Where foods are offered for sale to the final consumer or caterers in non-prepacked
form (i.e. without prepackaging, or packed on the sales premises at the consumer’s
request or ‘prepacked for direct sale’ (undefined in the FIC)), only the provision of
allergen information is mandatory on an EU-wide basis. The provision of all
other FIC information is at Member States’ discretion. The means of provision and
the form of expression and presentation of information (including allergen
information) for non-prepacked food is also at Member States’ discretion.

As far as England, Scotland, Wales and Northern Ireland are concerned, details of
their respective national measures on food information are included in the four
countries’ Statutory Instruments enforcing the FIC.

Enforcement legislation

The Food Information Regulations 2014 and their

Scottish, Welsh and Northern Irish equivalents (‘FIRs’)
enforce the FIC in the four UK countries. They also
indicate where the UK countries are taking advantage of
permitted derogations from FIC provisions and what
food information is to be required in the UK countries
under national measures.
Provision is made for the eventual revocation of the Food Labelling Regulations
1996 as well as for other more minor revocations and consequential amendments.
Enforcement
In England, Wales and Northern Ireland the FIRs formally enforce many of the
provisions of the FIC via the serving of improvement notices, once the well-
established informal procedures have been exhausted. The FIRs apply the
improvement notices already provided for in Section 10 of the Food Safety Act 1990
and Article 9 of the Food Safety (Northern Ireland) Order 1991 for this purpose.
Failure to comply with an improvement notice is an offence. Appeals against an
improvement notice are to the First-tier Tribunal in England and Magistrates Courts
in Wales and Northern Ireland. Enforcement in Scotland is universally via the
criminal law, as it is in the other three countries of the UK for selling a food after its
‘use by’ date and may also be for breaches of the rules on the provision of allergen
information.

Derogation: milk and milk products

Milk and milk products (undefined) presented in glass bottles intended for reuse are
exempted from all the requirements of the FIC in the UK countries.

Derogation: minced meat

In the UK countries the compositional criteria for different types of minced meat laid
down in the FIC do not have to be adhered to if a ‘national mark’ comprising a
depiction of a square and the words ‘For UK market only’ are used on the labelling of
a product. However, the use of the national mark does not allow the fat content and
collagen/meat protein ratio of lean minced meat to be varied. Minced meat described
as ‘lean’ would not carry the national mark and would need to have a fat content and
a collagen/meat protein ratio of not more than 7% and 12% respectively. It could be
described simply as ‘lean’ but not, for instance, ‘extra lean’.

All food sold loose

Allergen information for food sold loose to consumers or caterers can be provided in
any manner a business chooses including, if stated to be available in this way,
verbally.

Food sold loose to consumers or caterers, but not by caterers

The above food must be marked with a legally-compliant name. In addition, such
food which is a meat product (with exceptions) must be marked with a quantitative
indication for the meat, meaning meat as defined for the purposes of use of the
generic term ‘meat’ in ingredient listing. These indications can be given via a label,
notice or ticket visible where the food is chosen for purchase.
Net quantity

One of the mandatory particulars required for prepacked

foods under the FIC is an indication of net quantity, to be
given in metric units. Units of volume should be used for
liquids and of mass for other products. There are
exemptions, and specific EU weights and measures
provisions continue to apply unprejudiced by the FIC.
Units
The units to be used are litres, centilitres, millilitres, kilograms or grams as
appropriate.

Prepackages containing further individual packages

Where a prepacked food contains a number of identical, individually prepacked inner
items, the quantity indication should comprise the quantity of an inner item and their
number. If both of these can be clearly seen from the outside anyway, this fulfils the
requirement.

Where the individual prepacked inner items are not regarded as units of sale (e.g. a
cake kit comprising a mix and separate icing) the net quantity indication should give
the total quantity and total number of inner packages.

Food in a liquid or with a glaze

Solid food, presented in a liquid medium which is not essential to the nature of the
food and therefore not a decisive factor for purchase, should be marked with a
drained weight as well as a total net quantity. Such liquid media may be frozen and
include fruit or vegetable juices in the case of fruit or vegetables, water and aqueous
 solutions, but not oils. The declared weight of glazed foods, e.g. prawns, should be
exclusive of the glaze.

Exemptions
The net quantity declaration is not mandatory for prepacked foods:

 which are subject to considerable losses in their volume or mass and are sold
by number or weighed in the presence of the purchaser
 the net quantity of which is less than 5g or 5ml (unless herbs or spices)
 normally sold by number, with the number declared unless counting is clearly
possible from the outside

On the basis of the third bullet point, there are several types of prepacked foods
which can be sold either by number or weight in the UK. These include cereal biscuit
breakfast foods, flour confectionery, eggs, rolls and small loaves weighing less than
300g, meat or fish pies, puddings and flans, sausage rolls, sandwiches and a range
of 'countable' fruits and vegetables.

Date indications

Most prepacked foods are required to be marked with a

'best before' or 'use by' date, as appropriate. Which date
is required and the exact wording and level of detail
which is given depends on the type of food, how it is
presented for sale and the duration of its shelf life.
Some prepacked foods must be marked with a date of
freezing.
Best before dates
The FIC uses the term 'date of minimum durability' to refer to a 'best before' date,
this being the date until which the food retains its specific properties when properly
stored. The basic requirement is for the indication of 'best before' accompanied by a
day, month and year in that order in uncoded form. Foods which will not keep for
more than 3 months may be marked with just a day and month, those with a life
between 3 and 18 months may be marked with 'best before end' and just a month
and year, and those with a life of more than 18 months may be marked with 'best
before end' and just a year.

Some foods are exempt from minimum durability marking; these include fresh fruit
and vegetables, wine and some other alcoholic beverages, very short life bakers'
wares and some very long life products such as salt and sugar.

Use by dates
In the place of a durability date, foods which are microbiologically highly perishable
and therefore likely after a short period to constitute an immediate danger to health,
should be marked with a 'use by' date. The words 'use by' must be accompanied by
a day, a month and possibly a year in that order in uncoded form. Use by dates must
be indicated on individual prepacked portions where these exist within the complete
unit which is actually sold.

Date of freezing
Frozen meat, frozen meat preparations and frozen unprocessed fishery
products must be marked with a date of freezing or date of first freezing if the
product has been frozen more than once. This should comprise the words 'frozen on'
accompanied by a day, a month and a year in that order in uncoded form.

Signposting
In all cases, rather than the date being with the explanatory words, the words can be
accompanied by a reference to where the date is given elsewhere on the labelling,
e.g. 'best before end - see base of pack'.

Storage conditions and

instructions for use
In all cases where prepacked foods need to be stored or
used in a particular way, this should be indicated on
their labelling. This includes the giving of post-opening
storage instructions and a time limit for consumption
where appropriate.
Storage conditions
Storage instructions for the unopened food are an absolute requirement for foods
marked with a use by date, to enable the food to achieve the stated date in a safe
condition. There are no further stipulations regarding the detailed content of the
instructions but, when followed, they must ensure that the food is safe to eat up to
the end of its stated life. For foods marked with a best before date, storage
instructions should be given for the unopened food if any particular storage
conditions need to be employed for the food to retain its specific properties until the
stated date.

Instructions for use

Where it would otherwise be difficult for consumers or caterers to make appropriate
use of a food, instructions for use should be given.

Manner of giving instructions

Words and numbers must primarily be used for imparting storage and use
instructions, but these can be augmented by pictures and symbols, such as
depictions of ovens, rising steam, ice crystals etc.