Food Standards Agency
Saturday 4 July 2009
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Listen to this siteWednesday 7 May 2008
Meeting at the MRC Centre, Llandrindod Wells
The stakeholder event was held in order to explain in more detail the scope of the Commission’s proposal out to consultation and an opportunity to capture the specific views of Welsh stakeholders and therefore inform Agency policy decision and UK lines, ahead of negotiations later this year.
The event was attended by around 20 stakeholders with enforcement officers, large retailers and smaller businesses all represented.
The event was chaired by Steve Wearne, Director, FSA Wales. Speakers included:
Theresa Ekong began by explaining that the Commission’s food information proposal which was adopted on 30 January 2008 covers food information at all stages of the food chain. It brings together general and nutrition labelling for all pre-packed foods and also covers the requirements for foods sold non pre-packed (loose and pre-packed for direct sale). The proposal is the first step in the process of negotiating new regulations which will be directly applicable in Member States.
The aims of the proposal are simplification and consolidation of existing texts, while ensuring consumers have sufficient information to make informed choices. The Commission proposal adopts a principles approach governing mandatory information which is broadly similar to labelling principles developed by the UK last year, the aim of which is to ensure that mandatory requirements are proportionate and balanced.
There followed a session which outlined the background to and content of the proposal. Discussion sessions on key issues followed which focussed on nutrition labelling, label clarity, country of origin labelling, non pre-packed foods, distance selling and alcoholic drinks. The discussion was lively with full participation from attendees and a number of valuable comments were captured which will be reported as part of the Welsh response to the UK-wide consultation.
The following notes represent the key points raised by delegates as a consequence of each of the sessions.
General points
Delegates noted that consumer expectation would be different depending on product type and questioned therefore whether having the same requirements for both complex and simple products was appropriate.
It was emphasised that the proprietary name of the food and the legal name of the food should be clearly presented, regardless of other information required on the front of pack.
There was a need for more clarity on a number of definitions in the proposal, for example, 'front of pack', 'field of vision', and 'principle fields of vision'.
There was some concern that if the intention of the proposal is to standardise food labelling across the European Union, that the proposed national schemes hinder this overall aim.
Nutrition labelling
Delegates flagged up that the definition of sources of reliable nutrition data within the proposal was too prescriptive.
A more principles-based approach to the methods of calculating declared energy values was preferred by those present.
Particular issues raised by delegates that needed to be covered in legislation or guidance were (i) the basis for calculating presumed salt content from sodium; and (ii) how to deal with seasonal variability in natural products such as honey when quoting average nutritional information.
Label clarity
Delegates generally felt that there was more to label clarity than just font size (whether described in terms of print size or absolute size) and that this part of the proposal was not sufficiently principles-based.
Information that was clear, legible, and visible to the consumer at point of sale was key, and there was support for information presented in one uninterrupted view.
One suggested approach would be to embody these general requirements in legislative principles and then to develop supporting statutory guidance, possibly analogous to the industry guides that are prepared under food hygiene legislation.
Care should be taken when describing significant contrast and consideration needed to be taken of colour blindness.
Country of origin labelling
More clarity was needed over the triggers for separate country of origin labelling (the fictional example used in discussion was a kiwi yoghurt where, if country of origin labelling was used, it might need to claim 'made in Wales from Welsh milk and kiwi fruit imported from different countries').
There was particular confusion over the definitions of principal ingredients, significant ingredients and so on and their relevance to country of origin labelling.
There was general agreement that consumer interests are primarily focussed on the origin of meat and of meat in meat products. It was suggested that a more proportionate approach would be to impose separate, more stringent requirements in these circumstances – cross referenced for consistency with current and continuing vertical, commodity specific legislation such as that required for labelling of beef – with less onerous requirements for other products. These was concern that country of origin labelling claims such as 'produced in the EU' should still be permitted to continue to allow for flexible sourcing of ingredients.
The issue of food miles was raised. Within the context of the proposal’s principles-based approach governing mandatory food information, food miles may not (yet) qualify under the ‘majority interest’ provisions and would therefore fall when one of the general criteria were applied to deciding whether it should be the subject of on-pack labelling. However, there were current real examples, such as eggs laid in Cornwall that were transported to be packed in Monmouth and then transported back to Cornwall to be sold as 'Cornish eggs'. There was therefore concern that this description could be misleading, given how far the eggs have travelled before being sold.
Food sold loose/allergy labelling
There was widespread support for retention of the national provisions relating to pre-packed food for direct sale and general agreement that it was sufficient for such food to be labelled with the minimum statutory information.
On allergen labelling of food sold non pre-packed, there was general support for a best practice approach through guidance rather than a prescriptive labelling approach, as recommended by the Food Standards Agency (FSA) and other interested parties such as the Anaphylaxis Campaign.
It was suggested that ingredients that are allergenic should be included in the name of the food. This was particularly important in the food service sector where descriptions are commonly far less informative than legal names.
There was one suggestion that, to support a best practice approach, there may be a requirement for general statutory notice making people aware that food may contain allergens and prompting people who had concerns to ask about the ingredients in products that were not pre-packed. Others were concerned that such a requirement for general statutory notice may lead to notices that were ignored such as those for GM food and irradiated food.
There was support for FSA guidance notes for caterers to be available in other languages, notably those directed at Indian and Chinese takeaways.
Distance selling
Several delegates questioned the proposed list of food information particulars to be mandatory at the point of sale for distance selling.
Particular concern was given to the quantity of certain ingredients or categories of ingredients which is omitted from the proposed list.
Delegates felt this was sufficiently important to be required in advance of purchase through distance selling as it informs purchase decision.
The focus of the discussion was on internet sales although several people stressed that any legal provisions needed to recognise other means of distance selling such as by telephone.
There were some concerns (not universally shared) about the burdens that would be placed on small and micro businesses, particularly of handmade products which tend to get a large proportion of repeat business. One solution for such businesses might be to have a general statement on their websites or distance selling literature to say that information on ingredients, allergens and so on was available on request from a designated contact point.
The issue of takeaway menus delivered to homes was raised – as these were foods that were both sold by distance selling, and food sold non pre-packed.
Feedback from the day was uniformly positive; delegates welcomed the opportunity to become involved during the early stages of proposed new food labelling legislation when stakeholders can influence future Agency policy decisions and UK negotiating lines. Those present confirmed their interest in continued meetings and invitations to comment on the proposal as it takes further shape.
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