Labelling study reveals mixed readiness for FIC

With the main elements of the Food Information to Consumers EU 1169/2011 Regulation (FIC) due to come into effect in less than 7 months’ time, a snapshot analysis of the industry’s journey toward compliance has revealed some common labelling issues and misconceptions in the products tested.

GS1 UK commissioned Camden BRI to provide a snapshot of progress by analysing a basket of products. 20 samples were selected for the basket, with five each from the prepared ready meals, meat, confectionery and flour and bakery wares categories. Four of the 20 products tested were compliant, with a further four only requiring minor changes to reach it.

The mandatory requirements of FIC are applicable to 12 key information areas, and achieving compliance in some of these is necessarily more complex than for others. It is at the actual point of interpreting some of these changes that issues appear to be arising for affected businesses, which could become very costly to correct and lead to enforcement action after the regulation comes into effect.

The common issues and misconceptions identified from the analysis include:

·         Declaring nutrition information – A range of layouts were found in the survey. It remains the case that nutrition formats seen on some imported products from outside the EU are not acceptable on products sold in the EU and may not co-exist on a label with the format set out in FIC where there is a new ordering of nutrients and salt must be declared in place of sodium.


·         Country of origin statements– declaring the country of origin or place of provenance on foods is one of the more complex areas of FIC, as the requirements can vary in accordance with the product type and ingredients and there is legislation following FIC that could very well change the current understanding of what is required. This would appear to be posing a particular challenge for meat businesses; none of the statements used on the products tested were found to be fully compliant with FIC at the time of the survey.


·         Multilingual labelling – FIC sets out a minimum font size for use on product labelling, which can represent a significant challenge for smaller products. This was particularly found to be the case where multiple languages are declared on a single label.

Gary Lynch, CEO at GS1 UK comments, “Compliance with FIC is proving to be a complex process for industry, as it comprises many different areas and can involve multiple teams and in some cases thousands of products, each with different size labels and different requirements specific to the ingredient type. We recommend that all businesses involved in the supply and sale of food and drink products aim to be compliant well in advance of the 13th December deadline, to help avoid bottlenecks and ensure contingency measures can be put in place should final labelling errors be found.“


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