What about sunflower oil and the label? An update.

The food industry warned about it: sunflower oil is running out. The scarcity means that there is almost no bottle left on the shelves in the supermarket. And also that more and more manufacturers are running out of sunflower oil stocks. The label adjustment is a huge administrative job. What additional work awaits companies and manufacturers?

Sunflower oil is used in many different foods, such as margarine, meat, meat substitutes, ready meals, spreads and bakery products. This forces many producers to find an alternative in their recipes, which creates additional challenges. Not only must the raw material be replaced in the recipe, the ingredients on the label must also be changed. Indeed, Regulation (EU) 1169/2011 states that vegetable oil in the list of ingredients must be compulsorily supplemented with its origin.

A change in recipe of a product has a standard lead time, depending on the complexity of the change and the type of packaging. However, producers are now faced with a fait accompli of missing a raw material. Thus, if this raw material cannot be quickly and legally replaced with an alternative raw material, these products can no longer be produced.

European and national governments are aware of the impact for food producers and the market. This is why they have sought bridging measures at different levels for the lack of raw materials due to very exceptional situations (e.g. War). Belgium is setting up a task force for this purpose. The FPS Economy, together with the FPS Public Health and the FASFC, developed an action plan for the labeling of sunflower seeds and products derived from them. This has been discussed with various stakeholders and industry associations such as Fevia and Comeos.

Food safety rules, of course, remain unchallenged since they were created for the protection of consumer health.

Below we would like to briefly explain the action plan and what is expected of you as producers (listed as operators in the text below).

The action plan: reporting, labeling and informing

1. Report

All operators must inform the FPS Economy, the FPS Public Health and the FASFC of changes in the composition of their products. This can be done through the online platform:

The listing below shows what information operators must report:

• Company and product name
• Date of change
• Ingredient being replaced and the ingredient being replaced
• The lot number and/or packaging of the products involved
• Any change in nutrition labeling

2. The label

In terms of labeling, producers are advised to change the label as soon as possible, and if it can be done immediately, to do so.

Another option is to use stickers, stamps or ink jets if information on the label needs to be modified. In doing so, producers must be attentive that the information is accurate, in a clear place and that the consumer cannot be misled.

For products where there is an addition of an allergen, it is recommended to review the label completely. Since this is not always possible immediately, there is also the possibility of using a sticker. The sticker can, for example, contain the new list of ingredients pasted over the original list (here, care must always be taken to avoid confusion or miscommunication to the consumer).

3. Inform

In addition to reporting the changes and possibly changing the label, companies should inform consumers through various channels. This can be done in a variety of ways:

• Post posters in highly visible places in the various outlets; (https://economie.fgov.be/sites/default/files/Files/Entreprises/etikettering-affiche-a3.pdf). In this way, consumers will be alerted to the changes in certain products and what it all means.
• Info page on the website of the FPS Economy; This will include an overview of all measures related to the labeling issue. An overview will also be available with all products that have been modified.
• Awareness campaigns set up through newsletters, social media, mailings, ...

Meanwhile, other European countries and the United Kingdom have also published statements on flexible enforcement on labels where sunflower oil has been substituted for another raw material.

Update: May 20, 2022