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Allergens on the label? These are the labeling requirements

Many operators in the hospitality industry appear not to be complying with stated requirements for allergen disclosure. Providing information about allergens is part of the legal labeling requirements. The requirements for providing legal product information, depend on the type of packaging and the destination of the food.

Regulation (EU) No 1169/2011 distinguishes between prepackaged food, non-prepackaged food and bulk packaging. Pre-packaged food must show all mandatory information, as described in Article 9 of Regulation (EU) No 1169/2011. When the product is sold non-prepackaged, it is not mandatory to put all the legal items on the label. Bulk packages, sold business-to-business, are also subject to different regulations.

Prepackaged food products

A prepackaged product is intended for the final consumer. When purchased, the food is contained in the packaging with which it is sold to the consumer. Prepackaged products are usually sold in the supermarket or through a web shop. With these products, the following legally required items must be listed:

  • a legal designation;
  • the list of ingredients, including percentages of ingredients that stand out in words or pictures;
  • the allergens present;
  • a net quantity;
  • the date of minimum durability or use-by date;
  • a usage/storage recommendation;
  • The name or trade name and address of the manufacturer, packer, importer or seller;
  • the country of origin or place of provenance, if the consumer may otherwise be misled;
  • an instruction manual, if the product is difficult to use without an instruction manual;
  • the alcoholic strength by volume, if greater than 1.2%;
  • a nutritional statement;
  • the lot code, which allows the food to be identified and traced.

This information must appear on the label or a tag attached to the package. All legally required information must be given in the language of the country where it is sold.

Non-prepackaged foods

Non-prepackaged foods are products offered without packaging to the final consumer or large caterers. This includes foods packaged for immediate sale (within 24 hours) or packaged at the point of sale at the consumer's request. Examples of non-prepackaged foods are:

  • unpackaged bread, meat or vegetables
  • meats weighed and packaged in the supermarket
  • nuts packed at a market stall

For non-prepackaged products, only the following needs to be stated:

  • the legal name
  • the allergens present

This information may be written or electronic. One can think of using shelf tags, information boards or allergen symbols.
The information may also be provided verbally, for example by indicating to the customer that the staff is aware of it. It is important here that the customer knows that the information is available and in what manner.

Bulk Packaging

Finally, some foods are traded at a stage before sale to the final consumer, or are intended for further processing by a food company. These are bulk packages. A bulk package is a box, crate or plastic container in which large quantities or multiple products are transported. The following information should be included with these products:

  • a legal designation
  • the date of minimum durability or use-by date
  • a usage/storage recommendation
  • the name or trade name and address of the manufacturer, packer, importer or seller
  • the lot code, which allows the food to be identified and traced

This information must appear on the label or tag of the outer packaging in which the food is marketed. In addition, all other legally required information must be available at or prior to each delivery (on paper or digitally). Again, all legally required information must be listed in the language of the country where it is sold.

Allergen information always required

Allergen information should therefore be mandatory in all cases. This information should be directly on the packaging only for prepackaged foods. For all other products, the food operator must ensure that the information is properly made available. It is also important that operators and employees in the catering industry have sufficient product knowledge so that they can properly inform the customer. In addition, allergen information will need to be updated with every recipe change so that it is always up-to-date.

Don't miss any legislative changes?

Our Food Law Guide is the solution for you. For more information, contact us at +31 (0)30 - 65 66 010 or email foodlawguide@precongroup.com.

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