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Since April 1, 2020, the Implementing Regulation (EU) 2018/775, which lays down the rules for applying Article 26(3) of Regulation (EU) 1169/2011, has been in force. In particular, this implementing regulation on voluntary origin labeling aims at how to label the origin of the primary ingredient when it is not the same as that of the food.
Meanwhile, a Commission communication was published on Jan. 31, 2020, answering questions about some aspects of voluntary origin labeling. For example, the statement ''Produced in [country]'' is considered an indication of origin and the origin of the primary ingredient must be taken into account. In contrast, the statement ''packaged in'' is not considered an indication of the country of origin or place of provenance of the food. It has also been established that generic/usual designations do not fall within the scope of the implementing regulation if the designations are not generally considered an indication of origin. An example of a generic/usual designation is ''frankfurter'' (sausage). The Commission also provides further clarification on the interpretation of the following aspects, among others: indication of the food business operator, brand names, name of the food, place and presentation, distinguishing the primary ingredient and geographical levels. The Commission communication also makes it clear that consumers should not be misled by voluntary origin labeling. Whether this is the case must be assessed on a case-by-case basis.
You can read the Commission's full communication at this link: https://eur-lex.europa.eu/legal-content/NL/TXT/?uri=uriserv:OJ.C_.2020.032.01.0001.01.NLD&toc=OJ:C:2020:032:TOC
Do you have questions or need support evaluating your labels? We are happy to help. You can contact us at +31 (0)30 - 65 66 010 or email info@precongroup.com
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