General Food Labelling Review A UK Industry Perspective Clarity and Legibility Michael Hunt Food & Drink Federation (UK)

The growing pressure on label space Classic tension between label space and amount of legally required information Labelling Directive highly successful, clear and balanced Some key additions made such as for allergen ingredient labelling Others of less obvious importance Additionally requirements from other legislation Environmental pressure to reduce packaging

Development of UK food labelling requirements Up to 1930s Broad principles on safe food and preventing fraud. Specifics on labelling with: customary name or a registered trade mark quantity Little (voluntary) labelling on composition. Commodity standards on preserved milks. Range of pre-packaged foods widening More ingredients available

Development of UK food labelling requirements 1943 False labelling and advertising offence (nature, substance and quality) Minister of Food to make regulations on pre-packing, advertising and composition. During 1940s About 20 compositional standards introduced for a range of foods. Several commodity codes of practice were introduced that linking composition to product names of, e.g. soft drinks, drinking chocolate, fish pastes and spreads, canned soups, flour mixtures and vinegar.

Development of UK food labelling requirements 1946 Various terms defined (retail sale, pre-packed, label). Particular requirements for pre-packed foods included: Name and address of the packer or labeller (or registered trademark) Designation of single ingredient foods For compound foods, common or usual name (if any) of the food and designation of each ingredient in descending order of weight Need not declare water Minimum quantity marking Rules for claims on vitamins and minerals. Some foods wholly or partly exempt.

Development of UK food labelling requirements 1970 – Requirements significantly extended. Mainly: Many more terms defined Product naming in more detail Ingredient listing amplified: dried products, mixtures of fruit and vegetables, compound ingredients, and permitted food additives. A few generic descriptions allowed (e.g. vine fruits, fruit acids, emulsifying salts, edible oil or fat) More claims controls regarding energy, calorie, protein, vitamins, minerals, and slimming claims. Medicinal and restorative claims banned. Detailed provisions applied to ‘manner of marking’ legally required information: visibility, positioning, colour and letter height.

Development of UK food labelling requirements 1980 – Labelling Directive 79/112/EEC implemented, including: Product naming refined (trade marks, brand names and fancy names no longer substitutes) Addition of: date marking, storage conditions, conditions of use, origin labelling (if needed), instructions for use Ingredient listing more detailed. Added water to be declared Partial exemptions: small packages; food for direct sale; food sold loose ‘Manner of marking’ provisions less onerous. Definitions of ‘additive’ and ‘processing aid’ Category names for permitted additives plus E numbers or names. Conditions applied to use of certain words and descriptions e.g. butter, cream, dietary, flavour, milk, alcohol-free etc. Some exemptions for foods with EU vertical directives.

Development of UK food labelling requirements 1984 – Further EC provisions introduced on: Indications of physical condition or treatment. Restrictions on claims on Parnuts foods, food for babies and young children, and on diabetic, slimming, medicinal, protein, vitamin, mineral, polyunsaturates, cholesterol and energy claims. 1994 Nutrition labelling (90/496/EEC). Application voluntary unless nutrition claim made but “commercially required”

Development of UK food labelling requirements 1996-2005 – more EU provisions added, including: QUID Additional labelling for: foods containing sweeteners polyols consumption warning foods packaged in certain gases glycyrrhizinic acid in confectionery and drinks caffeine in high caffeine drinks non-heat treatment of raw milk. More detailed ingredient listing (removal of 25% rule) Allergen labelling Definition of “meat” GMO labelling Some requirements from vertical legislation remain

Clarity and Legibility Newer factors Multilingual labelling: now firmly-established in EU market. not always optional economic advantage costs of not being able to do it Legal requirement to minimise packaging Any more or less information requirements from EU review? Need principles on priority information to be included an agreed approach on visibility and clarity

FSA Guidance on Clear Labelling Key aspects Grouping of information Print size and clarity Increasing printable area 2005 survey of compliance Many products (87%) not complying with guidance, but with little or no effect on clarity Confirms clarity has multi-factorial basis and its assessment is somewhat subjective. Indicates that detailed legal specification is not appropriate. Suggests that wide agreement on guidance is appropriate, to enhance consistency of approach.

Consumer Food Labelling Requirements 2006 FSA research on food labelling requirements To determine: what information consumers want and need to see what should be provided on packs what could be delivered some other way Results High priority information, to dominate front of pack was chiefly: Brand name or brand identifier (product recognition top priority) Name of food Net quantity Datemark Some form of illustration

Consumer Food Labelling Requirements “Overall the findings indicate that there will be a benefit in encouraging industry to conform to certain principles in grouping and separating information while retaining their own design styles, and taking some specific information off pack.”

Key issues for clarity and legibility Presentation of statutory information on pack to achieve easy visibility; Font size and colour/contrast to achieve clear legibility;

Going Forward This is a collaborative issue: Legislators: To preserve some information exemption for small and irregularly shaped packs etc to adopt principles to protect the label from all but priority information requirements Not to over-specify legibility criteria Industry with other stakeholders to consider EU level consensus guidance on key factors in label legibility, to support the legal principles of ‘easily visible’ and ‘clearly legible’ All parties to bear in mind the cost/benefit implications