Presented by Phil Dalton of Legal Impackt REGULATION [EU] NO 1169/2011 ON THE PROVISION OF FOOD INFORMATION TO CONSUMERS INTERPRETATION AND GUIDANCE

A Sun Chemical Company Slide MANDATORY PARTICULARS ACCOMPANYING THE NAME OF THE FOOD - ANNEX VI Meat products, meat preparations and fishery products combined together by other ingredients shall bear the following indication: ‘formed meat’ and ‘formed fish’ Foods frozen before sale and sold defrosted - The name of the food shall be accompanied by the designation ‘defrosted’ What constitutes an indication of the presence of added water? [Basted? Bacon? Stock?] What does ‘accompanied by’ mean? FOODS WHICH ARE EXEMPTED FROM THE REQUIREMENT OF THE MANDATORY NUTRITION DECLARATION – ANNEX V Unprocessed products that comprise a single ingredient or category of ingredients "unprocessed products" means foodstuffs that have not undergone processing, and includes products that have been divided, parted, severed, sliced, boned, minced, skinned, ground, cut, cleaned, trimmed, husked, milled, chilled, frozen, deep-frozen or thawed; e.g. Whole mushrooms with <1% added Parsley? e.g. Beef Steak with Pepper <1% Pepper INTERPRETATION – SPECIFIC WORDS AND PHRASES 2

A Sun Chemical Company Slide INDICATION AND DESIGNATION OF INGREDIENTS – ANNEX VII May be grouped together in the list of ingredients under the designation ‘vegetable oils’ May be grouped together in the list of ingredients under the designation ‘vegetable fats’ Vegetable Oils and Fats [Coconut Oil, Palm Kernel Oil, Palm Oil, Sunflower Oil, Rapeseed Oil, Shea Fat] ? DESIGNATION OF CERTAIN INGREDIENTS BY THE NAME OF A CATEGORY – ANNEX VII All types of crumbed baked cereal products ‘Crumbs’ or ‘rusks’ as appropriate – plural? All species of fish where the fish constitutes an ingredient of another food and provided that the name and presentation of such food does not refer to a specific species of fish. Voluntary indication of origin by species? NAME OF THE FOOD – ARTICLE 17(1) The name of the food shall be its legal name. In the absence of such a name, the name of the food shall be its customary name, or, if there is no customary name or the customary name is not used, a descriptive name of the food shall be provided. INTERPRETATION – SPECIFIC WORDS AND PHRASES 3

A Sun Chemical Company Slide Use By Date - Annex X Shall be preceded by the words ‘use by...’ Followed by the storage conditions which must be observed The ‘use by’ date shall be indicated on each individual prepacked portion INTERPRETATION - LAYOUT 4

A Sun Chemical Company Slide Nutrition Format - Article 34(2) Shall be presented, if space permits, in tabular format with numbers aligned. Where space does not permit, the declaration shall be in linear format. What does ‘space permits’ mean? Any space anywhere? Voluntary Inclusion of Nutrition – Article 36(1) Where food information referred to in Articles 9 and 10 is provided on a voluntary basis, such information shall comply with the requirements laid down in Sections 2 and 3 of Chapter IV. Easily visible, clearly legible, minimum font size are all in Section 1 of Chapter IV. [Reverse print?] As Sold or As Consumed – Article 31(3) Where appropriate, the information may relate to the food after preparation If preparation is needed when is it not appropriate? All as sold or all as consumed or some of each? INTERPRETATION - LAYOUT 5

A Sun Chemical Company Slide INTERPRETATION - LAYOUT Compound Ingredients ANNEX VII Part E A compound ingredient may be included in the list of ingredients under its own designation in so far as this is laid down by law or established by custom, …, and immediately followed by a list of its ingredients. 6 Ingredients Mango & Apple Mango Puree (30%), Apple Juice from Concentrate (17%), Water, Sugar, Concentrated Apple Puree (12%), Wheat Glucose Syrup, Lemon Juice from Concentrate, Flavourings, Stabilisers Methylcellulose, Pectin, Guar Gum and Locust Bean Gum, Wheat Dextrose. Raspberry & Apple Raspberry Puree (27%), Raspberry Juice from Concentrate (25%), Sugar, Concentrated Apple Puree (14%), Wheat Glucose Syrup, Apple Juice from Concentrate (5%), Water, Flavouring, Lemon Juice from Concentrate, Stabilisers Locust Bean Gum, Methylcellulose, Guar Gum and Pectin, Blackcurrant Juice from Concentrate, Wheat Dextrose.

A Sun Chemical Company Slide INTERPRETATION - REPETITION STORAGE Storage Instructions must always ‘follow’ the use by date – Annex X Storage if need be must ‘follow’ the best before ( end) Detailed storage where foods require ‘special storage conditions’ is in addition to the above – Article 25(1) Storage after opening including conditions and time limit. – Article 25(2) After opening keep refrigerated and use within 2 days. Do not exceed the use by date. After opening keep in an airtight container and use within 4 weeks. A single indication can satisfy all 3 requirements (e.g. Keep Frozen) 7

A Sun Chemical Company Slide GUIDANCE EXAMPLES - NUTRITION Rounding Rules and Trace values 8

A Sun Chemical Company Slide Draft Commission Q&A Is the QUID mandatory for mandatory particulars according to Annex VI, part A, point 6 (indication of added water in the name of the food for meat products and preparations)? Yes, because added water is included in the name of the food (Article 22(1)(a)) and the variation in quantity of added water is essential to characterise the food in question and distinguish it from other similar foods. Therefore, the exemption provided by Annex VIII(1)(a)(iv) is not applicable. UK Technical Guidance on Nutrition Labelling Commission Q&A GUIDANCE 9 What is the role of guidance?

A Sun Chemical Company Slide GUIDANCE 10

A Sun Chemical Company Slide CONSISTENCY 11 For the Consumer – Recital 10 Education and information campaigns are an important mechanism for improving consumer understanding of food information. Business has interpreted the requirements on the basis of what is reasonable for consumers in their own context. There is some variation in presentation as a result.