The New European Food Information Regulations Ensuring retailers are EU1169 compliant online These slides do not constitute legal advice. Businesses are recommended to seek their own legal advice on the food Information Regulation

What’s the goal of the new regulation? To ensure that consumers can make informed decisions about the food they purchase in-store and online. Which means: An increase in the amount of mandatory information required New rules on how information is displayed on product The requirement for information to be accessible prior to purchase if the product can be bought online The new regulation will enforce changes in the way product data appears online.

How do the Food Information Regulations affect retailers? Retailers as well as manufacturers are jointly responsible for displaying product information in a legally compliant way. The distance selling regulations require retailers to make food and beverage information available to the consumer at the point of purchase for no extra cost. The new regulations will restrict the choices that retailers can make about what product information they display, and how they display it. From December 13 th 2014, every food and beverage product you sell must include the mandatory information listed in (EU) No 1169/2011 in a clear fashion. Allergens will now be emphasised in the Ingredients list (emboldened, italicised or underlined) and nutritional tables will be reordered Retailers’ websites will need to be changed in order to reflect this.

What does this mean for retailers? How product info is displayed on site today

What does this mean for retailers? How product info will differ once compliant Front of Pack Labelling Allergens emphasised Revised allergen statement

Because beyond missed sales, there are serious implications for online retailers: Legal liability You could face financial penalties for displaying non-compliant product information. Public or criminal liability If a customer has a serious allergic reaction to a product and you are found to have not provided product information in the correct, compliant format, you may be liable. Customer perception If you aren’t complying with the Food Information Regulations and your competitors are, what does it say to your customers? Brand reputation If you are penalised for non-compliance it could have a negative impact on your brand. But it’s not all negative... Why is it important?

Take a positive view and transform your obligation into an opportunity: 1.Raise the Bar Brandbank provides retailers with the opportunity to recalibrate or reset the baseline for online product data across their entire web store and make this the minimum requirement for the way product is marketed and merchandised to customers. 2.Differentiate You can use the requirement for revision of the digital product information as a way to develop and incorporate richer ‘beyond the pack’ marketing images and content that will deliver a more engaging customer experience at minimal cost or disruption. 3.Lead the Agenda View it as an opportunity to be seen as a business leading the agenda by collaborating with the category leading suppliers to initiate industry wide adoption and change. 4.Better Customer Experience Building Trust Provide your customers with the product information that enables them to make informed choices, increasing their trust in you as their preferred retailer. Why is it important?

You already have an FIR EU1169 compliant solution If you get your product information from Brandbank you are already using an FIR compliant service The way we capture on-pack product information means that we already have a data model and process which maintains and distributes all of the information the new Food Information Regulation is making mandatory, as long as it’s present on the packaging. You will need to make some technical changes to the way you receive data and format your website. But, you can rest assured that if you work with Brandbank your online retail offering is ready to become compliant - it’s part of our core service.

What do retailers need to focus on? As an online retailer, your main focus should be getting your site ready to display the updated product information. However, there are 4 key areas you should ensure your business has covered: 1.Awareness 2.Ownership internally 3.Technical changes 4.Other actions

Awareness Are you ready? Do you have a clear understanding of the Food Information Regulations? In summary: Retailers and manufacturers are jointly responsible for displaying product information in a legally compliant way. The distance selling regulations require retailers to make food and beverage information available to the consumer at the point of sale for no extra cost. If you need more information on the regulation refer to our quick reference guide that accompanies this presentation, or take a look at our webinar.

Ownership Who’s responsible across you business? It’s important to understand the extent of what you need to do as a business and who ‘owns’ the actions internally. You may need to make changes to your own-label product labelling; you will need to make changes to your website and the way you take product data from Brandbank, and you might want to develop customer facing material to communicate the changes in a positive way. Across your business this could involve a mix of different stakeholders from: Compliance Labelling Commercial Technical Marketing Identify the right stakeholders and ensure a coordinated action plan has been put in place to enable you to achieve compliance within the timeframe.

Technical change What do you need to do? Make sure your technical team understand the need to make some changes to the your online retail site in terms of the way compliant formatted label information is received and displayed on your website. To ensure that allergens are correctly highlighted, retailers’ sites will need to be updated to allow ‘Rich Text’ like emboldening, italics and underlining to be displayed. Two technical update solutions are available to retailers from Brandbank. Set up a meeting with all internal stakeholders and Brandbank to go through these in detail and decide on the appropriate technical solution to ensure you are compliant for distance selling.

Technical Solutions for compliance There are two options to ensure your website is compliant with EU Update to XML Schema Our Integration support team will advise on how and where to update your data schema to correctly display the updated information being received. There is no charge for changes to information, but there may be some small charges for professional services in the form of any technical integration support required. 2.Custom XLST Templating We can set up your data feed so that it populates a bespoke template and displays the new product information in a way tailored to you. There will be charges for professional services and technical integration support for this. 3.Brandbank On Demand This is a new service we will be introducing later this year to help retailers display richer product content (including 1169 product info) without having to re- architect their entire site.

Other Actions Own-label Product If you have own-label products has the label redesign process been started? When will updated packaging be available? Are your rollout plans allowing everyone enough time to deliver by December 2014? Supplier Awareness & Readiness Are all your Suppliers aware of the new Food Information Regulation and their responsibilities? We would like to work with you to ensure that your suppliers are doing their bit. We have provided a set of communications tools to enable you to deliver a joint message to the supplier community in the toolkit at the end of this presentation.

What are the next steps? 1.Evaluate feed options. 2.Choose your preferred technical solution. 3.Liaise with Brandbank Integration Services to schedule any support requirements. 4.Make the necessary changes to your website and formatting of your product pages to enable you to display all the updated compliant product information in the correct format. 5.Work with the Brandbank National Account Manager to define a delivery plan with timings. 6.Own-label product If you have own-label product, provide your Brandbank Account Manager with details of your labelling update programme and timings. 7.Supplier engagement Work with your Brandbank Account Manager to engage suppliers and make them aware of the need to provide products with compliant labelling.

Engagement pack 1.Technical Documentation 2.Visual Examples 3. Quick ref one-pagers 4. Action plan / checklist