How to Fulfil EU Food Labelling Requirements

Nutritics offer allergen management and nutrition labelling solutions to help food businesses comply with new requirements.

What do the new rules mean for food businesses?

The European Commission is responsible for publishing harmonised rules for the provision of food information across member states. The most recent set of rules are outlined in EU Regulation 1169/2011 on the provision of Food Information to Consumers (commonly called FIC). 

FIC came into effect in its entirety on the 13th of December 2016, meaning that now and for the first time, providers of non-prepacked (loose) food* are obliged to provide information regarding 14 categories of allergenic ingredients, this has been expected from December 2014. Since December 2016, all prepacked foods* must have a nutrition declaration. This means, if you are selling prepacked foods either, your old style labels need to be updated, or you will have to display labels for the first time. The bottom line is that all food producers and providers, including; manufacturers, cafés, delis, pubs, bakeries, restaurants, food retailers and caterers must correctly determine their recipe’s nutrient and/or allergen information, and understand the legislation well enough to create compliant labels. Most SME food businesses do not have the capacity to deal with these requirements on their own. 

Why is regulation of food necessary?

As consumers we expect to be informed about the foods that we choose to buy and consume. However, for as long as food has been considered a commodity, dishonest providers have tried to capitalise on profits by bulking out raw materials or disguising lower quality food as superior. At best, we are misled and waste money buying these fraudulent products, at worst, the safety of the food is compromised and our health is put at risk. It was the major food safety crises of BSE and Salmonella in the 1980s and 90s that prompted the harmonised regulation of food in Europe. Since then, the food chain has become increasingly complex, this means that the duty of the European internal market to ensure that consumers are offered a wide range of safe and high quality products from all EU Member States has become more challenging. The result is that better rules are needed to protect consumers and ensure safe food for everyone. The provision of accurate food information is at the centre of food regulation. Transparency and traceability is required at every link in the supply chain of food products, each link must be as reliable as the next if the health of consumers is to be adequately protected. The horsemeat scandal that was exposed by the Food Safety Authority of Ireland in 2013 is a reminder to all of Europe that rigorous regulation of food is important today as it was three decades ago.

As a food business, how can you fulfill your requirements to provide food information?

There are a number of ways to go about finding out the nutritional composition of your food products that will enable you to fulfil your legal obligation to provide accurate information about your food.  

• Laboratory testing: You can get your products analysed by a laboratory to determine levels of nutrients. However, this can be expensive, particularly if you reformulate or need to use substitute ingredients in your recipe. This is mainly because changes to a product will mean that it will need to be re-tested. Laboratory analysis will give you a detailed report regarding the specific nutritional composition of your food however, you will still have to translate this nutritional information into a label that will comply with labelling rules. 
• Database analysis software: Using food database analysis software has the potential to save you a significant amount on the cost of external services like laboratory analysis or professional consultants. Using a credible database analysis tool will give you transparency and control to independently reformulate your recipes and update labels as required. As you have control of analysing your recipes and creating your labels, it’s important to understand that the accuracy of your label will depend on your choice of reference ingredients and the quantities you use. 
• Professional consultants: Regulatory advisors, food scientists and nutritional professionals can review your products, identify allergens, calculate nutritional composition and create your labels. However, this is also an expensive service, because, similarly to lab testing, you will need their services every time you change even the smallest ingredient in any of your recipes.

How do you know which solution is right for you?

• Laboratory testing is recommended when producing fortified foods, as it will ensure that the levels of fortification in the final product are correct. Also if you claim that your product is ‘gluten free’, lab analysis is needed to ensure that levels of gluten are not above the required level set out in regulation. You may also consider laboratory testing if you are required to determine levels of contamination or pesticide residue. 
• Database analysis software provides an acceptable and easy solution to the majority of food providers. The best Database Analysis Software will give you access to local food composition data that is suitable to use for labelling in the country or region you are serving. It should offer a platform that is tailored specifically to your needs and, as part of the service, you should expect to have access to support from regulatory advisors, food scientists and/or nutritional professionals who are in a position to support you using the software. Database Analysis Software might be the best solution for you if you are in a position to manage your own recipes independently and you are confident in the accuracy of your recipe information. 
• A consultant may be right for you if you don’t have the time or human resources to manage you own recipe analysis or if you prefer for your recipe calculations to be completed independently, this is advisable if you know that you require professional advice and to not seek advice could be seen as operating without due care or responsibility. If choosing software, it’s important to make sure the program meets your needs. 

Here are our top 10 things to consider before choosing your nutritional analysis software:

1. Software operation: Is the software web based or is it installed locally to a device? Web based software offers many advantages over locally installed software. Local software may feel like it is more secure, but this isn’t the case anymore. Local software requires installation, management and frequent data backup. Web based software is automatically backed up and updated as required and modern encryption technology makes most online software even more secure than local software, with the added benefit of unrestricted access from any device in any location. 
2. Appropriate data: It is important that the correct database for your region is available in the software you choose. Not all food composition data is appropriate for food labelling, make sure that you choose software that uses recognised reference data that is acceptable for food labelling. Your chosen software should have the flexibility to allow you to supplement the existing reference databases with your supplier specific food information.  
3. Accommodation of changes to nutrient values: It is important to accommodate for changes that occur to your food following cooking or processing. Vitamins and minerals are susceptible to varying degrees of degradation during cooking. Weight changes occur through both loss and gain of water or oil. These will have a huge impact on your per 100g and per serving nutritional values. It is important that the software you choose can accommodate these complex changes to nutrition information. 
4. Foodservice specific: Choose software that will support your business and serve as a management tool. Database analysis software that has been designed to be used by the food industry can offer many other business management services that can support you in ensuring efficient and effective business operations. Supplementary features like costing analysis, data export to spreadsheets, allergen management, integration of data to customer ordering systems, collaboration across multiple sites and instant access to legally required records are invaluable instruments to support effective business operations. 
5. Output/export features: If you need to print labels, make sure that the software you choose can print labels directly, or easily integrate with your label printer. 
6. Language: For supply across the EU Member States or export outside of the EU, it might be necessary to translate your label to additional languages, or create a multiple-language label. If you export your foods, it is best to find a solution that can provide automatic translation and can also support foreign country labelling standards. 
7. Ease of use: It is best to choose software that is user-friendly and doesn’t require highly trained technical staff to operate it. 
8. Support and after-sales service: Make sure the system you choose provides support and after sales services as standard. You should expect email and phone support from qualified nutritional scientists and regulatory advisors at a minimum. Ideally your software should offer tutorial videos and how-to guides with step by step instructions on how to use the system. 
9. Software upgrades: A cloud based system should offer automatic updates to the latest version, bringing new features, food databases and guidelines as soon as they become available. This means this means you are always using the best available data sources, and not using out of date information between software update cycles, as is the case with traditional (non-cloud) nutrition programs. However, be sure to get confirmation from your software provider that your existing data will not get over-written when updates occur (unless you acknowledge and request the update).  
10. Security: A high level of security should be offered by your software provider. In advance of choosing your software, request information on the level of security provided. At a minimum, software should use encryption technology and data should be hosted on accredited, dedicated servers. You should be satisfied that your provider takes security very seriously before you choose to use them. 

At Nutritics, we offer a comprehensive nutrition analysis software platform that can be customised to meet your needs. Nutritics is easy to use, cloud-based, and offers the most comprehensive set of food reference databases available. Nutritics is developed by technologists and regulatory experts, specifically for use within the foodservice industry. Click below to try Nutritics for free for seven days, or to speak to one of our expert advisors.

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The new Regulation (EU) No 1169/2011 on the provision of food information to consumers entered into application on 13 December 2014. The obligation to provide nutrition information will apply from 13 December 2016.

* “non-prepacked or loose food” means food sold in loose form or packed on the premises at the request of the consumer or packed for direct sale or supply to the final consumer or mass caterer. 

**“prepacked food” means any single item offered to the final consumer or mass caterers, consisting of a food packaged before being offered for sale, whether such packaging encloses the food completely or only partially, but in any event in such a way that the contents cannot be altered without opening or changing the packaging.