FIR webinar
Alasdair Tucker
Premier Foods’ head of regulatory affairs Alasdair Tucker previously complained of delays surrounding the introduction and clarification of the new rules.
In our previous gallery, he helped clarify things for Kershaws Frozen Foods, Exova and others that asked if food could still be sold after the date mark?
The other questions he chose to answer were:
“Please can you specify the min font size?” Charlotte Wood, QA manager at Dalehead Foods
Tucker: “The Legislation defines minimum print size based on the height of the lowercase letter ‘x’ (‘x-height’ as set out in Annex IV of the Regulation including an illustrative example.
“The trigger points for the actual size are the largest surface area of the product container and not the label. For containers where the largest surface area is greater than 80cm2 minimum ‘x-height’ = 1.2mm, those where the largest surface area is less than 80cm2 minimum ‘x-height’ = 0.9 mm.
“The minimum print size will apply to the name of the food; the list of ingredients; where any ingredient is in the Quantitive Ingredient Declaration the values must be minimum height the net quantity of the food (n.b. Already addressed by weights legislation); (e) the ‘ best before’ or the ‘use by’ date including signposting (e.g. ‘for best before see cap’); (f) any special storage conditions and/or conditions of use; (g) the name or business name and address of the food business operator; (h) instructions for use; (i) a nutrition declaration – both back and front of pack.”
“Is it possible to launch food products with labels which meet 1169 Regulations now, prior to Dec-2014?”Sergey Litvinenko, regulatory manager at Red Bull Russia
Tucker: “The answer is yes, but you need to pay attention to where certain pieces of mandatory information appear – this particularly concerns the ‘field of vision’ requirements. In short, until December 13th 2014 the ‘best before date’ must appear in the same field of vision as:
- the name of the product
- the net quantity (for pre-packaged foodstuffs)
- the alcoholic strength by volume (for beverages containing more than 1.2 % by volume of alcohol)
After this date, the field of vision requirement for the best before date no longer applies.
For more information it would be worth referring to the EU Commission’s Questions and Answers on the application of the Regulation (EU) N° 1169/2011 on the provision of food information to consumers.
“With regards to things such as the Southampton colours warning will these still need to be labelled after December 14, or will this legislation supersede the regulation that covers this?”Laura Marriott, QA technologist at Kiril Mischeff
Tucker: “Article 24 of Regulation 1333/2008 states that food containing the colours listed in Annex V of that regulation should include the additional information set out in that Annex.
“The effect of Article 24(1) is that when the colours listed in Annex , such as Sunset yellow (E 110), Quinoline yellow (E 104), Carmoisine (E 122), Allura red (E 129), Tartrazine (E 102), Ponceau 4R (E 124), are required to be labelled, such labelling must also include this additional information. The name or E - number of the colours accompanied by the wording ‘may have an adverse effect on activity and attention in children.’ Therefore, the effect of Article 24(1) is that when these colours are required, Article 24 (1) applies without prejudice to Directive 2000/13/EC (labelling, presentation and advertising of foodstuffs, i.e. Regulation 1333/2008 does not displace any labelling requirements that apply to food by virtue of Directive 2000/13/EC.”