LEGAL Q&A
Your food manufacturing legal questions answered
This month, we put your queries to Alex Hill, co-founder of strategic energy management consultancy ZTP, and Aoac International board member Erik Konings.
What implications are there for manufacturers from current legislation covering energy use?
Alex Hill:
Two major pieces of energy legislation affecting UK businesses are the Carbon Reduction Commitment (CRC) and the Energy Saving Opportunity Scheme (ESOS). Additional legislation will see smart meters fitted across the UK by 2020, gas consumption monitored more closely through Project Nexus, and buildings with Energy Performance Certificate ratings of F and G become unlettable.
The CRC, requiring businesses consuming more than six gigawatt hours of energy per annum to report on their energy usage annually and purchase credits based on that consumption, will be removed from 2019.
CRC revenue will instead be generated through an increase in the Climate Change Levy (CCL) present on most commercial bills. As a result, UK businesses not exempt from paying CCL will see an increase in costs from 2019.
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ESOS rules require firms with more than 250 employees, or an annual turnover exceeding £50m and a balance sheet exceeding £43m, to report on energy consumption every four years. Those not yet compliant, or that miss the 2019 reporting deadline will face fines of up to £50,000.
Food manufacturers that have not yet been required to, or have not been able to, develop energy management and reporting capabilities in-house will need to either train internal staff or engage with a consultancy.
ZTP’s energy management portal Trace enables swift energy data gathering, and customised reports enable ESOS, CRC and supply chain reporting efficiently. Quantifiable benefits come from reduced administration and improved procurement, with our clients saving 6.73% a year against internal procurement strategies.
How can firms demonstrate compliance with international rules governing infant formula nutrition labelling?
Erik Konings:
Two new international standards for verifying compliance of such products with labelling regulations for nutrients have just been published, providing a new inter-laboratory validated analytical technique. They are:
- The International Standards Organisation (ISO) 20635, Infant formula and adult nutritionals – Determination of vitamin C by (ultra) high performance liquid chromatography with ultraviolet detection;
- ISO 20636, Infant formula and adult nutritionals – Determination of vitamin D by liquid chromatography-mass spectrometry.
Both are test method standards in support of the international Codex standard for infant formula and formulas for special medical purposes intended for infants.
Agreed globally, they can be used as reference for dispute resolutions and are just two in a series developed as part of the Stakeholder Panel on Infant Formula and Adult Nutritionals (SPIFAN) Project.
- Konings convened the working group that developed the latest standards for infant formula.
