Best practices in labelling are just as important as best practices in production. Your customers rely on you to communicate accurately with them (such as listing the correct ingredients or allergens) and when things are incorrectly labelled – potentially resulting in a product recall – your brand's reputation is put at risk.
However, ensuring labelling and packaging compliance with all relevant standards is no easy feat for food manufacturers, with compliance-driven requirements becoming more detailed and prescriptive.
Even with a raft of operating procedures and auditable manual checking regimes put in place to ensure compliance, mistakes can – and do – happen. Below we look at some of the best practices when it comes to food labelling and what you can do to ensure accuracy.
Food Labelling Regulations
Regulation 5 of the Food Labelling Regulations 1996, requires certain information to be given on all pre-packed food. These requirements are written by the EU and are as follows:
“Subject to the following provisions of this Part of these Regulations, all food to which this Part of these Regulations applies shall be marked or labelled with-
(a) the name of the food;
(b) a list of ingredients;
(bA) the quantity of certain ingredients or categories of ingredients;
(c) the appropriate durability indication;
(d) any special storage conditions or conditions of use;
(e) the name or business name and an address or registered office of either or both of:-
(i) the manufacturer or packer, or
(ii) a seller established within the European Community;
(f) particulars of the place of origin or provenance of the food if failure to give such particulars might mislead a purchaser to a material degree as to the true origin or provenance of the food; and
(g) instructions for use if it would be difficult to make appropriate use of the food in the absence of such instructions.”
The following items are not legal requirements, but are nevertheless good practice and often included on packaging:
- illustration of product
- nutritional values of the product
- customer guarantee
- the batch-code and bar-code numbers
- opening instructions
TOP TIP: The government has produced guidance to help manufacturers and retailers provide clear information on food labels, which can be found here.
The Food Information Regulation, which came into force in December 2014, introduced a requirement that food businesses must provide information about the allergenic ingredients used in any food they sell or provide.
Under EU law, any prepacked food or drink sold in the UK must clearly state on the label if it contains one of the 14 major allergens. A full list of allergens, including examples of where they can be found can be shown here.
How to ensure labelling and packaging compliance
In order to comply with the British Retail Consortium’s (BRC) Global Standard for Food Safety, product labelling needs to comply with the appropriate legal requirements and contain the correct information to enable the safe handling, display, storage and preparation of the product within the food supply chain or by the customer.
Clause 5.2.1 states that: “There shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications.”
There should also be effective processes in place to ensure that labelling information is reviewed whenever changes occur to:
- the product recipe
- raw materials
- the supplier of raw materials
- the country of origin of raw materials
As you can see from the above, ensuring compliance with both legal requirements and best practice is complex.
You may already have robust procedures to ensure new product development and packaging artwork sign off processes guarantee that the right information is in place. But what happens on the factory floor – can your staff correctly match the various items of packaging required on a product?
One of the biggest barriers to compliance is human error on the packaging line, which can lead to mislabelling even when the manufacturer goes to great lengths to ensure the correct information is present and correct.