Science Based Consumer Communication – Global Labeling Practices Shaminder Pal Singh
30+ Tons of food is consumed during lifetime
Home O ut of H ome Pre-packaged
What is Label? • Tag, Brand, Mark, Pictorial or other descriptive matter, • Written, printed, stenciled, marked, embossed, graphic, perforated, stamped or impressed on, • Attached to container, cover, lid, crown of package • Product insert
Claim means…. … any representation which states, suggests or implies that a food has particular qualities relating to its origin, nutritional properties, nature, processing, composition or any other quality.
General considerations • Labels shall be applied in such a manner that they will not become separated from the container. • Contents on label shall be clear, unambiguous, conspicuous, indelible and readily legible by the consumer under normal conditions of purchase / use • Label and claims details should be Truthful and not mislead consumers, where claims made the onus of substantiation lies with food business
Labeling (+ Claims) policy drivers 1. Consumers’ needs for information 2. Industry’s need for marketing flexibility and minimal regulatory burdens; and 3. Government’s objectives in the area of individual and population health
Food also has substantial economic, environmental and technological aspects that further add to the expectations regarding role of ‘food labels’
Label particulars India Americas Europe Codex � � � � Product description � � � � Manufacturer/packer � � � � Date of mfr, Best Before � Pricing block � � � � Country of origin (imported) � � � � Ingredients statement � � Food additives class, name X X Additives labeling Precautionary In Ingredient list Some X � � � Hypersensitive ingredients list Some; New being added � QUID Labeling Mandatory X Intl Trade � � � Nutritional Labeling If claims � Vegetarian / Non-veg logo X X X � � � � Directions for use
Intergovernmental Joint body … CODEX = + ALIMENTARIUS International Food Standards Food and Agriculture World Health Organization of the Organization United Nations Scientific Basis of Risk Analysis is Integral to Codex decision-making process
Issues of importance that require consideration when discussing implementation of mandatory nutrition labelling , include (but may not be limited to)…
EU Regulation # 1169/2011 • Published 22 Nov 2011 • Enter into application on: 13 Dec 2014 • Obligation to provide Nut Info from 13 Dec 2016 Combines 2 directives into one legislation : • 2000/13/EC - Labelling, presentation and advertising of foodstuffs ( applicable until 12 December 2014 ) • 90/496/EEC - Nutrition labelling for foodstuffs.
EU Regulation # 1169/2011 1 st major overhaul of Europe’s food labelling rules in 30 years Considerable changes to existing labelling legislation of significant impact on how food businesses communicate with consumers
EU Reg. # 1169/2011
EU Reg. # 1169/2011
EU Reg. # 1169/2011
EU Reg. # 1169/2011
EU Regulation # 1169/2011: Key changes Nutrition Content - General Principles on amount of nutrient in food which may vary compared to that declared on a label due to factors .. • Source of values (values derived from literature and calculated) • Accuracy of analysis • Variation in the raw materials • Effect of processing Nutrient stability, and • • Storage conditions and storage time
EU Reg. # 1169 Nutrient declaration: Tolerance & Compliance
EU Reg. # 1169 Nutrient declaration: Tolerance & Compliance
EU Reg. # 1169 Nutrient declaration: Tolerance & Compliance
EU Regulation # 1169/2011: Adoption Timing • 22 Nov 2011 Regulation (EU) N°1169/2011 published • 27 Jul 2011 Commission Opinion on the EU Parliament's position on the Council's common position • 6 Jul 2011 : European Parliament second reading position on the proposed legislation, agreed with the Council • 22 Feb 2011 : Commission Communication to the European Parliament on Council's common position • 21 Feb 2011 : Council's common position • 16 Jun 2010 : European Parliament first reading position on the Commission proposal • 30 Jan 2008 : Commission proposal
India: FSS (Packaging and Labeling) Regulations 2011
Consumer information on labels • Product / Trade Name Product Description • • Business address • Consumer Cell Info • Product Traceability Information – Date markings / Bar code – Batch / Lot No. – Country of Origin (if imported) Ingredients listing • – Food additive • Functional Class titles • Food additive names or INS – Food additives labeling (duplication of information on label) • QUID Labeling • Vegetarian / Non Vegetarian logo • Mandatory Nutritional Labeling mandatory since 2009 • Directions for Use • Other details
“Food Additives / Ingredients Labeling”
Codex approach on Food Additive listing in Ingredients implemented since 2004 Food Additives Class Title & Name/INS mandated • Acidity Regulator • Flavour Enhancer Acids • • Foaming Agent • Anticaking Agent • Gelling Agent • Antifoaming Agent • Glazing Agent • Antioxidant • Humectant • Bulking Agent • Modified starch (INS) • Colour • Preservative • Colour Retention Agent • Propellant • Emulsifier • Raising Agent Emulsifying Salt • • Stabilizer Firming Agent • • Flour Treatment Agent • Sweetener • Thickener = Codex Worldwide General Standard for Labeling of Pre-packaged Food 4.2.3.3
Duplication – Listing Current & Declarations FSSR Years � � Colour 14 � � Annatto 31-59 � � Improver in Wheat flour 39 � � Synthetic Food color label 37 � � Natural color - malted milk food 37 � Monosodium Glutamate 20 -24 � � � Anticaking agent in salts 33,27,17,15 � � Sweetener 11 & 17 � � Flavour emulsion 15 � � Added Caffeine 13 � (Nutrient?) � Oligofructose 10
Duplication of label information … some examples • Food containing Annatto ….. Colour (Annatto or INS) CONTAINS PERMITTED NATURAL COLOUR • Food containing Flavour, Colour ….. Colour (Name or INS), .., Flavouring and CONTAINS PERMITTED NATURAL COLOUR AND ADDED FLAVOUR (NATURAL, NATURE-IDENTICAL AND ARTIFICIAL (XXXXXXXX) FLAVOURING SUBSTANCES
Duplication of label information … some examples • Food containing Artificial Sweeteners, Colour, Flavours ….. Colours (like Caramel or INS numbers), Flavour, Sweeteners (Names or INS) CONTAINS PERMITTED NATURAL AND SYNTHETIC COLOURS AND ADDED FLAVOUR (NATURAL, NATURE IDENTICAL AND ARTIFICIAL (XXXXXXX) FLAVOURING SUBSTANCES)
New Draft Packaging & Labeling Regulation • Alignment with Codex and Global practices • Nutrients declaration, Nutritional & Health claims conditions for consumer’s benefit • Mandatory nutrients labeling will be more • Scientific substantiation criteria considered • Duplication of labeling and non-scientific labeling needs to be rationalized • Comprehensive changes after 8 years!
‘Consumers’ reaction to labeling? Manufacturers reactions?
Consumer perception to labels? • Overcrowded labels � No longer communicate in a meaningful way • Consumers want… – As Complete Labeling as possible – But, they think that “too much information” is counterproductive • Consumers … – Think Food labels are unclear, incomprehensible and unreadable – (Many consumers) do not read labels “at all” – when read labels , want information on the label that suits them best
Food Manufacturers reactions • Food manufacturers are unhappy ‘too’ – Costly due to frequent numerous labeling rules / amendments – Overcrowded due to piece-meal legislations built over time • Labels are not elastic • Duplication eats lot of space while more changes being added • Nutritional Information bound to vary considering prevalent practices and handling e.g. agricultural practices, varieties • Mandatory Nutritional Information needs “Compliance and Tolerance” guidelines for consistent application
How can we address this paradox? • All consumers pay for labeling changes in form of prices increase, so assessment is in their interests to understand ‘Necessary’ vs ‘Desired’ information • Any legal requirements progressed must be justified by ‘need’ rather than by ‘desire’, mandatory information must be useful and deliver public health benefits expected • Shift focus towards dealing with ‘consumers’ and not ‘the consumer’, as NO ‘one size fits all’ situations • Separate ‘perception’ from ‘realities’ for applying strategy (label, consumer awareness, enforcement accordingly)
Regulations – Scientific Convergence •Science-based, Transparent, Participating Regulatory system •Product and Process approach used •Harmonization of data, methods and standards required
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