What should you think about when labeling food?
Hereby a table that can be used as a checklist to improve labeling per item. The list goes trough several items, related to labeling. iMIS Food as developed iMIS Food SpeckCheck to aid with specification management and labeling.
Labeling Item | Required (yes/no) | Labeling Comments |
1. Product name/ fantasy name | No | Product name does not equal commodity legal name |
2. Categorical name plus supplementation such as: | Yes | Certain additions to the names must be indicated in the names, others may appear in the same field of vision. Only the presence of proteins and water is necessary, not the amount of water or proteins. If applicable, it is mandatory to include the condition of the product together with the commodities legal name. Please note, there are additional obligations to state the condition in the event that the consumer would otherwise be misled (this concerns, for example, products that have been frozen and have now been thawed.) |
– When using sweeteners; | ||
– When using alternative ingredients, which are not usually associated with conscious product; | ||
– When using sugar(s) together with sweeteners; | ||
– When using proteins and/or water for more than 5% (for meat and fish products); | ||
– When using specific additives (for meat preparation … composed of pieces of meat (if applicable). | ||
And in particular the physical condition | ||
– Frozen or quick-frozen; | ||
– Thawed (see note); | ||
– Irradiated; | ||
– Powder; | ||
– Concentrated; | ||
– Smoked; | ||
– Packed under protected atmosphere. | ||
3. Ingredients | Yes | Allergens may be mentioned again separately, but do not count as a way of emphasizing. Do not forget to mention what kind of vegetable oil it is. This obligation only applies to those nanoparticles that have been deliberately manufactured at the nanoscale because of their specific properties. |
– Ingredients must be listed in decreasing weight; | ||
– Vegetable and animal oils (hardened or not); | ||
– Indication of additives under category designation, with e-number or deregistered; | ||
– QUID (characteristic ingredients and/or as a result of approaches in name or image on the label); | ||
– Allergens are mandatory emphasized in the list of ingredients and if present are nevertheless mentioned as process aids; | ||
– GMO status (immediately after the ingredient in question in list of ingredients or separately via asterisk); | ||
– Mandatory mention of ‘nano’ prior to the relevant ingredient. | ||
4. Net quantity declaration | Yes | Whether product is solid or liquid depends on the density of the product or on national provisions |
– g/kg or ml/l | ||
net weight or filled under e-sign | ||
– drained weight (if applicable) when using liquid, etc. | ||
5. Expiry date | Yes | Depending on the length of shelf life in day, month and year or month and year or just mention the year. For shelf life, it is also possible to print / punch by means of a reference to other place on the label, etc. |
– THT or | ||
– TGT (for perishable products such as chilled ready meals) | ||
– Date of freezing (all for certain products) | ||
6. Batch code | Yes/no | Mandatory, unless the expiry date is considered a batch code. |
7. Same field of view: | Yes | These items do not necessarily have to be listed in front of the packaging, only in one field of view. |
The following items must be listed together in a field of vision: Commodities legal name (No. 2), quantity declaration (No. 5) and, if applicable, the alcoholic strength by volume. | ||
8. Name of importer or producer/brand owner (responsible for the correct information) | Yes | Please note: the advice to combine this information with the information about consumer service |
9. Country of origin Depending on the different impact assessments, it may be mandatory to state the origin in more cases. | Yes | … mandatory for some products, such as olive oil, fish (indication of fishing area), unprocessed meat and unprocessed fruit and vegetables. |
10. Instructions | No, but | … is obliged if the product cannot be used correctly without this information or is unsafe after incorrect storage. |
– Storage conditions; | ||
– Instructions for use and/or | ||
– Preparation instructions. | ||
11. Warnings, etc. | Yes, if applicable | Not mandatory according to the new regulation. All warnings must be displayed in the same field of vision as a commodity legal name. |
– Not suitable for children under 3 years. | ||
– Can … (allergen name) … contain (voluntary) | ||
– Alcohol >1.2% | ||
– Caffeine (high caffeine content) or contains caffeine (from certain content in products such as soft drinks). | ||
– Presence of aspartame (or contains a source of phenylalanine). | ||
– Presence of polyols (excessive use can have a laxative effect). | ||
– AZO dyes: “… may adversely affect the activity or attentiveness of children”. | ||
– Licorice. | ||
– Phytosterols. | ||
– When a sausage skin is not edible, this must be stated. | ||
12. Nutrition declaration | Yes and required in this order | Declaration per 100g or 100ml and voluntarily per serving (state how large a portion is). |
Energy, Fat, of which saturated, Carbohydrates, of which sugars, Protein and Salt. | ||
13. Voluntary nutrition declaration | Declaration per 100g or 100ml and voluntarily per serving (state how large a portion is). If present in significant quantities | |
In addition to mandatory seven nutritional values, the possibility of indicating one or more of the following: | ||
– Monounsaturated (fat); | ||
– Polyunsaturated (fat); | ||
– Polyols; | ||
– Starch; | ||
– Fibers; | ||
– Minerals and vitamins. | ||
14. Nutrition statement as a percentage of reference intake (RI) | No, not required | |
15. Quality statement | Producer name | |
– Telephone number consumer service; | Street name and number (visiting or postal address or answer number or P.O. Box) | |
– Responsible for product information / food safety. | City name (and country if relevant). | |
16. EAN (barcode) | Yes | But not from (commodity) law |
17. Recycling | No, not from the EU Vo. No. 1169/2011 | In certain countries this is mandatory, but not under Regulation 1169/2011. |
– Material identification; | ||
– Recycling symbols. | ||
18. Marketing | No | See EU regulation 1924/2006 and FNLI manual claims. Pay attention to consequences in relation to QUID (quantitative ingredient declaration) |
– Nutrition and/or health claims; | ||
– The use of pictorial/images to support product experience. | ||
19. Use statements etc. | No | See regulations Vo. No. 834/2007. Check conditions of use. |
– The term ‘natural/ traditional etc.’ | ||
– No artificial … flavors, fragrances or colorings, etc. | ||
– … name allergen … free (o.i.d.); | ||
– Suitable for vegetarians or vegans; | ||
– Organic; | ||
– Fairtrade or Max Havelaar etc. |
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