Science Based Consumer Communication Global Labeling Practices - - PowerPoint PPT Presentation

Shaminder Pal Singh

Science Based Consumer Communication – Global Labeling Practices

30+ Tons of food is

consumed during lifetime

Home Out of Home

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

• nus 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

+

CODEX

ALIMENTARIUS

International Food Standards

=

Intergovernmental Joint body …

Food and Agriculture Organization of the United Nations

World Health Organization

Scientific Basis of Risk Analysis is Integral to Codex decision-making process

Issues of importance that require consideration when discussing implementation

• f 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

1st 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

• Acidity Regulator
• Acids
• Anticaking Agent
• Antifoaming Agent
• Antioxidant
• Bulking Agent
• Colour
• Colour Retention Agent
• Emulsifier
• Emulsifying Salt
• Firming Agent
• Flour Treatment Agent

Food Additives Class Title & Name/INS mandated

• Flavour Enhancer
• Foaming Agent
• Gelling Agent
• Glazing Agent
• Humectant
• Modified starch (INS)
• Preservative
• Propellant
• Raising Agent
• Stabilizer
• Sweetener
• Thickener

= Codex Worldwide General Standard for Labeling of Pre-packaged Food 4.2.3.3

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

• Oligofructose

10

(Nutrient?)

Current FSSR

Duplication – Listing & Declarations

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

• 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)

Duplication of label information … some examples

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

Regulations – Scientific Divergence

• Extent of regulations needs to Proportionate to risks
• Regulatory cost, Complexity and Uncertainty needs

critical assessment prior to enforcement

• Regulatory Impact Analysis very important element

– Risk Assessment / Dietary Exposure > Proportionate regulations – Cost – Benefits analysis – Guidance, Compliance & Tolerance criteria should be released for consistent and effective implementation

“Necessary” info

“Right” enforcement

• Cost of Labeling
• Responsible labeling

Achieve balance (Mandatory vs. Voluntary)

Simple is Better …….& Effective Simplify labeling Helps consumers!

↓Complexity ↑ Simplexity

Shaminder.scientist@gmail.com

Shaminder Pal Singh 40

India FSS (Packaging & Labeling) Regulation Packing & Labeling of Foods Codex Codex Stan-1 General Standards for Labeling of Pre- Packaged Foods (Worldwide standard) FSANZ Standard 1.2.4 Labelling of Ingredients UK Food Regulations

• Food Labelling Regulations
• Sweeteners in Food (Amendment)

(England) Regulations EU Directive 2000/13/EC; Regulation # 1169 /2011 Approximation of Law of member states to labeling, presentation or foodstuffs Canada B.01.010(3) Ingredients & Additives Labeling USA 21 CFR 101.4 Designation of food ingredients