I have been asked about this a lot recently. So many times, in fact, that it was clear to me that there is some confusion amongst food operators about the new legislation that comes into force at the end of this year. So I thought it would be useful to get the facts straight.
New nutrition labelling requirements are set to come into force from 13th December 2016, which will form part of Regulation (EU) No. 1169/2011 on the provision of Food Information to Consumers (EU FIC). The existing requirement to label 14 allergens that was introduced in December 2014 is part of the same piece of legislation. In addition to providing allergen information, you will also be obliged to label all pre-packed food with nutrition information.
The purpose of FIC is to guarantee that nutrition information is provided in a uniform way across the UK. This helps all consumers, whether customers, patients, staff, students or school pupils, to make more informed decisions about the food and drinks available to them. Everyone across all sectors involved in food service provision will need to understand what this new legislation means for them.
Right, so let me get on with it. Essentially, from December 2016 it will be mandatory to provide nutrition labelling on all pre-packed food. Up to now, this information was only required if a nutrition or health claim was being made. If the food you sell or serve is not pre-packed, there is no requirement under EU FIC for nutrition information to be made available, nor are there any current plans for this to be introduced. But how do you know if the food you serve is pre-packed or not? Well, if the food offered does not come with any pre-packaging, or if it is packaged on your site at either the consumer’s request or is pre-packed for direct sale on the same site, e.g. sandwiches or salad boxes, then there is no need for nutrition information to be provided.
If caterers choose voluntarily to provide nutrition information for food that is not pre-packed, then it must be written in a specific format. To help caterers understand these requirements, and what they need to do to comply with the legislation, the British Dietetics Association’ Food Services Specialist Group has put together a toolkit called ‘Nutrition Toolkit for Healthcare Catering’ https://www.bda.uk.com/professional/practice/clinical_practice_guidance/bda_toolkits.
Although the title of this document indicates that it is for Healthcare, caterers in other sectors will also find the toolkit useful.
So, how relevant is all this, post-Brexit, I hear you ask? Well, the official line is that it is business as usual. The requirement to make allergen information available for any pre-packed and non pre-packed food or beverage item is still mandatory. In addition, from 13th December 2016, you will have to ensure that you include nutrition labelling information for any pre-packed food that you serve. UK law as it stands will be in force for at least a couple of years. This means that local enforcement officers in charge of EU FIC legislation in your area will continue to check your allergy and nutrition labelling procedures during inspections.
If you have any questions, or would like more information on this topic, please contact me: firstname.lastname@example.org