Xavier Lavigne, Food Law Manager at EAS, said that the clock starts ticking towards the five-year deadline for nutrition labelling requirements 20 days after publication, therefore from 13 December 2011.
The regulation requires a mandatory declaration on the label of the so-called ‘Big 7’ – energy, fat, saturated fat, carbohydrates, sugars, protein and salt – by 13 December 2016. It also requires these to be expressed per 100g/100ml and, where appropriate, per portion.
While most aspects of the regulation become applicable on 13 December 2014, companies have been given an extended transition period until 13 December 2016 to get in line with nutrition labelling requirements.
“The new food labelling regulation means inevitable changes for companies,” said Mr Lavigne. “The costs of conforming to the mandatory nutrient content rules will most likely hit the smaller food companies more than the larger ones, as many of the larger companies already have some type of nutrition labelling which will simply need to be adapted.”
“However, for those companies wanting to voluntarily label their products with nutrition information any time between 13 December 2014 when the regulation becomes applicable and 13 December 2016 when the transition period for nutrition labelling ends,” he continued, “they will have to comply with the regulations for nutrition declaration, regardless of the given transition period.”
Other aspects of the regulation, with which companies must be compliant by the 13 December 2014 deadline, include new rules on allergen labelling and legibility.
“The regulation introduces a minimum font size of 1.2mm for all mandatory label information, and 0.9mm for products whose packaging has a largest surface of less than 80cm2,” said Mr Lavigne. “For manufacturers it means that knowing how to use the space on certain packages will be key. Already some companies are looking into the creation of understandable symbols in order to gain space and to deal with multilingual challenges. Most companies in the food sector will be pressured into a detailed review of their product packaging in the months and years to come.”
1. EAS provides strategic advice on international regulation on food and nutritional products. It provides companies with regulatory and strategic advice for the marketing and approval of their products in Europe, Asia and Latin America.
2. EAS also advises governments, trade associations and companies on the impact of global policy.
3. EAS has offices in Argentina, Belgium, Italy and Singapore.
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