Food labels represent key elements in consumer-product interaction as their information can determine consumers’ food choices. Information such as food composition, characteristics, expiration date, nutritional properties and storage and handling instructions are crucial in order to match with consumers needs and desires.
It all started back on the 13th century
At the very beginning, almost all food was produced locally and consumed locally, so there was no need for food labels. In England, labelling regulations starts with the branding of bread in the 13th century, when King John enacted Assize of Bread, since bread was a major article of commerce. These regulations began with regulatory marks to enhance adulteration laws and levying duties and taxes on bread.
In the 19th century, industrialization of food products led to the need for regulation to prevent misleading and fraudulent labelling. Since then, food labelling regulation can count with some important milestones: In 1906, the original Food and Drugs Act is approved (USA) – It prohibits interstate commerce in mis-branded and adulterated foods, drinks and drugs; The first attempt to harmonize the way labelled foods were sold to the final consumer in Europe was a Council Directive on food labelling in 1979 (79/112/EE;1); In 1990, Nutrition Labelling and Education Act (NLEA) is approved (USA)- All packaged foods have to bear nutrition labelling and all health claims for foods has to be consistent with terms defined by the Secretary of Health and Human Services. As a concession to food manufacturers, the FDA authorizes some health claims for foods. The food ingredient panel, serving sizes, and terms such as low fat and light are standardized.
Food labelling policies aim at preventing consumer deception, unfair business practices, ensure food safety and improve public health. All these policies are essential to ensure credible, updated and clear information. This task combined with harmonizing national policies with international standards has been challenging to national authorities.
Food legislation and food safety schemes play a role in defining labels content
Food safety schemes (BRC, FSSC 22000, IFS and SQF) also approach product labelling on their systems, however only BRC and FSSC 22000 (version 4.1) address the theme in a dedicated clause. IFS (version 6.1) mentions product labelling in Product development/Product Modification/Modification of production processes; SQF approach is in Food legislation.
It is generally mentioned that the finished product shall be labelled according to the applicable regulations in the country of intended sale. All of them also emphasise allergens, saying that product labelling shall comply with legal requirements. Except SQF, all mention that labelling shall include information to allow the safe handling, display, storage, preparation and use of the product. Only SQF makes reference to labelling approval by qualified company personnel.
In the late 20th century and for many years, food labels were required to minimally carry only basic mentions (listed below on the left). Nutritional labelling, for instance, was not required. Nowadays, several mentions are required to be listed on the food label (listed below on the right). These additional mentions can impact the development of foods and food reformulation.
On food safety, the subjects more relevant in labels are probably suitable storage and handling instructions (including expiration date) and allergen information.
Storage and handling instructions are essential in preventing foodborne illness. They inform the consumer on how to use/consume/store the product and under which conditions, thus restraining the effects of deterioration and diminishing the risk of becoming unsuitable for human consumption. The expiring date, that is probably the information that consumers check first (right after price!), is attributed by the manufacturer based on the belief that the product will be handled by the food chain and consumer according to these instructions. Most of the consumers are not well educated about this aspect, and more often than they should they do not properly follow those instructions.
Undeclared allergens can put consumers seriously at risk of life; these are particularly important because they represent the biggest failure of food labels and consequently the major cause for food recalls. You can read more about allergens and cross-contamination in June’s 2017 article. Examples of legislation of allergens:
- Regulation (EU) No 1169/2011: Clearer and harmonised presentation of allergens, for prepacked foods (emphasis by font, style or background colour) in the list of ingredients; mandatory allergen information for non-prepacked food, including in restaurants and coffees;
- On 13 July 2017, EU adopted a Notice on the provision of information on substances or products causing allergies or intolerances;
- (US) Food Allergens Labelling and Consumer Protection Act of 2004 (FALCPA) requires that food that contains an ingredient that is an allergen or contains protein from a “major food allergen” should be declared on the food label. Eight foods or food groups are identified as major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans.
There are several ways to represent allergens: listed in bold in the ingredients/through a separate “may content” statement/emphasis by background colour, as shown below.
Nutritional information has been debated in last 4-5 years and has changed significantly. Nutrition facts label must include serving size, calories, percentage of daily recommended values for fat based on a 2,000 calories diet (with listed values for saturated fat and trans fat), cholesterol, protein, plus vitamin and mineral content, expressed in terms of their percentage of daily recommended values. In US 2014, ex-First Lady Michelle Obama unveiled the country’s first update to nutrition labels in more than 20 years. Changes including larger type font for calorie counts, the inclusion of a separate line for added sugars and updated portion sizes (see picture below – original label on the left; updated label in the middle).
In the EU, nutritional labelling becomes mandatory for most pre-packaged foods as from December 2016 (picture below on the right). The two systems are similar; the major difference is how they reveal calories: in the US, it is mentioned the number of servings per container, on the other hand, in the EU, all calorie listings are based in 100 g or 100 mL. Also US uses sodium content and EU uses salt.
Country of origin is a recent food label requirement to make it clearer where the products we buy are produced, grown, made or packed. Very recently in the EU (January 2018), the European Commission (EC) submitted a draft of a subject regulation, which mentioned indication of origin of provenance of food as voluntary. However, this word caused confusion. Thus, last month, a EC spokesperson clarified it by stating that Country Of Origin food labelling will be obligatory when the producer wants to have the country of origin label and the main ingredient of a particular food comes from a country different from the country of production.
For the consumer this can be good news since when the origin of a food is label they naturally can assume that the content is from that country. It sounds fair that at least if the main ingredient has other provenance they should know about. But this will be challenging for the industry since the source of an ingredient may change during the year (according with the season, for instance) or even the ingredient been mixed together with other from different origin.
What’s next?
The picture below shows some of the challenges labelling will face in the near future.
Labels are privileged marketing tools for the producers but they are also the final guarantee that consumers make informed and conscious choices. We envision the day in which labels can do the ultimate sacrifice in protecting the consumer and will read: “This label will self-destruct after the expiring date”.
