Week 21 Labelling Compliance - We've Got SALSA Sussed
Hi Everyone!
Labelling is always a HOT TOPIC!
Labelling Compliance is so important to get right first
time.
Knowing what to put on them is one thing.
Knowing the order of ingredients, how they need to be
displayed, which ones need percentages next to them, how to legally document
allergens and additives and what the legal description needs to be…… that is
another thing!
There’s no wonder businesses want an expert to check the
compliance for them! And now we have Brexit to think about too…
There is so much to think about! If you get it incorrect,
it could be extremely costly, especially if you have had thousands of labels
printed.
Many businesses want the peace of mind of professional
expertise. I provide a comprehensive label compliance checking service to many
of my customers. After visiting Campden for further labelling training earlier
this year, you can feel assured I will provide a great service to you if
needed! Trading Standards in some areas provide advice, but in rather limited
detail.
I am going to explain what SALSA requirements are, and
how to go about labelling compliance.
What’s coming next…
Week
22 Labelling & Coding Application
Labelling Compliance - what do you need to show your
SALSA auditor?
Labelling Procedure
Labelling Compliance Checking Evidence
Completed Labelling Artwork
Labelling Procedure
You need to write a documented
procedure to state how your business carries out labelling compliance.
Some businesses produce labels in
house and produce the design themselves. Some businesses contract the services
of a designer and get the labels legally checked by an expert. Some businesses
have the labels provided to them by their customers, who will have already had
the labels checked for legal compliance. For other businesses, it can be a combination
of all of the above.
However it works for your
business, write it down in the procedure.
Labelling Compliance Checking
Evidence
Your products label compliance is
your responsibility. You need to ensure that it is compliant with the current legislation.
But where do you start? What needs to be on the label in the first place? Once
you have put all the detail onto the label from the list below, then you need
to make sure each element is checked for legality, either by yourself if you
have the knowledge, or by an expert.
When carrying out the process of
the labels being checked, you need to keep evidence of this A report showing
the label amendments, with a copy of the final label artwork. It’s also good
practice to have a copy of the finished product specification attached as well.
Here is your starting point:
1
Product Name
2
Legal Name / Description of the Product
3
Ingredients
4
Allergens
5
QUID
7
Minimum Durability (Shelf Life) Best Before Date
or Use By Date
8
Storage Instructions
9
Name & Address
10
Country of Origin
11
Instructions for Use
12
Alcohol Content
13
Nutrition
14
Claims
Product Name & Legal Name /
Description of the Product
The Product Name can be a fancy
name which you decide upon. However, the Product ‘Legal Description’
needs to describe to the consumer exactly what it is they are purchasing.
The ingredients you use in the
Product Name and Description have to be QUID’d in the ingredient declaration. Read
on to find about what QUID is!
The important thing to remember
is, you need to describe the product adequately to ensure the consumer
understands what they are purchasing.
Ingredients, Allergens
& QUID
The ingredients listing is very
important. You need to have the heading ‘Ingredients’ to start with. Then you
must list all ingredients in weight order. Highlight ALLERGENS usually
in BOLD CAPITALS. List the additives correctly. QUID the relevant
ingredients.
You also need the Allergen Statement
at the bottom of the ingredient list, to direct the consumer to the allergens
in the product, and the addition of any allergens which may be contained
through a cross contamination risk from your site, or from your suppliers site.
A statement such as: ‘For
allergens please see the ingredients highlighted in BOLD’
And additionally: ‘Made in a
facility which also handles XXX Allergens’
What is QUID?!!
QUID is the Quantitative
Ingredient Declaration. It means you have to quantify the percentage of the
named ingredient (from the Product Name & Product Description) within the
ingredient declaration.
Some businesses want to name a lot
of ingredients to show how much ‘good stuff‘ is in the recipe! Many businesses
do not want to name their ingredients as they do not want to give away their
recipe.
You need to have a happy medium
between protecting your recipe and describing the product sufficiently and define
its true nature.
Ingredient List
As you can imagine, there is a lot
of preparation required to make sure the ingredient declaration is correct.
Obtaining Ingredient Specifications
being one. On many occasions when chatting to people about their
labels for the first time, I ask if they have obtained the ingredient
specifications from their suppliers, which most of them have not. I cannot
stress enough how important this is. Your Ingredient Specification document tell
you a great deal of information about your ingredient you are purchasing. They
have allergen information on them, information about additives, nutrition,
ingredient component breakdowns etc. all of which you need to complete your labels.
A Risk Assessment of Allergens
being another important part of preparation. As mentioned above, the risk of
allergens is not just from those which are contained in the ingredients, but
also from those which you are handling on your site, and those being handled on
your suppliers site. If they have put on the Ingredient Specification (or on
their ingredient labelling) that there is a risk from other allergens, you must
consider them. If you handle other allergens in your facility, you either need
to swab to prove they are eliminated through cleaning, or they must be put as a
cross contamination risk on your label. This is where the statements of ‘May
Contain XXXX allergens’ or, ‘Made in a facility which also handles XXXX
allergens’
For further information on
Allergen Risk Assessments, read: SALSA Sussed Week 5 Contamination & Cross
Contamination Prevention Allergens
Additives in the
ingredients MUST be listed. You can choose to list the E number or the additive
name. Additives need to be listed, with a prefix which describes the particular
form of the additive, prior to the additive name. For example: Preservative
(Potassium Sorbate)
Net Quantity
The quantity by weight or volume
is required to be stated. If you are using average weight controls then the e symbol must be used. If you
are using the minimum weight controls, then you do not need the e symbol. You need to state
average weight if you are exporting. If you are distributing in the UK only, you
can use the minimum weight guidelines.
If you are producing a liquid then
you must provide the weight by volume in ml / litres.
If you are producing all other products,
the weights must be displayed in grams / kg.
A note to remember, whichever you
use, ml / litres, or grams / kg, your nutrition needs to be calculated
accordingly per 100ml or per 100g.
Minimum Durability (Shelf Life)
Best Before Date or Use By Date
needs to be applied to your product. This is likely to be applied separately by
an additional sticker, or by printing coding onto the product separately.
However, you need to have a directional statement on the label of where to find
the date label. Usually a statement such as: For Best Before / Use By, see
bottom of pack / see lid etc.
Your product shelf life needs to
be validated. Usually you would do this by sending your product to a lab for
testing. If you have an ambient stable product such as bread or biscuits, you
can carry out organoleptic sensory testing, as long as you keep evidence that
you have done it, and what the results are. Please contact me for help with
this!
Storage Instructions
You must state how the product you
are selling must be stored. Ambient Stable Products usually come with a
simple statement such as, ‘Store in a Cool Dry Place’. However, if it is a
chilled or frozen product you need to be more specific.
Frozen Products need to
have details of how long they can be stored frozen. How to safely defrost, how
to store once defrosted, then what timescale they need to be used by once
defrosted, needs to be stated. These, along with Preparation Instructions are
very important for these types of products. This will be very specific to your
product and must be validated to be true and correct instructions.
Chilled Ingredients storage
instructions, again, are very specific to your products. They need to be
validated. An example could be ‘Keep refrigerated, once open use within 3 days,
do not exceed the stated Use By Date’.
Name & Address
The name of the business, and
address of the Food Business Operator. This needs to be a physical address not
an email.
If exporting then you must add the
importer address in the country or union which you are exporting to. This is a
requirement exporting into Europe due to Brexit.
Country of Origin
Country of Origin or place of
provenance must be labelled as such for agricultural products and foodstuff.
There are mandatory foods which must declare Country of Origin, For rules and
guidance on what these are please visit the following link:
And those with Traditional
Specialities Guaranteed (TSG), and for those food stuff with Protected
Geographic Indications (PGI) and Protected Designated Origins (PDO). Please see
further guidance on the following link:
Instructions for Use
Instructions for Use are
preparation instructions. They need to be documented for the cooking
instructions of products, to make sure the consumer understands how to cook the
food so it is safe to eat.
Cooking guidelines should be
validated. You need to try, test and make sure the guidelines you provide are
sufficient.
Usually a statement to say that
they are guidelines and appliances may vary is also added to the instructions
too.
Alcohol Content
Alcoholic strength must be
displayed for beverages with over 1.2% by volume of alcohol. It should be
displayed in XX.X% vol alc. / alcohol to one decimal place.
Nutrition
Nutritional information needs to
be displayed in the format similar to the example below:
Nutrition Per 100g Unit
Energy (kJ)
Energy (kcal)
Fat g
Saturates g
Carbohydrate g
Sugars g
Protein g
Salt g
Nutritional information can be
calculated or tested by a lab. There are many systems available to help you
complete the calculations, or they can be completed by experts. Another service
that I am able to provide.
The important thing to remember is
that you have to display per 100g or per 100ml legally. You are permitted to
also provide per portion information but is not required.
Claims
There are many claims you might
want to make about your product.
Please see the link below for
permitted Health & Nutritional Claims:
https://ec.europa.eu/food/safety/labelling_nutrition/claims/register/public/?event=register.home
Other claims could include the
provenance claims we spoke about earlier… Traditional Specialities Guaranteed
(TSG), and for those food stuff with Protected Geographic Indications (PGI) and
Protected Designated Origins (PDO).
Other claims could include Organic,
Vegetarian, Vegan, Free Range, Homemade, UK Meat for example. All of these
claims need to be validated.
Use of logo’s such as the Vegan
Society logo comes with conditions of being certified to them, so everything
needs checking out to make sure.
Using pictorial references on pack
also need to be honest. If you have pictures of specific fruit on the pack,
there must be that fruit in the product you are making. You cannot mislead the
consumer in any way.
Customer provided labels
If you are using labels provided
from your customer, it is important that you are always using the most current
up to date labels they provide. The compliance of the label produced by them is
their responsibility, although if you noticed something non-compliant you have
an obligation to report it to them.
You also have to ensure they are
always informed of changes to your ingredients, specifically an allergens which
may require adding to their product label if there is a cross contamination
risk.
The further responsibility that
you have, is that you are using the correct label, not an old version. You may
have to have a checking system in place at Goods In, when they are delivered to
you, that is checked against a sample copy they provide.
That’s it for now folks!
Have a good week!
If you need assistance, please
feel free to contact me! On that note, that is the end of this section. Please
do not hesitate to ask any questions.
Be careful and stay safe!
Ruth
Ruthshawconsultingltd@gmail.com
07732
966 836
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