Future labelling trends

Following on from the publication of the Green Paper on Food Law by the European Commission, which recognised the need to review and consider whether or not current labelling requirements best satisfy the information needs of consumers, a number of aspects of food labelling are under review. The provision of information to consumers is considered to be of paramount importance, in order to allow them to make informed decisions, and is becoming increasingly recognised as essential where a public health risk is concerned. It has not, therefore, been surprising that the labelling of potentially allergenic compounds in foods has become a key issue, particularly as product liability laws will also need to be considered in the event of a consumer having a reaction from an unlabelled product. Although a number of countries have their own provisions in place or at the proposal stage, there is considerable interest in the Codex and EC proposals in this respect. Owing to the reference role of Codex standards in World Trade Organisation agreements and possible trade disputes, many countries will undoubtedly focus on Codex provisions once agreed. Adoption of an amending Directive at EC level will have direct implications for each of the EU Member States and for those wishing to become part of the expanded Union in the future.

Two issues are apparent and of concern in proposals that have been published so far. The first aspect is the need for any list of potentially allergenic or hypersensitive ingredients to be based on scientific evidence and to be established in such a way that it can readily be changed if required, for example by addition of a new ingredient. The second issue concerns that of non-prepacked foods and foods prepacked for direct sale. Such foods are often outside the scope of labelling regulations (for example Directive 79/112/EEC, as amended), but may be the more significant potential problem in this area. Possibly the use of tickets or notices for labelling is an option, and staff knowledge and training are of paramount importance. Currently, it is up to countries' individual regulatory requirements whether or not such labelling is required. As food labelling regulations continue to reflect consumer safety and information needs, it is inevitable that more and more countries will include provisions on the labelling of potentially allergenic substances in their national law. The importance of Codex and EC provisions in this area cannot be overestimated as, once agreed, they will play a significant role in minimising the potential for the labelling of ingredients causing hypersensitivity to form trade barriers.

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