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Food labelling

As a result of these areas of work moving from the Food Standards Agency (FSA) to Defra, guidance notes for legislation are currently in the process of revision. They will be published on this website once completed.  In the meantime the National Archive holds a page containing the guidance as published by the FSA for your information.

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The current situation and background

Food labelling is the means by which consumers get information about their food. It is important this information is accurate and not confusing so consumers can make informed choices about the food they buy.

Legislation sets requirements for food labels in the UK. The legislation also aims to ensure food labels are an honest presentation of food.  Food labels are a useful source of information, primarily to inform consumers and enable them to make a decision on which food to buy. Through the requirements in place it makes sure of consistency for the industry and for consumers so they can find the information they need to make these food choices.  Much of the Defra’s current work on labelling is to help make sure people get the information they need in an understandable form.

Note: Food labelling legislation is harmonised at an EU level. The responsibility for food labelling legislation and policy is split across three government departments, Defra, the Food Standards Agency (FSA) and the Department of Health.  

  • Defra is responsible for labelling legislation in England that is principally non-safety and for the coordination of labelling policy across Government. 
  • FSA is responsible for legislation on labelling and standards that are principally safety based. 
  • Department of Health is responsible for nutrition labelling policy in England.

For Scotland, Wales and Northern Ireland all domestic labelling and standards legislation is the responsibility of the Food Standards Agency.  Further information can be found on the FSA website.

General

Food labelling legislation ensures consumers are not mislead as to the nature of food products when it is sold to them.  It also makes sure a level playing field for food producers, so they have clear requirements on the information that appears on the label and how this is presented. Currently this is enforced in the UK through the Food Labelling Regulations 1996 (as amended).

General labelling legislation covers a wide number of pieces of information that are found on a food label. This includes the rules on the ingredients list, date marks the name of the food, as well Country of origin labelling. The legislation on food labelling is developed in Europe, with full involvement from UK Government officials. 

Food information regulation

New Labelling rules are under negotiation in the EU. The European Commission issued a proposal for a new Food Information Regulation on 4 February 2008. This proposal follows an EU-wide review of both general food and nutrition labelling legislation, which began in 2004.

The proposal will bring EU rules on general and nutrition labelling together into a single regulation which will simplify and consolidate existing labelling legislation. The Regulation once agreed will be directly applicable in all Member States and replace existing legislation in this area in the UK. Defra has responsibility for coordinating the UK’s input into the negotiations. The responsibility for nutrition labelling policy aspects of the proposal have moved to the Department of Health. 

Negotiations on the dossier are ongoing. This proposal is a co-decision dossier which will require agreement between the 27 members of the Council and input from the European Parliament. This is a complex process and we will continue to update stakeholders as progress is made in the negotiations on the proposal.

Marketing terms

Marketing terms are phrases used by business to inform the consumer about the nature of their product. Many of these terms such as ‘fresh’, ‘pure’ and  ‘natural’ are not defined in law but when used must not be misleading for consumers. To assist industry with using these terms consistently, best practise guidance was developed. This guidance also assists enforcement officers identify misleading labelling.

Guidance has also been developed for the use of the terms ‘vegetarian’ and ‘vegan’ to assist consistent use of these terms in the UK. The aim of the guidance is to make sure where these terms are used they are consistent and in a way consumers understand.

Clear labelling guidance

The labelling legislation requires that product information on food labels to be easily visible and clearly legible. Information from consumers suggests that some people find labels difficult to use. To help industry improve the way in which information is presented on labels, best practise guidance was developed to highlight some of the factors that affect label clarity. The aim is assist industry with designing labels that allow consumers to access the information they need more easily.

Publication of research findings into the costs of labelling changes on the UK food and drinks industry

There are existing requirements for the labelling of food and drink products under UK law.  The EU wants to consolidate these into a single Regulation and a Commission proposal for changing existing EU legislation is currently under discussion. The draft EU Food Information to Consumers Regulation, which sets out new requirements for clarity of labels and for the labelling of alcoholic drinks, is an example. Until now, both Defra and the Food Standards Agency (FSA) have had only relatively limited cost data on which to draw when considering proposals for labelling changes.

When government consults on proposed changes to labelling requirements, stakeholders suggest these are likely to increase costs, particularly if there is a limited transitional period over which to phase in the new labels. However, evidence on the scale of increased costs is difficult to obtain.

After discussion with the FSA, Defra commissioned Campden BRI, the food and drink research consultancy, to undertake research to develop an evidence-based framework to assess the costs of food and drink labelling changes in the UK. Their work commenced in July 2009. The objectives for the research were:

  • Identification of the drivers of labelling changes, and how label information and format interacts with, and influences, food and drink product development
  • To conduct a sector and market analysis of the labelling industry
  • Identification of the size and nature of different cost components of labelling changes
  • Identification and estimation of any hidden costs of meeting mandatory labelling changes. This included consideration of the cost arising from the waste of obsolete stock, where unavoidable (eg disposal costs)
  • Identification of the points on supply chains these hidden costs are incurred, and the degree to which the costs of labelling changes are passed on to the consumer
  • An assessment of the implications of labelling changes for market structure and competition

The consultants invited 664 businesses to complete the survey questionnaire on costs. The survey response rate was relatively low – 12%. While not statistically robust, the project has furnished Defra with a set of indicative re-labelling costs, which can be used to inform stakeholder discussion.

The project findings have also greatly improved Defra’s understanding of the drivers of both imposed re-labelling costs  and “business as usual” labelling costs for a range of products and packaging types, and the practicalities of labelling/packaging design and production.

The main findings of the research are:

  • The reported costs of label changes per stock-keeping unit are somewhat greater than those previously quoted by the European Commission and in UK impact assessments
  • Re-labelling costs vary widely, from £1,800 to £6,500 per stock keeping unit. This variation is driven by factors such as the size of the business concerned, the printing technique used, the packaging material, and the complexity of the label change
  • Commercial factors are the cause of most label changes; changes caused by regulatory requirements accounted for a relatively small minority. Therefore, the cost of regulation-based label changes can be reduced by lead-in times of sufficient length to allow for the alignment of those changes with commercially-driven changes.

For enquiries, please contact: foodpolicyunit@defra.gsi.gov.uk

Relevant legislation and regulations

See also

Page last modified: 19 January 2011