Food Labelling, Nutritional Claims and Composition
Environmental Health Officers in the Food Team carry out food standards inspection and interventions in food businesses to look at the quality, composition, labelling, presentation, advertising of food and the materials and articles in contact with food.
Food Standards Inspections
The aim of a food standards inspection is to assess that the food being produced is of the correct composition and is fairly described and labelled. The food offered for sale should not mislead the consumer.
This refers to any food put into packaging before being offered for sale for example a bar of chocolate, a sealed packed of crisps, a jar of sauce or a can of soup.
In the case of prepacked foods, mandatory food information must appear directly on the package or on a label attached to the packaging. The information must be in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It must not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.
Voluntary information must not be displayed to the detriment of the space available for mandatory food information.
For prepacked foods, the following mandatory information must appear directly on the package or on an attached label:
1. The name of the food*
2. The list of ingredients
3. Any ingredient or processing aid listed in Annex II of FIC or derived from a substance or product listed in Annex II of FIC causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form
4. The quantity of certain ingredients or categories of ingredients
5. The net quantity of the food*
6. The date of minimum durability or the ‘use-by’ date
7. Any special storage conditions and/or conditions of use
8. The name or business name and address of the food business operator
9. The country of origin or place of provenance where its absence may mislead the consumer as to the true origin or provenance of the food or where country of origin is specifically required under legislation
10. Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions
11. With respect to beverages containing more than 1.2% by volume of alcohol, the actual alcoholic strength by volume*
12. A nutrition declaration (note date of application)
*Must appear in the same field of vision
*‘Field of vision’ means all the surfaces of a package that can be read from a single viewing point
Non-prepacked food (Loose Foods)
Non-prepacked foods (also referred to as food sold loose) are those that are:
- not prepacked
- packed on the operator’s premises at the consumer’s request
In a physical retail environment this is likely to apply to foods which are sold loose from a delicatessen counter (e.g. cold meats, cheeses, quiches, pies and dips), fresh pizza, salad bars, bread sold in bakery shops, meat from butchers, pick and mix confectionery etc.
In a catering environment this is likely to apply to foods which are not sold prepacked, for example food from a takeaway, or meals served in a canteen or a restaurant.
Labelling of Non-Prepacked (Loose Foods)
Foods sold non-prepacked will require the following information be given on a label attached to the food, or on a notice, ticket or label that is easily read and in close proximity to the food:
- Name of the food, e.g. a pie or cake sold in a bakery with the name of food on a tab at the front of the product.
- Quantitative indication of ingredients (meat products only)
- Indication of allergenic ingredients (either on a label attached to the food or by displaying allergen signage inviting the customer to ask a member of staff for more information.)
Prepacked foods for direct sale
Prepacked for direct sale or PPDS is food that is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected e.g. sandwiches, pies, salads.
It can include food that consumers select themselves (e.g. from a display unit), as well as products kept behind a counter and some food sold at mobile or temporary outlets.
From 1 October 2021 the requirements for PPDS food labelling changed in England, Wales and Northern Ireland. Any business that produces PPDS food is now required to label it with the name of the food and a full ingredients list, with allergenic ingredients emphasised within the list.
Businesses need to check if their products require PPDS labelling and what they need to do to comply with the new rules. For further information: please visit Introduction to allergen labelling changes (PPDS) | Food Standards Agency
Natasha’s Law is a new allergen labelling law that affects prepacked for direct sale (PPDS) foods in Northern Ireland. Find out more at safefood | How to implement Natasha’s Law - see also this short video on Facebook
Allergen Labelling on Prepacked Foods
Allergenic ingredients must be emphasised in the ingredients list e.g. by use of font, style or colour. The use of a ‘Contains: followed by a list of allergens’ statement will no longer be permitted. Voluntary statements highlighting the risk of cross contamination with allergens may still be used.
For further information please visit Allergen labelling for food manufacturers | Food Standards Agency
If non-prepacked food is sold at a distance, such as food takeaway businesses which offer purchase through telephone/internet, you need to ensure that allergen information is made available to the consumer before they decide to buy the product.
Information about Food Date Labelling
What is the difference between a 'best before' and 'use by' date?
Most prepacked food must carry an indication of minimum durability. This is better known as either a best before date or a use by date. These dates must be marked clearly on the label. If this is difficult the manufacturer must state where the date can be found, for example, Best before: see date on lid.
Use by dates
Use by date is about safety and the most important date to remember! Foods can be eaten (and most can be frozen) up until the use by date, but not after. You will see use by dates on food that goes off quickly, such as meat products or ready-prepared salads. Foods that have to be stored at low temperatures to maintain their safety rather than their quality need to be labelled with use by dates.
You shouldn’t eat any food products that have passed their use by date as it may not be safe to eat. Even if the food looks and smells fine, using it after this date could put your health at risk and cause food poisoning. It's an offence for food business operators to sell any product after its use by date.
For the use by to be a valid guide, you must carefully follow storage instructions on food labels, otherwise the food might not last until the use by date. Usually food with a use by date must be kept in the fridge.
Best before dates
Best before date is about quality and not safety. The food will be safe to eat after this date but may not be at its best. Its flavour and texture might not be as good. The best before dates appear on a wide range of frozen, dried, tinned and other foods. The best before date will only be accurate if the food is stored according to the instructions on the label, such as 'store in a cool dry place' or 'keep in the fridge once opened'.
Certain foods don't have to be marked with a use by or best before date. These are:
- fresh fruit and vegetables, including potatoes which have not been peeled or cut into pieces (sprouting seeds and similar products must be date marked);
- wine, liqueur wine, sparkling wine and similar products;
- any drink with an alcoholic strength by volume of 10% or more;
- flour confectionery and bread normally consumed within 24 hours of preparation;
- cooking and table salt;
- solid sugar and flavoured or coloured sugar products;
- chewing gum and similar products
From December 2016 mandatory nutrition declarations for most pre-packed foods will apply.
There are certain foods which are exempt from this requirement which can be found in Annex V to the Food Information to Consumers (EU) Regulation 1169/2011.Exemptions relate mainly to minimally processed foods and those with little nutritional value. Food directly supplied by manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer is also exempt.
Some businesses may be able to avail of the exemptions to the nutritional requirement. This will apply when the following definitions of ‘micro business’ and ‘local sales’ are both met.
1. Manufacturer of small quantities: a micro business under the EU and UK definition i.e. less than 10 full time equivalent employees and a turnover/balance sheet total of less than €2m (or Sterling equivalent).
2. Local Sales: within the supplying establishment’s own county plus the greater of either:
i) the neighbouring county or,
ii) 30 miles/50 kilometres from the boundary of the supplying establishment’s county.
The Department of Health provides guidance on nutrition labelling.