Labelling

Trust the numbers? What McCance & Widdowson tell us about nutrition labelling

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In the UK, the assimilated food information regulation (EU 1169/2011) requires mandatory ‘back of pack’ nutrition labelling for the majority of pre-packed foods. The values declared should be the average values derived using one or more of the following methods:

• Manufacturer’s analysis of the food
• A calculation from the known or actual average values of the ingredients used in the preparation of the food, or
• A calculation from generally established and accepted data.

So let’s talk about ‘generally established and accepted data’

In the UK the Composition of foods integrated dataset (CoFID) is the official UK national food composition database and is available as a single electronic file, most recently updated in 2021.  The McCance and Widdowson 7th Edition book, last published in 2015, contains a subset of data from the CoFID 2015 version.

The dataset provides macronutrient and micronutrient profiles of commonly consumed food and recipes including cereals and cereal products, milk and milk products, eggs and egg dishes, fats and oils, meat and meat products, fish and fish products, vegetables, herbs and spices, fruit, nuts and seeds, sugars, preserves and snacks, beverages, alcoholic beverages and soups, sauces and miscellaneous foods.  All foods are expressed per 100g edible portion, unless otherwise stated, and alcoholic beverages are expressed per 100ml.

CoFID as we know it today began in the 1930s with the vision of Dr Robert McCance and Dr Elsie Widdowson.

“A knowledge of the chemical composition of foods is the first essential in the dietary treatment of disease or in any quantitative study of human nutrition’” – (McCance & Widdowson, 1940)

Public Health England are now responsible for maintaining data on the nutrient content of the UK food supply to support the National Diet and Nutrition Survey, and it is data from this work that is used to update CoFID.  Food composition data is updated for many reasons including new foods being introduced, existing foods being reformulated as well as new farming and manufacturing processes.

Using CoFID values on food labels

If you have ever used CoFID or 7th edition of McCance & Widdowson, you will no doubt be aware of the guidance notes on pages 15-17 (or pages 21-24 if you have the book).  If not, then it is really important you read that section so that you are aware of the differences between some values listed in the dataset compared to the requirements of the current food labelling regulations. In summary:

Protein – means the protein content calculated using the nitrogen content x 6.25, whereas more specific factors have been used in the CoFID dataset.

Carbohydrate – is provided in the dataset as its monosaccharide equivalents (mse), whereas for labelling it should be the weight of the carbohydrates themselves. The following factors should be used to convert mse to actual weights:

Energy values – are to be calculated for food labels using the conversion factors provided in annex XIV of EU 1169/2011:

Alternative datasets

On occasions it is necessary to use nutrition values from a different food composition database, a common one is the U.S. Department of Agriculture’s USDA National Nutrient Database for Standard Reference.  It is just as important to make sure you understand the differences in the dataset compared to UK labelling requirements, for example total carbohydrate by difference includes the fibre content and so this requires adjustment before using.

With more than 25 years’ experience in food and nutrition labelling, AB Food Nutrition helps you produce compliant nutrition declarations for menus and product labels, whether you’re selling in the UK/EU, US, Canada or Australia. Our service is straightforward and cost-effective. We calculate the nutrient profile of your recipes from the ingredients, quantities and cooking methods you use, and we can recommend ways to improve their nutritional profile so you can offer customers healthier choices.  For more information, please contact Anne.

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UK Government delays some EU food labelling rule changes

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Following the UK exit from the EU, the UK Government had put in place a period of adjustment (21 months) for labelling changes to goods produced or imported and placed on the GB market. This period of adjustment was due to end 30 September 2022.

Due to the current cost of living crisis and to protect consumers from being passed any associated administrative costs, the Government has announced delaying these labelling rule changes from 1 October 2022 to 1 January 2024. This means that some labelling terms including EU Food Business Operator addresses and UK/EC health marks will continue to be permitted on the whole of the GB market for an additional 15 months.

The labelling rules affected include:

With the extra 15 months grace period to get your labels updated, check out this useful, frequently asked questions guide with responses from DEFRA’s Food Information to Consumers Team. A copy of the full note from DEFRA about the extension period is available below:

With over 20 years experience in ensuring regulatory compliance of food labels and specifications and carrying out nutrition analysis for back and front-of-pack labelling, AB Food Nutrition can review your product artwork and highlight anything that needs to change, suggesting ways you can amend so that you they meet the latest regulations and industry best practice.  Contact Anne for a competitive quote today.

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Tips for reviewing your food & drink label artworks

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We are now a good few weeks into the post-Brexit era and navigating our way through the changes and challenges this has brought to the food industry.  The final months of the transition period were particularly busy for anyone concerned with the regulatory aspects of food labelling – making sure necessary changes were in place before the 30 December 2020 deadline so that products could continue to be sold throughout the EU.  That work still isn’t quite finished yet but thankfully for those of you who only sell to the UK market there is a bit of breathing space until 2022 to get everything in order.

The monumental increase in label/artwork checking in the latter part of 2020 meant there was clearly not enough hours in the day to lose reviewing amended versions 2 or 3 or beyond, and so it was highly important to make sure everything was correct or that all of the necessary amendments had been identified at version 1.  The way I generally approach this is to follow a four stage review process, which I thought might be useful to share with you.

  1. Is it the correct product/recipe?
  2. Is the information technically correct as per the regulations?
  3. Is the information consistent?
  4. Read it again through the eyes of a consumer.

Before you start, make sure you have set aside enough time to do the review adequately and get rid of any distractions.  If you are going to spot mistakes then you need to concentrate.

Stage one

You will know exactly what I mean here! You have literally spent months (or longer) developing your product and modifying the recipe to perfection, so by this stage you must be absolutely sure you are using the correct and final recipe to establish your ingredients list, allergens and nutrition information.  A few quick sense checks here and there are useful too – for example, if you know you are adding 1% salt to your product – do the nutrition values match and is there at least 1g/100g salt declared?  

Stage two

This is the bit that understandably takes the longest.  First, you need to be confident that you know which pieces of legislation apply to your product. You must check carefully that all the mandatory information is included and presented correctly as specified in the regulations. For example, in addition to the selling title, have you included a suitable legal name for the food such as a customary name or a sufficient descriptive name? Are the ingredients all declared is descending order by weight including the sub-ingredients of any compound raw materials? Have you highlighted every allergen in the ingredients list? Is the nutrition table in the correct format/order?  Are you making any authorised nutrition or health claims – and does your product comply with the necessary conditions?  If you happen to be making products that are sold under a retailer own brand then you will have the retailer’s labelling policies to consider as well.

Stage three

Consistency of the information on your artwork can mean two things. One, being consistent with the other products you already manufacture and sell – to convey your brand identity, and two, for consistency with other brands of the same or similar products.  Compare to see if you are providing the same general information as the other brands and haven’t overlooked anything vital. Take care here though and don’t always assume that the other brands are 100% legal.

Stage four

Finally, have a look at your new label from a consumer perspective. Absolutely no spelling mistakes! (Apparently, proof-reading backwards helps with this as it stops you from skimming the text – give it a go!). Is there anything that isn’t clear and might prompt consumer queries? Is photography realistic and representative of what will be inside the pack?  Is the design eye catching and can consumers easily compare your product to something similar when they are walking down the shopping aisle?  Is there enough contrast between the colour of the text versus the background and is the font type used clearly legible?

We’ve still got some time yet to get all our UK packaging compliant before October 2022, and I hope my hints might help make the process more structured for you whenever you are launching a new product or redesigning existing.

If you would prefer to outsource this important task, then don’t hesitate to contact a food regulatory/labelling expert who already does this crucial work day in and day out.

With over 20 years experience in ensuring regulatory compliance of food labels and specifications and carrying out nutrition analysis for back and front-of-pack labelling, AB Food Nutrition can review your product artwork and highlight anything that needs to change, suggesting ways you can amend so that you they meet the latest regulations and industry best practice.  Contact Anne for a competitive quote today.

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The rise of home food businesses

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This is the first blog I have had chance to write since the UK was placed into Covid-19 lockdown (100 days ago today!) so I would like to start by saying that I hope you and your families are well whether you are working as normal or have found that work is now busier/quieter than usual or you have had to adapt to working whilst simultaneously home schooling the kids.

One observation that became apparent when we entered the strange world of lockdown was a return of community spirit.  It was admirable to see people helping neighbours with grocery shopping and even putting their own home economic skills into good use making food accessible and available to those who were self-isolating or shielding.  It was also understandable why those on furlough or who have lost most of their income, would seek alternative ways to make money by using their cooking/baking skills whilst staying at home. 

However, as all existing food business owners I’m sure will agree, starting-up a food production business is no easy task and brings with it huge responsibilities.  It’s not just as simple as make food and sell it – there are a raft of legal obligations and standards in place to ensure products are safe to consume, are made following strict hygiene regulations and that product information is presented to a standard that does not put people’s health at risk. 

First and foremost, if you wish to start preparing, cooking, storing, handling, distributing, supplying or selling food – you must be registered as a food business operator with your local authority. This is free to do, and the registration cannot be refused.

It is an offence to operate a food business without being registered – and this includes voluntary, charitable, people operating at home and via the internet as well as those on the high street.  It doesn’t exclude people who are operating from home even if the food is supplied for free.  If you are simply baking a couple of times a year for the school fete then this wouldn’t require registration but producing a tray bake once a month for a café for example, would.

Once registered, you may be inspected and given a food hygiene rating, so it’s important to ensure you have all the right procedures and record keeping in place from the start.  If you are new to the food industry it is most likely (and highly advisable) that you will require appropriate training/mentoring/experts to help you with the following start-up checklist:

  • Does the design & construction of your food preparation area meet legal requirements?
  • Have you invested in the right equipment?
  • Are you aware of the main food law requirements?
  • Do you keep written records of all the food ingredients you are buying or being supplied with?
  • Have you put food safety management procedures in place and are the records kept up to date?
  • Do you understand the principles of good food hygiene?
  • Have you considered health & safety arrangements?
  • Have you registered as self-employed?
  • Are you keeping records of all your business income and expenses?
  • Do you describe/label food and drink accurately and in compliance with legislation?
  • Are you aware of all the allergens in your products, including those present in your home for domestic use and are they communicated properly?
  • Is the packaging you are using suitable for food contact?
  • Do you have public liability and product liability insurances?
  • Do you need to apply for a licence to sell alcohol or hot food between 11pm and 5am?

The Food Standards Agency has developed this useful ‘Safer food better business’ pack specifically for small catering businesses.

I also asked some fellow North West food & drink businesses who have been there and done all the above to share their top tips for start-ups:

“Do your research and then check, check and check again. Then get someone qualified to check it too! Don’t just copy existing similar products on the shelf as its 99% certain NOT to be suitable to copy especially where weights and measures and the Estimate symbol are concerned.” The Nowt Poncy Food Company Ltd, @nowtponcy

“My tip is the Safer Foods Better Business website. It’s got all the documents and paperwork you need, and plenty of guidance. Make sure you register with the local authority, and use them for advice and guidance as well as inspection, they are there to help as well.” The Sunflower Kitchen, @TheSunflowerKi1

“Ensure your labels are up to date with the necessary information and have the correct allergen advice.”  Farm Yard Ales, @farmyardales

Whilst this article aims to point out the main things for you to consider when starting a food business, the good news is that there is absolutely no reason why properly-registered people should not sell food they have prepared at home – it can be done safely!

With over two decades of food industry experience, Anne founded the award-winning AB FOOD NUTRITION to work closely with businesses of all sizes ensuring they can fully inform consumers about the ingredients, allergens and nutrition information legally, whilst also enabling them to make healthier dietary choices.  Contact Anne for further information about our nutrition and labelling services.

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4 reasons you need a food & nutrition labelling consultant

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Maybe you are puzzled at why companies might hire consultants instead of solving their own problems themselves? As much as I hate to hear it, that question does make sense however, there are many reasons why a company might need to use a consultant to help with their nutrition and labelling obligations (and also why I am able to keep working with some of the coolest foodies in the industry!).

 

You might not want the responsibility of verifying all the information on your own

Labelling rules are strictly regulated and can get complicated when trying to establish if you have included all the mandatory information correctly, taken account of the minimum type sizes for the text on your label in addition to any specific declarations that may apply to your product type.

A labelling consultant is there to support you in producing compliant labels.  They are the experts who know what can or cannot be printed on the label and they are aware of which sets of regulations will apply to your product type no matter how complex that may be.

You are just starting out in the food industry

No doubt you have done tons of research looking at competitor products so that you can make your label the best and the most eye catching.  However, if your competitor makes certain claims on their packs, this doesn’t mean that you should too.

Consultants will advise you what is compliant rather than what sells best in the market place.  Brands who break the law do so at their own risk and are likely to be challenged by the authorities eventually.

You don’t have the time to learn about labelling laws

Perhaps you are launching several products at once or have just won a new retail contract with a very tight launch timeline.  Maybe you just don’t have the energy or desire to check your label designs are compliant amongst all the other important tasks required in the running of your expanding business?

By nature, consultants will provide advice that clearly keeps their client within the law, so do exactly what a labelling consultant tells you!!  Obvious I know, but there are so many regulations under constant change, it would be almost impossible for small businesses to keep up. Once you have established your product portfolio and had your labels reviewed, it should become a routine task to add more SKUs in the future if they are of similar ingredients.

You want to hire an experienced and knowledgeable labelling expert

In an ideal world, you would have a team of experts in-house, but the reality is, the number of hours and frequency you would need them means employing these experts full-time is not an option.

This is where the flexibility of using a consultant really comes into its own. You only pay for the services/time the consultant provides.  You also benefit from projects being completed speedily because your consultant (unlike in-house employees) isn’t distracted by other business tasks.  This means good value for money!

It may seem like a big investment or effort to employ a food and nutrition labelling consultant, though you may find that you are eligible for funding or grants that will cover some or all of the fees.  AB Food Nutrition specialises in working closely with organisations of all sizes and has years of experience supporting new and small food businesses not just in the North West, but across the UK. Contact Anne to discuss your requirements for a cost-effective food & nutrition labelling quote.

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