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The 10 most common labelling mistakes
Labels on food products traded within the European Union (EU) must comply with the applicable European legislation. This legislation can be found in EU Regulation 1169/2011. Some countries have also drawn up additional national legislation. The amount of information required on labels means that sometimes things go wrong. What are the 10 most common labelling mistakes made by companies? This research was conducted for the Dutch market.
1. Faulty additive listing
The name of the additive is not always written as stated in Additive Regulations 1333/2008. Punctuation marks, such as brackets or colons, are not always used consistently within one ingredients list. Other mistakes include omitting the category name when declaring E-numbers.
2. No nutritional value table
The mandatory nutritional value table is sometimes not included on the packaging. And sometimes the spelling/notation of the various nutrients is also not as prescribed.
3. Legally incorrect name
Choosing a good legal name for a product is often more difficult than it would appear. For example, if a product contains sweeteners the term ‘with sweeteners’ must be added to the product name. In practice this is not always the case. Frozen products sometimes lack the addition ‘frozen’.
4. Incorrectly stated expiry date
The stipulations for stating the expiry date can be found in Appendix X of Regulation 1169/2011. Although this is one area you might expect to be fairly problem-free, mistakes in the way the dates appear in the DD/MM/YYYY and MM/YYYY formats are common. In addition, the required ‘clear reference’, for example ‘see packaging’, is not always clear enough.
5. Repetition of allergen information
According to an official communication from the European Commission dated 13 July 2017, repeating the presence of allergens outside the list of ingredients is not permitted. According to the Food Labelling Manual (Handboek Etikettering van levensmiddelen) published by the Dutch Food and Consumer Product Safety Authority (Nederlands Voedsel- en Warenautoriteit (NVWA)), the chance of errors when repeating the information is high, which increases the risk to consumers. The repetition is often incorrectly applied on labels.
6. False claims
Regulation 1924/2006 provides guidance regarding which claims are permitted, for example the amount of a nutrient that must actually be present in order to claim that its presence. Sometimes the quantity of nutrients is not stated on the packaging either in the nutritional value table or elsewhere. A health claim must be approved by the European Commission via the EU Register of Health Claims. Companies can also use the EU Directory of Nutrition and Health Claims to check the wording of a claim.
7. Information in another language
As a rule, a label must be written in a language that can be understood by the consumers in the country in which the product is marketed. This is an attention point because in practice the regulations are not always applied correctly, especially in the case of imported products.
8. Images that include ingredients not actually present
To avoid misleading consumers, the images on the packaging must not depict any ingredients that are not contained in the product. Additional ingredients may be shown if the image is clearly captioned as a ‘serving suggestion’ and the image also makes this obvious.
9. Incorrect mention of aromas/flavourings
9. Incorrect mention of aromas/flavourings The inclusion of aromas/flavourings in the list of ingredients and in the legal name of the product is also regulated through legislation. Mistakes are frequently made in this area. For example, the term ‘X-aroma/flavouring’ may not be used if the named aroma/flavouring (in this case let’s assume the ‘X’ stands for vanilla) only tastes like vanilla but does come from actual vanilla. In products intended for sale in the Netherlands the use of alternative terms, such as ‘smaakstoffen’, is not permitted.
10. Incorrect indication of weight or volume
Finally, the rules regarding weight and/or volume are not always observed. The contents of the packaging must always be stated in the same field of view as the legal name of the product. The font size used must also increase in parallel with the dimensions of the packaging.
Reduce the allergens in your product(s) with Dutch Spices
Would you like more certainty regarding the statements related to the allergens in your food products? There is another option – you could reduce the presence of allergens by using Dutch Spices’ seasonings. Our herb & spices mixes, sauces and marinades only include ingredients that comply with the allergen safety, vegan and halal guidelines, with a BRC and Halal certification. We also ensure no cross-contamination with allergens in conformance with the VITAL-standard. In a nutshell: Dutch Spices means ‘Freedom of Taste’.
If you would like to know more about reducing the allergens in food please feel free tocontact us.
More information about labelling can be found in the Handboek Etikettering NVWA or on the VMT website.