Implications of EU allergen regulations

As of 13 December 2014, new rules on food and allergen labelling came into force. But what are implications and do any ambiguities remain? Cesare Varallo writes for Foodservice Consultant

The aim of the new rules is to ensure that consumers receive clearer, more comprehensive and accurate information on food content, helping them to make informed choices about what they eat. The new Regulation replaces the old Directive 2000/13/EU, which has now been repealed.

Some of the key changes to the labelling rules are outlined below:

  • Improved legibility of information (minimum font size for mandatory information, now 1.2 mm in the most of cases )
  • Clearer and harmonised presentation of allergens (e.g. soy, nuts, gluten, lactose) for pre packed foods (emphasis by font, style or background colour) in the list of ingredients
  • Mandatory allergen information for non-pre packed food, including those sold in restaurants and cafes
  • Requirement of certain nutrition information for majority of pre packed processed foods (applicable from 13th December 2016
  • Mandatory origin information for fresh meat from pigs, sheep, goats and poultry (Reg. (EU) n. 1337/2014)
  • Same labelling requirements for online, distance-selling or buying in a shop
  • List of engineered nano materials in the ingredients
  • Specific information on the vegetable origin of refined oils and fats
  • Strengthened rules to prevent misleading practices
  • Indication of substitute ingredient for ‘Imitation’ foods
  • Clear indication of “formed meat” or “formed fish”
  • Clear indication of defrosted products
  • Clear indication of added water, especially in meat and fish products

Although food business operators have been given three years to ensure a smooth transition towards the new labelling regime, some aspects are still unclear, particularly where legislation is not unified throughout the EU and the commission left space to national legislation.

There is also an ongoing study on the feasibility of a EU database to facilitate the identification of all EU and national mandatory labelling rules in a simple way. This should offer a user-friendly tool for all food business operators and SMEs, but it will not be ready at least until the second part of 2015.

Guidelines were recently published on the DG Sanco website which related to the indication of the presence of allergens. The document is the subject of a public consultation that will end on 4th January 2015 and it covers also some aspects related to non-prepacked foods.

On 31st January 2013, the EU Commission published the first – and until now only – document of clarification of some specific provisions: Questions and Answers on the application of the Regulation (EU) N° 1169/2011 on the provision of food information to consumers. More Q&A and guidelines documents are expected to be published in the next few months: they will cover different topics, in particular general labeling, nutrition labeling, the QUID (Quantitative Ingredients Declaration) and specific products’ type (i.e. meat and fish).

Cesare Varallo is a food lawyer and founder of He blogs for Foodservice Consultant on legislation and labelling

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