One year on from the implementation of the EU’s FIC/FIR/EU 1169 allergen provisions, their impact on the food industry has been widely felt.
Early in 2015, we saw a lot of confusion regarding exactly what was required on labels and in stores. Different approaches to both education and enforcement between local authorities, discrepancies in advice published by government and industry bodies, plus a lack of transparency in the supply chain all contributed to ongoing perplexity and complacency regarding the issue. Estimates place non-compliance in certain sectors as high as 80%!
As the year has worn on, however, the dust seems to have settled on allergen legislation. As more businesses become aware of the help that primary authorities and advisory bodies such as Campden BRI can provide, a semblance of standardisation is beginning to form.
Still, with more than 80 allergen-related product recalls this year – many by large multiples – it is clear that manufacturers are still struggling with their allergen and ingredients’ labelling. And with the sector’s renewed drive for innovation and reformulation, keeping food information accurate, consistent and up-to-date is still a huge challenge for many.
Quite a few firms were given grace periods by enforcement officers on allergen provision due to the complexity and relative novelty of the new rules. It is unlikely, however, that the same approach will be taken with nutrition. Manufacturers will have had almost four years to prepare for requirements that are not radically different from the standards voluntarily employed by many FBOs already.
On December 13, 2016, the second round of FIC provisions, largely focused on nutritional information, will come into force. This will mean that all pre-packed foods will be required, as a minimum, to provide nutritional information per 100g of the product.
As with allergens, we can expect to see some significant upheaval over the next twelve months as food businesses prepare themselves for the final round of changes to their food information. So we asked our own industry experts for their three top tips on how to handle this year’s changeover:
Supplier information: chase early, chase often
Your recipe information is only as good as the data it is built from so it is important that you have the right information about your suppliers’ products. We all know how difficult it can be chasing suppliers for up-to-date information on your ingredients, so make sure you start requesting product specifications and up-to-date nutritionals as early as possible so as not to be left with gaps in your recipes come December.
When in doubt, seek advice
There are a number of professional organisations that can provide education and training on FIC and food information in general. Research and training bodies such as Campden BRI or the Institute of Food Research provide both training and calculation services for product nutrition, as do many independent consultants.
If you are a member of a trade organisation, ask them if they provide education on FIC (many of our Infood partners offer these types of services). It is better to commit time and money now than face angry Food Standards officers later.
As with allergens, providing nutritional information can, at first, seem like a daunting, unending drain on resources. The slightest changes in a supplier’s product can have wide-reaching consequences across multiple product lines and, if managed incorrectly, lead to wasted stock or even a recall.
To avoid getting overwhelmed or caught out, establish a system for auditing and updating your recipe information and stick to it. Remember that, legally, there is no distinction between lab-tested, calculated and McCance & Widdowson nutritional information, so work out which method is most cost- and time-effective for your business (hint: if you have more than a few different lines, it is probably not lab-testing).
Once you have a system in place for ensuring your information is accurate, make sure that it is followed and that your staff know what steps need to be taken to update labels and specifications.
Process-driven IT systems make this task much easier as well as reducing the margin for human error, so consider investing in a food information system to save on time, money and mistakes in the long-run.
So there you have it. Don’t let FIC get you down in 2016 – but ensure you have systems in place to handle it before December 13.
John Prendergast is a sales executive for Infood, the cloud-based food information system from RedBlack that generates FIC/FIR/EU 1169/2011-compliant allergen and nutritional information for labels, product specification documents, till receipts and web pages.