What is FIR?
The Food Information to Consumers regulation is an EU directive (number 1169/2011) that dictates how allergen information, ingredients, origins, nutrition and shelf-life is given to consumers. FIR is the British government’s enactment of this legislation and came into force in December, 2014.
Failure to comply with FIR can lead to notices from local Trading Standards and/or a £5000 fine for each breach of regulations.
Which allergens are covered?
The allergens are: Eggs; Milk; Fish; Crustaceans (e.g. crab, lobster, crayfish, shrimp, prawn), Molluscs (e.g. mussels, oysters, squid); Ground Nuts (e.g. peanuts); Tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazils, pistachios, macadamia nuts, Queensland nuts); Sesame (e.g. sesame seeds); cereals containing Gluten (i.e. wheat, rye, barley, oats, spelt, kamut, or their hybridised strains); Soya (e.g. soybeans); Celery and celeriac; Mustard; Lupin; Sulphites at concentration of ten parts per million.
Which rules apply to me: loose food or pre-packed?
Pre-packed foods are usually made by one business and sold by another such as a retailer or caterer. Loose or foods that are not pre-packed describe everything else. This includes foods that are wrapped on the same site as they are sold, such as in a sandwich bar, bakery or from a delicatessen counter.
What are the FIR rules for loose foods?
How do I provide the information for loose foods?
Signposting allergen information
Where allergen information is not provided upfront in writing, signposting a customer to where they can get this information is required.
Your sign should be where customers expect to find this information; for example, where they would be making their food orders such as at the till point, on the menu board or menu, on the shelves or on the counter.
Written allergen information
This can be provided on menus, menu boards, on websites or printed from your EPoS till system. With Infood, for example, you can automatically feed the right food information to your EPoS tills, websites and menus.
Specification folders that contain product specification sheets, ingredients/recipe labels or charts of the dishes provided and their allergen content can be used to communicate or aid communication of allergen information to the consumer.
However, these can quickly become out-of-date and require constant monitoring. With Infood, product specification sheets are generated automatically and reflect any change in recipe, however slight. This ensures the accuracy you now need when communicating allergen safety advice to your customers.
Telling a customer about allergens
Allergy information can also be provided as part of a conversation with the customer as well as using any of the ways described above. However, verbal communication does rely on the ability of your staff.
Remember: you must ensure the information provided is accurate, consistent and verifiable. Staff error can be catastrophic when it comes to food allergens. With Infood, you have one version of the truth that is always up to date. Staff read off the correct info or print it out from their tills or just show it to the consumer on-screen.
Other ways of selling
If food is sold at a distance, such as via a telephone order for a takeaway meal, the allergen information must be provided before the purchase of the food is complete (this could be in writing, verbally or the customer could be directed to your website).
Or it can be in a written format when the food is delivered, i.e. on a product label or till receipt. Either way, Infood has it covered and you can be sure that all the information that consumers are given is accurate, verifiable and auditable.
What are the FIR rules for pre-packed foods?
How do I provide the right information for pre-packed foods?
INGREDIENTS: Water, Carrots, Onions, Red Lentils (4 .5%) Potatoes, Cauliflower, Leeks, Peas, Cornflour, Wheatflour, Salt, Cream, Yeast Extract, Concentrated Tomato Paste, Garlic, Sugar, Celery Seed, Sunflower Oil, Herbs and Spice, White Pepper, Parsley.
You may also decide to use an allergy advice statement on the product label to explain how allergens are emphasised within the ingredients list. For example: “Allergy Advice: for allergens, see ingredients in bold“.
Allergens should be declared with clear reference to name of the allergenic ingredient as listed in the EU FIC Annex II. If the ingredient name contains the allergen, then the allergen should be highlighted within the ingredient name, (e.g. Mustard seed, wheat). Otherwise, it should be listed afterwards, for example “tofu (soya)” or “tahini paste (sesame)”.
If there are several ingredients or processing aids in a food which come from a single allergen, then the labelling should clearly emphasise each ingredient or processing aid concerned – for example “skimmed milk powder, whey (milk)…”
Infood automatically generates the right labelling information. What’s more, because of the unique way Infood works, its alert system prevents errors. If, say, an improver has an allergenic ingredient that may not be immediately apparent, the system informs its user.
IMPORTANT: The voluntary use of allergen statements such as “Contains: milk and nuts” to repeat allergen ingredient information already given in the ingredients list is no longer allowed.
What if I am distance selling?
The allergen information needs to be made available at the point of purchase and upon delivery so that allergen information is made available to the consumer before they decide whether or not to buy the product.
What about precautionary allergen labelling?
This type of labelling is voluntary and is not covered by the provisions set out in FIR. It should only be used following a thorough risk assessment when you think there is a real risk of allergen cross-contamination that cannot be eliminated.
What about “free-from” labelling?
Where does front-of-pack nutritional information fit in with FIR?
- Information on the energy value in kilojoules (kJ) and kilocalories (kcal) per 100g/ml and in a specified portion of the product.
- Information on the amounts, in grams, of fat, saturated fat (“saturates”), (total) sugars and salt in grams, in a specified portion of the product.
- Portion-size information expressed in a way that is easily recognisable by, and meaningful to the consumer. For example, ¼ of a pie or 1 burger.
- % RI information based on the amount of each nutrient and energy value in a portion of the food, and Colour coding of the nutrient content of the food.
Infood calculates all of the above.
This leaflet contains the full information on the creation of Front of Pack nutrition labels and calculation of recommended intake (RI) values.
Nutrition – what do I need to declare?
The new rules state that nutrition per 100g/ml of finished product should be declared in the following order:
Of which Saturates (g)
Total Sugars (g)
Ideally, this information should be presented as a table, but for smaller products a list is also acceptable, as long as the order is maintained.
Nutritional information on the back of packaging may also voluntarily be given in the following three ways:
- In grams, by product serving
- As % of Reference Intake, by 100g/ml of product
- As % of Reference Intake, by product serving
A full nutritional table should be displayed as below:
|Value||Per 100g||Per ‘x’ g serving||%RI Per 100g||% RI Per ‘x’ g serving|
If information is given by serving size, the serving size must be clearly stated in grams on the same side of the packaging as the nutrition table.
For information on UK reference intakes, click here
Front of Pack 'Lozenges'
Front of pack Lozenge information remains voluntary in all circumstances. When given, you must use the format:
Energy | Fat | Saturates | Sugars | Salt
Values should be given in Kj then Kcal for energy, and grams for all other fields. This should be given by product serving (which must be stated on the packaging)
Optionally, % of RI can be given at the bottom of the lozenge, and the ‘traffic light’ colours used, though these are not mandatory even if Front of Pack nutrition lozenges are used.
Exemptions from nutritional labelling
All pre-packed foods will have to carry a nutritional declaration from December 13th 2016, except for:
- Products sold within the “supplying establishment’s own county plus 50 kilometers from the boundary of the supplying establishment’s county”
If you are supplying to multiple counties and are unsure about whether you need to declare nutrition, it is best to contact your local trading standards.
Which font type and size should I use?
Food information facts and figures
- Allergy UK suggests up to 25m people (nearly 40% of the total population) suffer from some food allergy or intolerance.
- Around 5% of the UK population have gastric-related problems related to gluten.
- 500% rise in hospital admissions due to serious allergic reaction since 1990.
- One in 50 UK children now allergic to nuts.
- The EU 14 are thought to account for 90% of serious allergic reactions to food.
- 70% of consumers think retailers should do more to explain what’s in the products they sell.
- 41% say that “It’s worth paying more for added benefits” (e.g. added vitamins).
- 87% see having a balanced diet as important.
- 81% of food suppliers said they try to go further than regulations to educate their consumers on food content.
- 16.5% of the UK population are regularly buying gluten-free products.
- Bakery goods such as bread, biscuits and cakes continue to account for the bulk of the UK gluten-free foods market.
- Gluten free sales increased by 23% in 2013.
- Gluten free market forecast to grow by 46% to £561M by 2017.
- UK drinks product launches with a low/no/reduced sugar claim increased 63% between 2009 and 2012.
- The average total cost of a health and safety related product recall is £17 million.
- 90 food products were recalled last year, with around 50% of this due to incorrect labelling.
- 38% of 900 food samples analysed in West Yorkshire between March and Sept 2013 were mislabeled.
- 36 food products have been withdrawn from Asda since 2011.
- Over 50% of businesses plan to upgrade their food information systems in the next five years. Will you?
The FSA have laid out the key points of the legislation here.
For further information The Food Standards agency has produced the following guidelines
More information can be found on the FSA website at http://www.food.gov.uk/business-industry/allergy-guide
To find out more about recent product recalls visit: http://www.tradingstandards.gov.uk/advice/advice-recall-list.cfm
Additionally, there are many UK organisations which provide guidance, training and support on allergens for food businesses.
Allergy UK and The Anaphylaxis Campaign are two leading UK charities whose websites contain a wealth of information for both allergy sufferers and businesses catering for them. The FSA also have an online course and test available for free for businesses wanting to increase their allergen awareness, you can find it here.