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and in USA by CRC Press LLC ISBN 0-8493-0852-6 320pp, hardback Editor’s Foreword A food label may literally be a label – a piece (or pieces) of printed paper attached to a food package – or it may comprise all or part of the printed or lithographed exterior surface of the package. In either case, it consists of a finite area to carry what needs to be meaningful (and, therefore, legible and intelligible) information. Different "stakeholders" require the label to do different things. There is thus considerable "competition" for the available space.Through its legislators, the country for which the product is destined determines certain information that the label must include, and in what form. The manufacturer of the product, through his/her marketing managers and creative label designer, wants the label primarily to help sell the product in preference to competing products. This purpose is sometimes pursued with little or no reference to legal requirements, sometimes sailing as close to the wind as possible. At the same time, the manufacturer, advised by his/her technical manager, regulatory affairs manager or consultant, also needs to ensure that the label complies with the law. This may lead to internal competition, not only for space but about what is written and how it is presented, usually – but not always – resulting in a compromise that meets both requirements. Compliance with labelling legislation is by no means a straightforward process. Labelling regulations are themselves in a virtually continuous state of evolution, often changing with a transition period during which the old regulations and the new ones simultaneously exist. Compliance sometimes involves requirements stated in more than one location; for example, general requirements in horizontal legislation, and particular requirements in vertical legislation affecting the class of products. Moreover, compliance very often involves interpretation of how requirements relate to the particular circumstances of the product, For the regulatory agency and the analyst, the label provides an essential part of the data required for checking that compositional and labelling regulations are being met. For both the manufacturer and the regulatory agency, the label provides the indispensable means for traceability of products in the event of need for withdrawal or recall. For the retailer the label fulfils two important additional purposes. It carries the bar code which, when scanned at the check-out, extracts from the in-store database and prints-out the price, and it inserts minus one into the stock quantity of that item in the database. The bar code must be large enough and clear enough for easy and accurate scanning, and this represents additional competition for the finite amount of space on the label. For consumers, the label provides the essential means of informed choice when purchasing, the means of identification of what is in the package, of what it consists, what quantity, how to store it (and for how long) and how to prepare and use it. Consumer organisations look for more, and more easily understood, information on labels. For some consumer activists, no amount of information provided appears to satisfy the Oliver Twist-like call for "More". But what about the mass of consumers for the benefit of whom whatever is on the label is primarily intended? If one is to believe the message of many consumer surveys, the majority want detailed label information but few use it, many because they do not fully understand it, particularly nutrition information. Few are said to understand the meaning of percentages – even when expressed as quantity per 100 g; or the significance of kilojoules (kJ); or that the kcals on a label are actually the "Calories" that dieters confidently count. Very few relate sodium on a label to the salt about which they hear health messages, or realise that 0.4 g of sodium per 100 ml on an EU food label (say, soup), equals 1 g of salt in 100 ml, which in turn means 2.5 g salt in a good sized cup of the soup. Beyond nutrition information lies the topic of health claims. This has long been a grey area in respect of labelling of health foods. As knowledge increases about the relationship between diet and health, research and development give rise increasingly to food products designed to provide positive health benefits. Many consumers will wish to know, and many manufacturers will wish to tell them, about the health merits (or supposed merits) of particular food products, sometimes on the basis of evidence far short of what would be legally required in a medicine. At what point does a health claim on a label become a medicinal claim? Indeed, are marketing-invented terms "functional foods" and "nutraceuticals" convenient euphemisms for "medicinal foods"? In the absence of adequate labelling measures that require satisfying an independent body of experts on the scientific validity of the evidence for efficacy and safety, how is the consumer to be given useful information while being protected from the modern equivalent of the old-time snake oil salesman? Clearly, if consumers are to utilise information on labels, there is a need for a major education effort to enable them to appreciate the significance of what they read there. It is, however, difficult to see how the label can be the education medium. This needs to be provided by other means and through other media. "What they read there"? This raises several problem areas. In the era of global marketing, and of the internal European market, the same product with the same label may be marketed in several countries and will need to carry information in several languages. Multi-ethnicity in a single country may also necessitate several languages. This of course intensifies the competition for the label "real estate" previously noted. Even the keenest-sighted of consumers would have difficulty in reading the extremely small print of some ingredients lists or nutrition information tables, particularly if print is not on a strongly contrasting background. This problem can be partly alleviated with better label design, but there remains the dilemma that the more information that has to be crowded on to a finite area, the more difficult it will be to read. How much more difficult is it for the partially sighted to "read what is there" and how impossible for the blind. Efforts to find ways of solving the latter problem have resulted in a technically-successful solution which so far cannot be put into practice. The last decade has seen new labelling needs. The advent of genetically modified foods and irradiated foods has necessitated the development of new labelling provisions to facilitate informed consumer choice. The belated recognition by legislators and industry that food allergy, though affecting a minority of the population, can be life-threatening, and is a major food safety issue, has led to measures in manufacture, and, as regards labelling, to the need for label warnings about the presence, or potential presence, of major food allergens. These are the main issues that are discussed in detail by the specialist authors of the various chapters, in terms not only of present problems and requirements but also of possible future developments. The latter are important because any book on a topic that is the subject of food legislation is to a considerable extent a "snapshot in time"; and nowhere is that truer than of food labelling. This book is a unique and valuable compilation on all aspects of the subject and should prove helpful to legislators, regulators, marketeers, label designers, food technologists, consumer organisations and perhaps even individual consumers.
Contents List Introduction D Jukes, University of Reading, UK; C Bruhn, University of California, USA; D Hunt, Food and Drink Federation, UK; D Love, Consultant (formerly MAFF UK); D Walker, Chief Trading Standards Officer, Shropshire County Council, UK Key issues in food labelling I Consumer needs I Manufacturers’ needs I Legislators’ perspectives I An enforcement perspective Labelling requirements: EU D Love, Consultant (formerly MAFF, UK) Key principles I The organisation of EU legislation I EU legislation and Codex standards I The main requirements for pre-packed foods I Nutrition labelling and claims I Specific labelling requirements in food composition directives I Specific labelling requirements in CAP marketing regulations I Novel foods and GM foods: labelling rules I Future developments Labelling requirements: USA J Vanderveen, Centre for Food Safety and Applied Nutrition, FDA, USA Introduction I The legislative and rule making process I The main enforcement agencies I Regulations on product name I Ingredients I Responsible agent for product I Net contents labelling I Nutrition facts I Country of origin I Nutrition content claims I Health claims I Details of regulations by competent authorities I Future trends Declaration of ingredients and additives: EU D Flowerdew, Consultant (formerly Leatherhead Food Research Association, UK) Declaring ingredients and additives: the basic principles I Review of key legislation I Summary of manufacturers’ responsibilities I How it can go wrong Declaration of ingredients and additives: US R H Schmidt, University of Florida, USA Declaring ingredients and additives: the basic principles I Regulation and key legislation I Manufacturers’ responsibilities for ingredient and additive declaration Durability Indication: EU A Mrohs, Bund für Lebensmittelrecht und Lebensmittelkunde e.V, Bonn, Germany Introduction I The legal situation U Manufacturers’ responsibilities I The product on its way to the consumer I Varied application in the EU I Special provision for short-life products: introduction I The legal situation: use-by date I Products with use-by date on their way to the consumer I Varied interpretations of ‘use-by’ provisions in EU member states I Guidelines on how dates should be calculated and presented I Future trends Durability indication: US R A LaBudde, North Carolina State University, USA Introduction I History I Terminology I Conflicting purposes of durability indications I Cost of durability indications I Guidelines for durability indications I Telltale indicators I Future trends Nutrition information: EU L Insall, Food and Drink Federation, Introduction: key issues in presenting nutrition information I EU nutrition legislation I Manufacturers’ responsibilities I Consumer expectations I Voluntary codes I Future trends Nutrition information: US TA Altman, EveryX Knowledge Integrators, Denver, USA Key principles of US labelling requirements I Making nutrient declarations I Format requirements and exemptions: conventional foods I Dietary supplement labelling I Compliance management I Future trends Nutrition and health claims: EU P Berry Ottaway, Consultant Introduction I Nutrition and health claims in the EU I Substantiation of health claims I Nutrition labelling I The future Nutrition and health claims: US M K Schmidl and T P Labuza, University of Minnesota, USA Introduction I Definitions I Disease-specific claims or disease-prevention claims I FDA Modernisation Act of 1997 I Medical foods I Dietary Supplement Health and Education Act of 1994 I Controversy over labelling I Advertising and the Federal Trade Commission I The future Special issues in food labelling E J Whitely and M J Sadler, Institute of Grocery Distribution, Watford, UK;J-P Kern, Mars incorporated, Belgium; J Ralph Blanchfield, Consultant; G W Gould, Consultant Good design in food labelling I Multi-language requirements I Food allergen labelling I GM foods and ingredients I Irradiated foods and ingredients I Label problems for blind and visually-impaired people Determining shelf life C M D Man, South Bank University, UK What do we mean by ‘shelf life’? I Introducing the main categories of product I Principal ways of determining and extending shelf life I Future trends The role of traceability In food labelling C Morrison, United Biscuits Frozen and Chilled Foods Ltd, UK The key objectives of traceability I Legal requirements concerning traceability coding I Wider aspects of traceability coding I A modern computerised production and management control system I Use of care lines in traceability I Applying traceability systems when problems arise Instructions for storage and use K G Anderson, Consultant Introduction I Risk categorisation I Clarity of language I Date marking I Storage and post-opening storage I Freezing, treatment post-freezing and re-freezing I Cooking and reheating I Microwaveable foods I Use in recipes I Special circumstances I Future trends
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