Raising a number of questions and discussions about the peculiarities and requirements of food labelling, we have summarised and answered the most relevant questions for the consumers and businesses.
The appropriate food labelling is important to enable a person to choose which product to buy and consume, which is more nutritionally appropriate, and how to avoid unwanted allergens and food additives. The labelling of products is quite a complex and strictly regulated matter, primarily due to the fact that various food ingredients and additives can have unequal effects on different people.
What is the mandatory food information on the package of a prepacked product?
When prepacked foods are sold, the following information must appear on the package: the name of the food; the list of ingredients; substances that may cause allergies or intolerances; the quantity of certain ingredients or categories of ingredients (if applicable); the net quantity of the food; the date of minimum durability or the “Use by”… (date); any special storage conditions and / or conditions of use; the name or business name and address of the food business operator; where applicable, the country of origin; instructions for use, where it would be difficult to make appropriate use of the food in the absence of such instructions; a nutrition declaration; if alcohol is labelled, the actual alcoholic strength by volume of beverages containing more than 1,2% by volume of alcohol must be indicated.
The mandatory labelling information on the food package or on a label attached to the packaging must be provided in Lithuanian. The information must be accurate, clear and easy to understand for the consumer, and must not be misleading, particularly:
• as to the characteristics of the food, in particular its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of production or preparation,
• by attributing to the food, effects or properties which it does not possess,
• by suggesting that the food possesses special characteristics when in fact, all similar foods possess such characteristics, in particular by specifically emphasising the presence or absence of certain ingredients and / or nutrients,
• by suggesting, by means of the appearance, the description or pictorial representations, the presence of a particular food or an ingredient, while in reality a component naturally present or an ingredient normally used in that food has been substituted with a different component or a different ingredient.
How to present the information about the allergens on the label of prepacked products?
The substances and products causing allergies or intolerances (listed in Annex II to Regulation 1169/2011) must be clearly distinguished in the list of ingredients (other font, style or background colour).
In the absence of the list of ingredients, allergenic or intolerant substances / products must be indicated on the package or on a label attached to the packaging, using the word “contains”.
Different expiry dates of food on the packaging of products
The shelf life is the information provided by the food manufacturer on the extent to which the food will remain safe and of good quality when stored under the specified conditions.
The expiry date is indicated as “Use by” (for microbiologically perishable foodstuffs) or the date of minimum durability as “Best before” (this indication means that the product will remain in optimal condition throughout the period indicated, e. g. will not expire, and is mainly related to food quality: taste, texture, aroma, appearance).
Regulation 1169/2011 sets out detailed requirements for how these dates are to be indicated. "Best before…" is written when the day is specified in the date or "Best before… (end)" when on frozen meat, frozen meat preparations and frozen unprocessed fishery products must also be indicated the date of freezing or the date of first freezing if the product has been frozen for more than once: “Frozen… (date)”. The date is written as follows: the day, month and year.
Are there any requirements for the font size of the labelling information?
The mandatory particulars shall be given on the package or on a label attached to the packaging in such a way as to be clearly legible, in a font with a character height (lowercase letters) of 1,2 mm or more. In the case of packaging or containers the largest surface of which has an area of less than 80 cm2, the x-hight of the font size must be at least 0.9 mm.
Which foods are not required to provide information on the durability date?
Is not required to indicate the date of minimum durability for the following products:
- fresh fruit and vegetables, including potatoes, which have not been peeled, crushed or similarly treated; this derogation shall not apply to sprouted seeds and other similar products such as legume seedlings,
- wines, liqueurs, sparkling wines, aromatised wines and similar products obtained from fruit other than grapes, and beverages falling within subheading 2206 00 of the CN obtained from grapes or grape must,
- beverages containing 10% or more by volume of alcohol,
- baked or flour confectionery products which, depending on their composition, are normally consumed within 24 hours of manufacture,
- edible salts,
- solid sugar,
- confectionery products consisting almost exclusively of flavoured and / or coloured sugar,
- chewing gum and similar chewing products.
In which case should the distributor be indicated on the label? Is it necessary to indicate the distributor in Lithuania, if the manufacturer is indicated on the label?
In accordance with Regulation (EU) No 1169/2011 of the European Parliament and of the Council<...> (Article 8, Paragraph 1), the name or business name and address of the food business operator must be provided. Therefore, if the manufacturer is indicated on the label, the name of the distributor would be the additional information to the consumer, but this is not mandatory.
Why may some product names not correspond to their composition, for example, "Doctor's sausage" does not contain a doctor, "Lads’" sausage does not contain lads, the sweets "Swallows" contain no swallows, the biscuits "Chanticleer"– no poultry, etc.?
The provisions of the European Union law do not, in principle, prohibit the use of fictitious names, if they do not conflict with the case law of the European Court of Justice and do not mislead the consumers, but in all cases the labelling of specific foods must be legal, i. e. the name prescribed by law or, failing that, a descriptive name (a sweet, a sausage, a biscuit, etc.). In addition, when choosing a product, the consumer evaluates the totality of the information provided about it (e. g. the statements used, the symbols, the drawings, etc.). The legislation provides the data of mandatory information, assessing the totality of which allows the consumer to make a decision on the choice of the product.