Did I misunderstand the label?

Food labelling

Image by Freepik

The holiday season is over and many of us are counting the cost and keeping an eye on our spending. If you track your trips to the supermarket, we’re sure you’ll see a definite increase during December.

In the run-up to Christmas and New Year, retailers and food product manufacturers battle to attract as many customers as possible and product packaging is one way to do it. A nice presentation is likely to catch your eye and influence your decision-making when deciding whether to buy a product.

Food labelling regulations are in place to protect consumers from a food safety and quality perspective but also to prevent misleading advertising practices.

The main point of reference when it comes to the food labelling presentation would be Regulation (EU) No 1169/2011 – on the provision of Food Information to Consumers (FIC).

This regulation has many provisions which are meant to prevent misleading practices. Some refer to visual cues and have the consequence of protecting consumers from deciding to buy a product only to end up disappointed later, such as Article 7 points 1 and 2 which mention that:

1.Food labelling information shall not be misleading, particularly:

(a) as to the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production;

(b) by attributing to the food effects or properties which it does not possess;

(c) 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;

(d) 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.

2.Food information shall be accurate, clear and easy to understand for the consumer.

In addition to this, Article 3 of the same regulation sets the overall objective of this regulation, and the first would be:

1.The provision of food information shall pursue a high level of protection of consumers’ health and interests by providing a basis for final consumers to make informed choices and to make safe use of food, with particular regard to health, economic, environmental, social and ethical considerations.

Informed choices and safe use of the food are pillars for building trust in the food industry and for brands as well. It’s in everyone’s interest that rules are followed with all the above considerations.

Illustrations are often used as a way to describe the product or set expectation in terms of how a ready-made meal might look like, for example. In order to avoid customer disappointment, clear distinction should be made as to whether the imagery represents a serving suggestion or is describing the contents of a pack.

As they unpack and start cooking, the customer should not realise that the product they have purchased is not the ‘real deal’, just piece of a puzzle.

As exemplified by this product review which we decided to keep anonymous:

The customer should never have to wonder, “did I misunderstand the label?”   

Our regulatory team can support you with comprehensive checks on food product labelling to ensure compliance with all relevant EU/UK legislation. Working at any stage, from a development brief to finished artwork, we can advise on product formulations, so that names, claims and descriptions are supportable.

Get in touch with us at business.development@jensongroup.com to find out how we can help.
Mihai Inceu
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