How Premier Foods is tackling new EU FIR labelling rules

Alasdair Tucker, head of regulatory affairs at Britain’s second largest ambient food manufacturer, told the Food Manufacture Group’s webinar​ on the EU’s new food labelling rules that complying with the legislation was a massive task. Premier Foods had more than 2,000 stock keeping units in its branded portfolio and up to 15% of its own-label portfolio that required label changes.

“In terms of our approach to the delivery of FIR, we’ve addressed this with a project management approach,”​ said Tucker. “It’s a major project within the business with a full-scale project management focus and support. It needs to ensure we have a mechanism in place that is cross functional and engages with the stakeholders at the right time.”​

Premier Foods’s list of internal stakeholders is divided into 12 categories. Those are: marketing, procurement, new product development, technical information (specifications), artwork originations, operations, bought-in / licensed, commercial business to business team, commercial foodservice, commercial export within the EU, technical account managers and commercial finance.

Own-label business​

External reference points have included artwork studios and repro houses, printers, retailers for own-label business, Trading Standards for home authorities, the Department for Environment, Food and Rural Affairs, Food and Drink Federation, Anaphylaxis Campaign, Allergy UK / Coeliac UK, raw material suppliers, bought in goods suppliers, ingredients and product licensors.

Key elements of the management process have involved: a mechanism to track costs and the updating of ‘back office’ systems – with particular regard to specifications – both raw materials and finished products – nutrition analysis results and artwork approvals.

“There have to be mechanisms in place to track costs – despite the three-year transitional period to introduce FIR,”​ said Tucker. “But we have seen you cannot incorporate the changes just as business as usual, there has to be extra spend – we need to manage that and track those costs.”​

Premier Foods has adopted an approach by brand, monitored by key performance measures and supported by internal guides and documents. “We have approached it by brand to ensure that we timed it correctly and put it through in relation to​ [brand managers’] business as usual brand or artwork updates.” ​

Key performance indicators​

Key performance indicators (KPIs) have been introduced to ensure the firm is on track with delivery. This has been supported by internal guidance documents to ensure managers make the right choices about the information to put onto the artwork.

While the business began preparing for the FIR labelling changes – also known as FIC – before its incorporation into UK law, as far back as November 2011, when the regulation was published in the EU official journal, “various diversions and distractions and delays, that have meant we have had to consider our approach to putting the information onto label”, ​said Tucker.

A mixture of guidance published by various governmental and non governmental organisations last year meant that it was only at the end of 2013 that it became clear what would be required on the label, he added.

“We are still going through the process of taking FIR on through the majority of our products so we are going to have to have a very busy 2014 to make sure we are fully compliant and by the end of the year,”​ summed up Tucker. “So, the KPIs have been concertinaed into this year. They are on track but it is going to put more pressure on the system to deliver.” ​

Missed the webinar? Don’t worry, register now​ and listen at any time. The webinar will be available on FoodManufacture.co.uk for the foreseeable future.

FIC regulation – sets rules on:​

•             How foods should be labelled – what information is mandatory.

•             Presentation, style and positioning of this mandatory information.

•             New rules for advertisements and distance selling.

•             Defines who is legally responsible for the mandatory information.

Key new requirements under FIC​

•             Minimum font size for mandatory information.

•             Clearer indication of allergens in the ingredients list.

•             Allergen information to be provided for non pre-packed foods, including those sold in restaurants and cafes.

•             Extension to the rules for country of origin labelling for meat.

•             Mandatory nutrition labelling.

•             Specific rules for the repetition of nutrition information and additional forms of expression.

 ​

Other key differences​

•             Fair information practices.

•             Responsibilities.

•             Distance selling.

•             Name of the food.

•             List of the ingredients.

•             Additional mandatory particulars.

•             Net quantity.

•             Minimum durability date.

Source: Premier Foods