No I'm not referring to the weather, but the speed at which the time to sort out product labelling is disappearing under the new claims and fortification legislation.
The European Food Safety Authority has now finished the consultation on submission of dossiers as regards scientific substantiation of Article 14 health claims with final publication due during July. Scientific data required for the Article 13 submissions is not covered in the guidance it is important to note.
Let's not neglect the fortification controls, Regulation EC No. 1925/2006 on the addition of vitamins and minerals and certain other substances. While we await the revision of Directive 90/496/EEC on nutrition labelling for foodstuffs, there is a mismatch of declaration controls for fortified foods.
The Nutrition Labelling Directive contains a restrictive list of vitamins and minerals, which may be declared as part of the nutrition labelling when present in a significant amount and in respect of which nutrition claims may be made. The concept of 'significant amount' is elaborated to set out that 100g/ml or a single packaged portion of food should contain 15% of the recommended daily allowance (as defined) of the given vitamins and minerals.
In the meantime we have a selection of 'new' minerals, which may be added to foods, namely; copper, manganese, sodium, potassium, selenium, chromium, molybdenum, fluoride, chloride and vitamin K, but which are tricky to claim as being present.
Article seven of the fortification controls states that the labelling must include Group two nutrition information and the total amounts present of the vitamins and minerals when added to the food.
Thus when fortifying with these nutrients and labelling you need to juggle the need to declare quantity present without specifically making it part of the nutrition declaration.
Kath Veal is business manager, Regulatory and Technical Consultancy Services at Leatherhead Food International