Manufacturers have hit out at the burdens that will be placed on them by COOL as currently drafted and with the extensions envisaged. COOL is a requirement of the new Food Information Regulation (FIR), published by the EU late last year.
"Very few of us have any idea how [COOL] will be implemented," Melanie Leech, director general of the Food and Drink Federation said at Food Manufacture's Business Leaders' Summit last month. "The people who decided this know nothing about how industry works. We've got a continuous downward spiral of regulation, because it starts from the wrong place."
COOL requirements are still the subject of much heated debate. As currently drafted, they will introduce mandatory origin information labelling for most fresh and frozen meat, plus the origin of the main ingredients, which will have to be given if different from where the final product is made.
Katharine Vickery, a partner with legal firm Eversheds, described how COOL had extended origin labelling from beef to sheep, pigs, goats and poultry. "The controversial issue is in relation to the question of primary ingredient," she said. "If on your product your primary ingredient, which is defined as a product that is 50% or more of your product, differs from your declared country of origin, you have to state that as well."
"Hopefully, with some powerful lobbying some of these rules may change because they will have a big implication for the processed and ready meal market in terms of declaring all the ingredients and their country of origin," said Vickery.
Separately, she also suggested that the restrictions on what information can be repeated under the nutrition labelling requirement of the FIR "may be the death of the traffic light system" of nutritional labelling used by some retailers.
While COOL doesn't cover meat products such as bacon, there are indications that these will eventually come within its remit. There are plans to extend the rules to meat products used as ingredients, as well as milk, milk used as ingredients in dairy products, unprocessed foods, single ingredients products, and ingredients that represent more than 50% of a food.
There are concerns that labelling will need to include the animals' place of slaughter as well as place of birth and rearing, since this goes beyond current UK guidelines. Pig meat that ends up in the UK can be born in Germany, reared in the Netherlands and slaughtered in Denmark. Processors hope that an 'EU origin' label would be permitted, but the question remains whether retailers would accept this.
The FIR was designed to make food labelling easier to understand for consumers and combines rules on general food and nutrition labelling into a single EU regulation. Transitional arrangements set out in the FIR mean that the bulk of the requirements will not apply until 2014, with nutrition labelling becoming mandatory in 2016.