Most FIC provisions, including stipulations on text size, do not need to be enacted until the end of 2014. Requirements relating to nutrition labelling are not mandatory until the end of 2016. But country of origin labelling will be necessary during 2013, according to Phil Dalton, regulatory team leader at Legal Impackt, part of Sun Branding Solutions.
“Crucially, up to now, labelling regulation has only dealt with mandatory information,” he explained. “The FIC regulation deals with voluntary information, too. The big change is that you’re not permitted to restrict the size of mandatory information, in the required format and font size, in order to fit in voluntary information.”
Mandatory
The nutrition panel, formerly voluntary, will now be mandatory. The x-height defining text size will be set at either 0.9mm or 1.2mm depending on the size of the largest available labelling surface though debate continues about how such an area should be defined on a curved container, for instance.
So far, there has been no guidance on this. But where a label is applied to a meat pack, for instance, its size will need to increase if that is what is required to include mandatory information at the correct point size.
To add to the confusion, other factors affecting legibility are likely to be addressed at a later date. “Over the next couple of years, the Commission will consider issues such as letter spacing, line spacing and text colours,” Dalton added. “There will probably be more regulation in this area.”
He believed the regulation would radically alter the design process. “Variables such as ingredients lists and a full nutrition table must be locked down at an earlier stage,” he said.
Multilingual labelling
Multilingual labelling poses special challenges. Dave Hill, a labelling consultant at Foodlabelcheck, predicted: “Space constraints mean there's not likely to be as much room for each language from now on.”
This language aspect will be complicated further by the UK industry’s adherence to the ‘traffic light system’ for nutritional information. “Not one of the major brand owners has made these changes,” said Hill. “Understandably, they want to make all the FIC and traffic light changes in one go.”
Said Dalton: “There’s going to be an almighty rush to implement all these measures in the second half of this year and next year, too.”
The lack of explicit guidance from the Department for Environment, Food and Rural Affairs has probably not helped the situation, says Dalton.