First, the letters FIR used to refer to the UK version of the EU Food Information to Consumers regulation EU1169/2011, the FIC. Why the UK had to duplicate a complex European document is beyond logic. We have really made a mess of things in Britain. For instance; the ‘use by dates’ refer to safety so fall under the Food Standards Agency, the ‘best before dates’ come under the Department for Environment, Food and Rural Affairs (DEFRA), as they are to do with quality and the Department of Health set the safety limits.
Secondly, when we were writing the FIC (that is EU 1169/2011) years ago I spent days in Brussels with the Commission and colleagues from small and medium-sized enterprises in the other Member States trying to get the text right. Without our interventions, every label would have had to have had a declaration as to whether any non-union or even child labour had been used anywhere in the food chain. That one took me a whole morning with the Commission.
Inadequate
Third, guidance. Large firms have specialists who know the rules for labelling. Guidance just on the FIC or even the UK FIR is inadequate because there are lots of other rules that might apply. Rules such as the protected names regulations, EU 16/2012, EC 41/2009 on gluten and there is a long list. Our web-based resource www.foodlabelling.info has over 200 links to documents.
Guidance produced by DEFRA and other departments is more geared for enforcement agents who have the paid time to read through the verbiage. Small food businesses do not have the time to wade through that sort of thing. Fourth, where were all these people you say were at this conference when the European FIC was being written? It is no good complaining now. The thing is law.
Lastly, there used to be about 40 EC regulations governing food labelling. Now there is just one. That is of great benefit as all products sold in the EU will have to display the same format. Every Member State I go to tells me they have the rules applied more strictly. I am told: “If only we were like you in Britain, you can get away with anything”.
Bob Salmon
Director, Food Solutions