New guide promises consistency on COOL

The guidance, drawn up by DEFRA, the British Retail Consortium, food manufacturers and caterers, covers meat, processed meat products, milk, fresh cream, cheese and butter and pre-empts legislative changes in this area proposed under the EU Food Information Regulation.

The new guide argues that the term ‘British’ should only be used on meat from animals born and​ reared in the UK (or, in the case of poultry, reared in the UK) and dairy products made from milk produced in the UK.

Supermarket own-label cheese should state the country of origin of the liquid milk it is made from or​ the place the cheese was manufactured, NOT where it was packed.

Union Jacks, ‘British imagery’ or terms such as ‘British Classic’ should not be used on products that do not originate in the UK, while firms using statements such as ‘packed in the UK’ should also state the place of production if this is different.

Retailers are advised to list COOL information on the label or in close proximity to the product, while caterers should include COOL on menus, accompanying literature or ensure it is available upon request.

Meat and meat products​

Where an animal has been born and reared in different countries, additional information should be provided to make this clear, says the guide, while firms are also asked to label the origin of the meat in 'lightly processed’ products such as bacon, ham, gammon, sausages and burgers.

If the meat is sourced from multiple countries this should be made clear either by naming the countries (‘produced in the UK with meat from Thailand and Brazil’), stating ‘product of multiple countries’, defining a region (‘product of the EU, South America, Scandinavia’) or by stating that the origin of the primary ingredients is different from the origin of the main product: ‘produced in the UK from imported beef’.

In ‘composite products’ such as pies and casseroles, where a voluntary origin declaration is already made, the country or origin of the main meat ingredient should be labelled “if the meat is considered of primary interest to the consumer or a predominant component of the product”, ​suggests the guide.

Dairy products​

Liquid milk and fresh cream, meanwhile, should be labelled with the country of origin of the milk while cheese and butter should state the country of origin of the liquid milk or​ the place of manufacture, NOT where the product is packed.

This goes beyond current legislation, which defines origin as the place in which the product underwent the ‘last substantial change’, which in the case of cheese, could mean where it was cut, packed and wrapped, said Dairy UK: "At the moment, if you pick up a pack of own-label cheese in a supermarket, it might be labelled with the name of a UK seller and carry a UK identification mark, but it could have been manufactured outside the UK.”​

Where the milk is sourced from multiple countries this should be made clear either by naming the countries in question, stating ‘product of multiple countries’, defining a region (‘product of the EU’) or by stating that the origin of the primary ingredients is different from the origin of the product: ‘produced in the UK from imported milk’.

What COOL isn’t…​

The following information is not considered to count as an origin declaration under the new code:

• Approved premises codes.
• Breeds of cattle such as Aberdeen Angus.
• Name and address of the manufacturer, packer and seller.
• Control body code numbers under the organic standards.
• Use of slogans such as ‘the UK’s favourite brand’

While the EU Food Information Regulation contained detailed proposals on COOL, the outcome of this legislation was both uncertain and some way off, said Dairy UK, which welcomed today's guidance.​

“Dairy UK has made no secret of the pressing need for effective arrangements for country of origin labelling for milk and dairy products, particularly cheese”,​ said director general Jim Begg.

“We therefore see this initiative, which has been developed by industry in conjunction with Defra and which, crucially, has the support of both retailers and suppliers, as an important step forward”.​

Food Information Regulation​

In the first reading of the Regulation at the European Parliament in June, MEPs voted to extend COOL from selected foods such as beef and olive oil to other single-ingredient products including meat, poultry and dairy products.

More controversially, they also voted for mandatory COOL on meat, poultry and fish when used as ingredients in processed foods such as ready meals, stews and pizza, which many manufacturers argue would be impractical and hugely costly, without delivering any meaningful consumer benefit.

One industry source told FoodManufacture.co.uk more detailed COOL might also prove counterproductive for British farmers given the amount of British dairy ingredients that are exported for processing abroad, as manufacturers in continental Europe “might prove reluctant to carry on buying British dairy ingredients if they must declare them on labels”.​

The European Council has recently come up with a compromise proposal on COOL, with the Belgian Presidency hoping to reach agreement at an EU Council meeting in early December.