The FIR – due to be enforced on December 13 2014 – sets out strict rules requiring changes to food labels covering: font sizes, mandatory information on ingredients, nutrition, allergens and the country of origin and a range of other topics.
Spice explained the huge task facing the food industry at the Food Manufacture Group’s webinar – The Food Information to Consumers Regulation: what you need to know – yesterday (February 20).
“A small to medium-sized retailer can have 10,000 SKUs [stock keeping units] in its portfolio and they will all have to change,” said Spice. “A typical throughput would be about 250 to 300 lines a month, which can get converted within resources. So, if you are starting, with your 10,000 lines with roughly 10 months to go, it is going to need roughly 1,000 a month to get the job done. Now that is a tall order.”
As well as the physical challenges of compliance, the food industry is also grappling with its “colossal cost”.
‘£32.5M just for one retailer’
The Department for Environment, Food and Rural Affairs calculated, through Campden BRI, that the average cost of a label change was about £3,260. “If a retailer has 10,000 lines, multiplied by £3,260, you get £32.5M just for one retailer,” said Spice. “Scaling that up to big brand owners, you start to see how much this is costing the business.”
Alasdair Tucker, head of regulatory affairs at Premier Foods, explained the scale of the challenge facing one of Britain’s largest food manufacturing businesses. As the UK’s second largest ambient grocery supplier, Premier Foods has more than 2,000 SKUs in its brand portfolio; all of which will require labels to be updated to comply with FIR.
“We also have a small number – probably less than 15% of own-label portfolio that we manufacture – that also takes on board the requirements of the FIR,” said Tucker. “So, that’s the size of the prize we need to task.”
A tough challenge will be reconciling the label space required for FIR compliance with the space available for marketing messages. “One of the big issues we have found is that when speaking to marketeers, we have had to balance voluntary information and marketing puff, for want of a better phrase, against the requirements for the space available with legal information.”
Corrine Lowe, joint lead officer food and nutrition, Trading Standards Institute, said the FIR will, for the first time, provide the enforcement tool of improvement notices to deal with food labelling and food information breaches not related to safety.
But the enforcement tool will not be available in Scotland and any breach will be classed as an offence, Lowe warned.
Dominic Watkins, partner and head of the food group at law firm and event sponsor DWF, highlighted some of the many unanswered questions raised by FIR. “The vast array of secondary information that sits under the primary legislation is going to be a real problem,” said Watkins.
“Because there are lots of rules that are still to come and the EU has left the door open to make quite a number more.”
For example, in the food servicing industry, the labelling regulations require member states to make their own decisions. Other than allergens, there are no other obligations. “But what about products served on airlines and in other transport industries?” he said. “And distance selling, how is that going to work? Are the websites ready for it, as well as the obvious point about getting food products into shops.”
Missed the webinar? Don’t worry, simply register now to listen at your leisure. The webinar will be available on FoodManufacture.co.uk for the foreseeable future.
Meanwhile, watch out for more webinar reports next week on how Premier Foods is complying with the new rules and how they will be enforced, plus answers to some of the hundreds of questions submitted by our webinar audience.