• Issues

Labelling Food

Directive 2000/13/EC defines all the labelling requirements for food products and ingredients.
Several provisions in this legislation are key for the oils and fats sector and are currently being discussed in the Commission proposal on food information to consumers.

Hydrogenation
Hydrogenation is indicative of a process and not of the content of the relevant nutrients i.e. trans fatty acids (TFA) and saturated fatty acids (SAFA) in a food product.

As it stands, the word does not inform the consumer accurately.  Indeed, nowadays the majority of hydrogenated oils and fats today is fully hydrogenated and contain less than 0.5% TFA, which is similar to or even lower than non-hydrogenated oils and fats.  Only partially hydrogenated oils and fats could contain substantial amounts of TFA.
Consequently, the possibility of voluntarily replacing the word ‘hydrogenation’ or ‘partial hydrogenation’ by the level of TFA and SAFA in the food would clearly help transparency towards the consumer by informing him about the nutrients themselves, and hence lift the confusion.

Class name
The European oils and fats industry has been using the class name approach “vegetable oils/fats” as laid down in successive EU labelling directives ever since 1978.
 
FEDIOL believes that it is important to maintain the “class name” principle for the following reasons:

  • what is really important for the consumer is the fatty acid composition of a food product.
  • The same fatty acid composition can be achieved using different oils and fats in changing quantities.
  • The class name is necessary to ensure a certain flexibility in the formulations, allowing for the variation in the raw material sourcing.  Different vegetable oils and fats are indeed inter-changed depending on seasonal and market availability.
  • The class name is necessary to guarantee the confidentiality of certain oil and fat formulations for specific food applications.
  • Mandatory indication of the specific oil or fat is only justified in case of a specific claim and mandatory if its presence is highlighted by words or image on the label.


Country of origin or country of provenance
It is essential that any labelling provisions regarding country of origin are set to provide consumers with relevant information in order not to mislead them.
Hence, FEDIOL supports maintaining the current voluntary requirements under the existing EU legal framework.
Indeed,

  • single-ingredient foods such as bottled vegetable oils are processed foods. They are, as such, significantly different from unprocessed foods such as fruits, vegetables, eggs, etc. Hence, FEDIOL members face with respect to origin labelling partly the same problems as producers of composite foodstuffs. This again refers to industrial processing, packaging and marketing.
  • ‘country of origin’ may cover different concepts in consumers’ mind when it comes to single-ingredient foods. It is unclear whether consumers would expect the country of origin to be the country where a single-ingredient food was produced or the harvesting place of the agricultural raw materials from which this product is derived (e.g. soyabean, rapeseed, sunflower seed, coconut, etc.).
  • mandatory indication of the country of origin for single-ingredient foods would be of little informative value since it will not provide any particular characteristics to the product.  FEDIOL members comply with an EU Code of Refining that  lead to standard refined vegetable oils and fats.
  • it would take away the flexibility for single-ingredient food producers to deviate and/or differentiate sourcing (seasonal availability, variation, quality, sustainability).
  • in the case of continuous production processes, bulk handling and storage, the partition of the production according to the origin of the raw materials may not be possible with any degree of certainty. Where at all possible, costs imposed on producers of single-ingredient foods, including constant food label adaptations, would in any case be disproportionate in comparison to the expected consumer benefits.
  • it would unnecessarily increase the amount of information provided on the label without a real benefit for the consumer.