The new EU-wide food labelling regulations coming into effect tomorrow (13 December) represent the most extensive revision of food labelling regulations manufacturers across Europe will ever have had to cope with.
Included in the EU Food Information to Consumers (EU FIC) Regulation are measures relating to allergens, mandatory nutritional information on the back label, the listing of the specific types of oil used on the ingredients list and the standardisation of font sizes for all mandatory information.
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Not all the EU FIC measures come into force tomorrow. Companies have until April to include country-of-origin labels for unprocessed pig, sheep, goat and poultry meat on-pack, while those manufacturers which do not provide nutrition labelling have until 13 December 2016 to do so.
Sukh Gill, head of global regulatory services at Leatherhead Food Research, told a Westminster Food & Nutrition Forum seminar on food labelling in May that the EU FIC Regulation has brought labelling changes for food companies “on an unprecedented scale”.
The changes also come at a time when the merits of EU membership are the subject of fevered political debate, most notably in the UK but also in other countries across Europe.
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In the UK, the emergence of the UK Independence Party (UKIP) as a political force, and a party which could hold the balance of power after the General Election next May, has thrust the European debate to the top of the political agenda. While David Cameron seeks a “new settlement” among EU member states, the lobby for total withdrawal has grown in strength and confidence.
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By GlobalDataIn the context of that debate, the final arrival of the EU Food Information to Consumers Regulation could not be more timely.
It is often said by supporters of European integration that in addition to the benefit of free trade, EU legislation has improved people’s lives, with enhancements in consumer protection almost always cited as an important example. The new food labelling laws are precisely the kind of measures which would be presented as exemplifying that benefit, while opponents of EU membership would most probably rail at more “interference” from Brussels.
Those advocating continued EU membership but opposing the strengthening of administrative, political and bureaucratic ties might also cite such legislation as unnecessary. They would be wrong to do so.
In addition to advancing consumer protection across Europe, the other critical attribute – and arguably the more critical aspect in the context of the EU debate – of the new regulations is that they provide a standardised approach to food labelling across all EU countries.
Such legislation can be represented – and sometimes misrepresented and satirised – by Eurosceptics as Brussels “meddling”, but harmonisation of such legislation is vital in the pursuit of a fully functioning single market.
However, while to portray such legislation as arbitrary would be wrong, there is no doubt that the expansion of EU bureaucracy and regulation results in added costs and upheaval for UK companies, and the food sector probably has more than its fair share of such burdens.
Since the EU FIC Regulation was first published in 2011, UK food manufacturers have had to devote considerable resources to preparing for the changes. Food manufacturers have been helped in this by the work of the Food and Drink Federation (FDF) and other trade bodies in disseminating information, and the amount of time and effort the FDF has had to spend on helping its membership prepare for tomorrow speaks to the significance of the changes.
There are still unanswered questions and the pain of transition is likely to continue for some time to come. Fortunately, in the UK, the FDF has coordinated closely with Trading Standards, which will police the new regulations, in preparing its members for the change, and there is expected to be a degree of latitude during the transition to the new regulatory framework.
Some of this work has been irksome for food manufacturers – not least the quest for clarification and clarity on numerous issues – and there are of course increased costs associated with the changes the legislation has required.
However, there are clear benefits to such legislation in terms of removing barriers to trade and reducing the costs of entering other European markets.
As to whether the food industry could ever align itself with calls for the UK to leave the EU, this is the time of year when turkeys not voting for Christmas might come to mind. According to the FDF, shipments to the rest of the EU accounted for 74% of UK food exports in the first half of 2014.
Eurosceptics would say bi-lateral trade agreements can be struck or the UK could enter some form of associate membership, or could become part of the European Economic Area (EEA). However, it should be borne in mind that were the UK to leave the EU, in order to continue exporting to EU states, food companies would have to comply with the EU FIC regulations anyway.
Moreover, even if it were the case that UK food manufacturers would not be disadvantaged in terms of market access by the UK leaving or becoming semi-detached from the EU, there is another critical aspect of EU membership that the UK food industry depends upon, and it is also right at the centre of the current debate.
The UK food and drink sector employs more than 400,000 people, representing almost 17% of the total UK manufacturing workforce. Industries such as food – and farming – rely significantly on low- or unskilled migrant labour from other parts of the EU. The FDF did not have a definitive figure but estimates that migrant workers probably account for 15% to 20% of the UK food industry’s workforce. So, far from being an unwelcome and unnecessary facet of the Single Market, the free movement of labour is arguably critical to UK food supply, both in agriculture and food manufacture.
Nevertheless, the FDF does not have an official position on EU membership. The organisation simply states: “Europe has a key role to play in meeting the growing global demand for food while adapting to the impacts of climate change and dwindling resources. UK food and drink manufacturers want to be part of a strong, outward facing, competitive Europe that leads through innovation supported by science and evidence based policy making. The EU must break down the barriers to trade and deliver food security for its citizens as well as shared, significant and sustainable growth.”
By the same token, the organisation resists making value judgments about the EU FIC Regulation. Barbara Gallani, the FDF’s director of regulation, science and health, simply hailed the changes coming into effect tomorrow as “the biggest change to on-pack labelling for the modern food industry”. However, the FDF statement also speaks to the benefit to the consumer of on-pack information, saying it helps consumers “make informed purchasing decisions by enabling individuals to check, compare and choose between similar products”. With that aim in mind, it seems hard to argue that the EU FIC Regulation is anything other than a step forward.
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