Correct labelling and packaging remains a challenge

Published in Meat magazine December 2018 - Industry Special

We often see labels and packaging as attractive marketing tools to seduce consumers in the field of, for example, health, origin or an environmentally or animal friendly production method. We can be very innovative in this respect. But we also have to deal with regulations and consumer organisations. The trick is to create the right balance. Because sometimes it goes wrong.


This year the NVWA carried out an investigation into compliance with the claims legislation by producers who produced foodstuffs aimed at losing weight. These foods are more expensive than regular products. In practice it turned out that 34 of the 36 companies violated the claims legislation. Compliance with labelling rules was better, with 19 companies failing to comply. But that is still more than 50 per cent! If this sample is representative, there is still a lot of work to be done. much work to be done.

Is the legislation so difficult or are the Are the boundaries being sought and/or crossed? We will not get the answer to this will not be answered. It is true that the Consumers' Association is very active in the fight against deception. counter deception. They regularly receive complaints from consumers that the expectations aroused expectations aroused on the packaging are not being met. On its website, the On its website, the Consumers' Association even has a 'wall of shame' with all kinds of products for which it has they have found to be misleading.

They are also increasing the pressure on the NVWA to act more firmly and to make inspection data in this area public. Given the developments within the government, that chance is real.


For the correct application of the labelling rules, we must keep abreast of developments in this field, but we must also know how to interpret the law. in this field, but also know how the law must be interpreted. Nowadays, you have nice labelling programmes. These are handy modules which organise ingredient declarations and calculate nutritional values. But interpreting the But interpreting the labelling law is still a human job. And And this is where the mistakes are made. Sometimes labels of the same products are simply copied products are simply copied, which can go wrong with allergens, resulting in a recall. allergens, resulting in a recall. In short, labelling remains a problem.

In 2018, several changes were made in the field of labelling, both in legislation and in its interpretation by the NVWA. On 28 May 2018, Regulation (EU) No. 2018/775 was published with new rules on voluntary origin labelling with rules for the application of Article 26(3) of Regulation (EU) No. 1169/2011. If the country or place of origin on the label is not the same as the primary ingredient, this must be stated on the packaging.


The European Commission will follow guidelines. As of 1 April 2020, all food products must comply. On 30 May 2018, Regulation (EU) No. 2018/848 was published with renewed rules for the production and labelling of organic products. Organic products from third countries will not be allowed to carry an EU logo just like that. The products concerned must comply with EU rules and be recognised for this. There will also be a central database for the availability of organic products. This regulation will apply from 1 January 2021.

For trans-fatty acids (even worse than saturated fat) there will be a new standard. Recently a new proposal of the European Commission has been adopted which sets a limit for trans fatty acids of no more than 2 grams per 100 grams of fat in the product. From 1 April 2021 onwards all industrially manufactured food will have to comply.

Products of animal origin which naturally contain it are excluded from this. In the Netherlands, hamburgers and minced beef contain an average of more than 2 grams of trans fat per 100 grams of fat, so these products are exempt. But you can be sure that these products will soon end up in the Consumer Association's suspect list. One solution is to add other fats to reduce the trans fat content of the final product, as is already being done in the food industry by reducing the salt and sugar content. However, this results in a higher higher fat content.


The interpretation of regulations has been tightened in recent years by the NVWA for the sake of greater unformality within the European Union. For example, overnight 'filet americain' became a meat preparation instead of a meat product. instead of a meat product. And this has consequences for the use of additives, because far fewer additives are permitted in meat preparations than in meat products.

Since recently, type 3 MSM (meat on bones or carcasses, mechanically removed) cannot be included in the meat content. In the Netherlands, we had classified MSM into two categories; type 3 (created under low pressure) and type 4 (created under high pressure). Type 3 was allowed to be included in the meat content, but since recently this is no longer allowed. The NVWA has been warned about this by Brussels. There will be a transitional period to adjust this in practice.

A new warning label for fresh poultry meat A new warning label with pictograms will be introduced shortly, because the old warning text was not effective enough. The requirement for pictograms will also will also follow for the warning text for red meat. Nice development, but the printers will have to be able to handle the pictograms.

Labelling remains a topic of discussion. In January, the Dutch Lower House will consider the evaluation of the 2016 Labelling Action Plan of the NVWA. NVWA's 2016 Labelling Action Plan. New action points may emerge from this! action points may emerge from it!

Yvon Bemelman