By way of recap, until now mandatory food labelling obligations applicable in the UK have been contained principally in the 1996 Food Labelling Regulations.

That position is now in the process of change. The EU’s Food Information for Consumers Regulation 1169/2011 (EUFIC) was adopted by the EU in September 2011. This requires, in particular, packaged food companies to declare the energy value and the calorie, carbohydrate, fat, protein, salt, saturates and sugar content on the pack. EUFIC compliant labelling becomes mandatory for most pre-packed foods from 13 December 2016. However, where a nutrition declaration is required (principally where a nutrition or health claim has been made or vitamins or minerals have been added), that declaration must comply with the EUFIC requirements from 13 December 2014.

In anticipation of EUFIC packaged food requirements taking effect in the UK, industry participants have been seeking to reach an accord on a uniform approach to presenting this information. After many months of consultation, debate (and disagreement) all the indications are that the Department of Health, which has now assumed many of the functions of the Food Standards Agency, will endorse a hybrid front of pack labelling system that will combine elements of both the GDA and the traffic light systems. This approach is unlikely to be mandatory but compliance is likely to become an industry standard approach to satisfying the EUFIC labelling obligation. Disappointingly however it now appears that, despite the broad industry acceptance of the hybrid front of pack approach, the Department of Health is carrying out some further research as to the effectiveness of labelling schemes and it therefore remains possible that the outcome of that research may dictate further changes.

The cost of implementing the new labelling arrangements is estimated at £7,000 per product disregarding training costs. On the positive side it is likely that compliance with EUFIC requirements in advance of the mandatory dates will be treated as satisfying existing 1996 Food Labelling Regulations requirements.