The Organic Farmers & Growers (OF&G), a leading organic control body, is concerned that organic food processors will be caught out by the assumption that any changes do not need to be checked by their organic control body.
The new EU Food Information for Consumers (FIC) regulation sets out a standardised format for food information on product packaging, including the way allergens are distinguished, how nutritional information is displayed and font size. FIC is known as Food Information Regulations (FIR) in UK law.
Most food and drink labels will need changing before the December 13 deadline. In terms of organic regulations, nothing has changed. However, the issue arises because of other aspects of the new labelling requirements.
"Everyone is working hard to ensure they meet the new FIR requirements but I think that because they are not related directly to the organic regulation, they often come to the conclusion that control bodies do not need to be involved," explained OF&G processor certification officer, Ruth Lamb.
"We are finding that design houses can change an aspect of the label that they consider insignificant, for example amending the mandatory EU organic logo dimensions or amending the specific wording in the ingredients panel, which could then put the product in breach of the law relating to organic products.”
Possible pitfalls
Organic regulations state “the list of ingredients shall indicate which ingredients are organic”. When amending ingredient panels for allergens, there have been cases where the panel was altered while forgetting to identify some ingredients as organic.
In addition, the size of the EU organic logo can been changed when moving it. There is a minimum size for this logo.
To fit in wording or when labels have been altered, positioning of text has been changed. Specific text, such as the control body code, must be in the same visual field as the EU organic logo. If the EU logo is moved, the text may not be.
The EU agricultural statement must be directly below the control body code. When moving text, some have not moved the statement with the code, noted Lamb.
Planning ahead
Companies are advised to seek timely feedback from their organic control body on any changes, to avoid expensive mistakes.
OF&G warned that it may face increased demand for its services, as is the case for design houses and specialist printers, particularly as the December deadline approaches. Therefore there may not be time to rectify mistakes discovered late in the day.
A similar issue was also raised by Reading Scientific Services Ltd (RSSL) earlier this year, which highlighted the finite number of companies that print packaging and urged manufacturers to get their label orders in early.