Update: EU Country of Origin labelling

Fri 10 Aug 2018

The EU Food Information to Consumers Regulation 1169/2011 - contains a new rule on origin labelling – which is that

  • where the country of origin, or the place of provenance, (coo/pp) of a food is given (voluntarily) on the label, and
  • where it is not the same as that of its primary ingredient,
  • the coo/pp of the primary ingredient in question shall also be given; or
  • the coo/pp of the primary ingredient shall be indicated as being different to that of the food,
  • The rule will apply from 1 April 2020,
  • See second link for examples.

The ‘primary ingredient’ is defined as …

  • “an ingredient, or ingredients, of a food that represent more than 50% of that food, or
  • which are usually associated with the name of the food by the consumer, and
  • for which in most cases a quantitative indication is required”.

The Implementing Regulation 2018/775 - provides some clarity on interpretation – stating that the new rule applies where the origin indication of the food is given by any means such as …

  • statements,
  • pictorial presentation,
  • symbols, or
  • terms.

The origin indication must be provided with reference to one of the following geographical areas:

  • ‘EU’, ‘non-EU’ or ‘EU and non-EU’;
  • Region, or any other geographical area either within a Member State(s) or within a third country/countries;
  • Member State(s) or third country/ countries;
  • The country of origin or place of provenance in accordance with specific EU provisions applicable for the primary ingredient(s).

This is a complex new rule and many questions remain unanswered. The European Commission will produce guidance and UK industry guidance is also planned.

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