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How to Make Sense of Food Labels (Ingredients & Legislation)
Labels on food generally have two very important functions: 1) make the product look appealing and make people want to buy it and 2) tell the (legal) details of your food. You both want to make sure people know what your product is, where it comes from, what it contains, as well as want to buy it. The marketing side of a label is its own field of study and complex enough by itself, so here we’ll focus on the more technical side of things. How to get started making a proper label.
Especially for people scaling up from a kitchen or for people with no experience at all within food industry, making a label might sound daunting. Good thing, it’s not the hardest thing to do, but it is one that you’ve got to get right. It should comply with any applicable legislation, which can sometimes be confusing. Also, you might need to collect information about your product that you never even thought of (e.g. nutritional value)!
That said, the topic of making labels is highly influenced by the country you’re making and selling the product. In the USA legislation is different from Europe which is again different from that in China. Therefore, this post will not cover all specific details, but try to help you get started or simply be able to read and understand a label you’ve found somewhere! Feel free to leave behind a question when something’s not entirely clear!
Why a label?
The simple answer is: for a lot of products (yes, not all) it is required by law. But a label often isn’t just a must, instead, it’s something that can also greatly help to sell your product. It can also help build confidence, people will understand what your product is, know whether it’s safe for them to eat (e.g. in the case of food allergies) and know for how long and how it should be stored. Also, it helps them to recognize who made the product (and potentially find your product a second time!).
The exact requirements really differ per country, so always check your our legislation. This post is not meant as proper legal advice. Instead, it’s meant to help you get started to find your way in label world. Note, if you need legal advice, please contact a local expert.
That said, you will find several similarities for label requirements between different countries.
European labeling legislation: 1169/2011
In the European Union labelling is regulated by a pretty recent piece of legislaton, with the number 1169/2011 (the second number is the year in which it was passed). It’s a long document with a lot of requirements, exceptions and explanations. It mentions which aspects have to be on most labels (e.g. storage conditions, a shelf life for most products or a preparation method), but there are also a lot of exceptions and products that require additional (or less) information.
The legislation starts by stating why this legislation has been put in place and what it aims to achieve: proper and complete information for the consumer. That is why, it states, why the following topics will always have to be on a label (note that this list is not complete, just a highlight):
- Name of the food
- Ingredient list
- Allergens (these are ingredients for which people can be allergic, there is a list of allergens that have to be mentioned,for example gluten, milk and egg)
- Net quantity of the food
- Expiry date (although some products such as chewing gum do not have to contain this)
- Storage or usage conditions (for example, a milk producer will have to mention the milk has to be stored in a fridge,)
- Nutrition declaration
- Alcohol content for alcoholic beverages
USA labeling legislation – FDA
Food labeling legislation in the USA seems to be covered in a different way. The FDA has developed a food labeling guide to help manufacturers along. The basic requirements are similar for those in Europe, but take care, requirements do differ, especially in the details:
- Name of the food
- Net quantity
- Ingredient list
- Nutritional value
- Manufacturer or distributor
Expiry dates do not seem to covered by the federal law (source) nor do the storage conditions. A nice overview can also be found on the North Dakota State University website.
Chinese food labeling regulation
We’re definitely no food label experts for the Chinese market, so we’ll limit ourselves here with a link to a guide for importing foods into China as well as a comparison of Chinese and European food labeling. That said, the basic requirements seem to be very similar to the European legislation although allergen labeling does not seem mandatory, but some other statements (e.g. radiation & GMO) do have to be stated.
Even though requirements may differ, there are a few common themes here on which we’ll zoom in with a bit more detail: nutritional value, ingredients, expiry date and allergens.
Food labels: determining nutritional value
Once you’ve developed a product its nutritional value will have to be determined. In a previous post we’ve taken a deep dive on determining the nutritional value of a food. As with any aspect, make sure that you determine the correct parameters. Some countries might ask for certain vitamins, whereas others are specific with regards to types or fat or sugar.
Overall, the nutritional value is meant to give consumers an indication of what’s in the food. It will help consumers choose which products to buy and which not.
Ingredient list on a food label
When reading food labels the ingredient list is the part where you get to learn most about the product. The list contains all ingredients present in the product (with a few exceptions though). The first ingredient is the list is the one that is present in the highest quantity of all ingredients. From there they are listed in descending order. From a certain percentage (2% in the EU) the order of ingredients may be random in some countries, since quantities are small anyway.
Of course, in real life there are a few things making the situation a bit more complex. For instance, in Europe certain ingredients do not have to be mentioned, these are so called ‘processing aids’. These are ingredients which have been added to the process for various reasons, but have no function anymore in the end product. Often their quantities are very small, they might have also evaporated for instance. Examples would be anti-caking agents which are added to spice mixes. These also end up in the final product, but do not serve a role in this final product anymore. Of course, these substances do have to be safe for consumption.
There are also a few other rules and guidelines. For instance, in Europe, if you’re making a strawberry yogurt, you’ll have to mention exactly how much of that strawberry is present. Do the yogurt only contain 0,5% or is 10% of the yogurt made up of strawberries? In most cases though, the quantity of ingredients does not have to be given (or manufacturers would be sharing their recipes!).
A group of ingredients worthwhile to mention are the so-called E-numbers. This only applies for Europe. E-numbers are additives which have been approved by the European Union for use in foods. As a result, they’ve been given a number. When reading food labels a lot of people will focus on these E-numbers. There’s some controversy on the topic, read the post dedicated on E-numbers to learn more.
Making food labels: storage conditions & expiry date
Not everywhere, but in a lot of countries it is obligatory for a lot of foods to have an expiry date on the label, with the accompanying storage conditions. The storage conditions of a food are closely related to the science of the product. It will determine whether it spoils at room temperature, whether it can be kept in a freezer, etc. There are roughly three categories of storage conditions for foods:
- Fridge (of freezer): Things that have to be stored in the fridge apparently don’t keep well at room temperature. Most likely because of growth of micro organisms.
- Room temperature, then fridge: Some products can be stored at room temperature, until they are opened. Then they have to be stored in a fridge. These are typically products that have undergone some sort of heat treatment to kill off micro organisms. Nevertheless, the product is such that micro organisms can still grow in them once they’ve been able to enter.
- Room temperature: There are the products that can simply be stored at room temperature. These are not prone to spoilage. Often it is mentioned that products should be kept in the dark. That indicates light can ‘hurt’ them, for instance through oxidation.
Once the storage conditions are known, you can use those to determine the shelf life of a food, but we’ve discussed that in a separate post on determining shelf life.
Why allergens are labeled
Last but not least, let’s have a quick look at allergen labeling. Allergens are ingredients of a food that people may be allergic to. Common examples are peanuts, crustaceans, gluten, milk and eggs. If these are present as an ingredient, they will be on the ingredient list. However, in some cases the allergens aren’t necessarily part of the recipe, but they may occur in a food product. Food instance if a production site first made bread with cheese and then a plain version. Some of that cheese might still be left and might contaminate the plain bread. Most consumers won’t notice, but people who are (highly) allergic will and it might be dangerous for them to eat. Therefore, labeling of these likely possible allergens and allergens present as an ingredient is often mandatory and very important.
This article aims at trying to help those interested in understanding and reading labels. In no way may this be considered as legal advice for setting up labels and the author is not responsible in any way for those using this information. Refer to the original legislative documents for a complete and most recent overview.