Scottish stakeholder forum on providing food information to consumers: 12 March 2008

Friday 18 April 2008

The Food Standards Agency in Scotland (FSAS) held a stakeholder forum in Edinburgh on the 12 March 2008. The forum provided an opportunity for the 21 attendees to receive information on the purpose and content of the Commission proposal, to facilitate open discussion and to provide their initial views.

Lydia Wilkie (Assistant Director of Policy, FSAS) opened the meeting and outlined the consultation process in Scotland on the proposal.

Steve Pugh (Head of Food Labelling and Marketing Terms Branch, FSA) provided some background to the proposal, followed by a general overview. The next steps were explained in terms of both FSA activities and procedures in Brussels.

Steve Pugh then opened the discussion session during which stakeholders were provided with a number of short presentations by him and FSAS staff on nutrition labelling, labelling clarity, country of origin labelling, food sold non-prepacked, distance selling and labelling of alcoholic drinks. The discussion session enabled stakeholders to ask questions, highlight any areas of concern or make observations about the proposal.

The following points were raised:

Alcoholic drinks – ingredients listing and energy declaration

• There should be consistency across the industry – why should wine, beer and spirits be treated differently from any other product?
• Ingredients listing is problematic for 'secret recipes' and could effect marketing.
• Problems around alcoholic units and portion sizes – they are not specified and both vary across Europe. If energy values are quoted per 100ml consumer would need to calculate for a portion size. Additionally, this might be taken to imply 100ml is a 'portion' to be consumed.
• The issue of labelling of cider was raised.
• Is there scope for labelling alcohol units meaningfully across Europe?
• Different labels are required for different markets – no alcoholic drink label could cover all countries in the EU.

Country of origin

• Clarity sought on whether there is scope to list 'Scotland' as country of origin as opposed to Member State ('UK').
• The separate legislative rules for beef labelling arose from the BSE problem. Should these rules now be incorporated into general labelling?
• Scottish consumers want to buy locally produced meat; a voluntary scheme will not ensure this.
• Mandatory origin labelling would aid sustainable development through consumer awareness of 'food miles'.
• Mandatory origin labelling would help avoid fraudulent labelling.

Distance selling

• Consumer would want quantitative ingredient declaration (QUID) and alcohol by volume (ABV) information at time of placing order.
• Clarity sought on whether a label/labelling needs to be a physical thing, and physically attached to the product? Or is it sufficient to be available on the company's website? (This cuts down on packaging and promotes sustainability.)
• When a recipe is advertised and a consumer buys products to make the recipe, should raw materials be labelled or the recipe itself?
• If an internet business is getting local producers to supply foods to the consumer, such as a farmer that delivers his own produce to a consumer's home, would labels be required?
• All labelling on goods delivered adds costs to small businesses.
• Why should distance selling be considered in proposal at all? – normal regulations apply.
• Nutrition information could be available on company's website only.
• Concerns about enforcement of distance selling.

Labelling clarity

• FSA traffic lights should be mandatory throughout the EU – simple, easy to use at a glance information.
• 3mm font size may pose problems for multi-language labels.
• Type of font can affect legibility.
• Difficulty in defining 'significant contrast'.
• Difficulty in enforcing labelling clarity.
• Article 16 is confusing; Welsh and Scots Gaelic are not official languages of the Member State.
• Need less prescription.

Non-prepacked foods (foods sold loose and prepacked for direct sale)

• Non-prepacked food should be treated the same as prepacked foods.
• FSA voluntary 'best practice' guidance is an invaluable resource in the short term, and should become mandatory in the future.
• Cross contamination can be a big problem especially in small restaurant kitchen.
• Problems arise when there is a change in supplier or recipe, important that allergen information is updated to reflect changes and staff are informed. Suggestion that regulation addresses the issue of education of food business staff.
• HACCP (a food safety management system) should already cover safety aspects of dealing with food allergens.
• Allergen labelling particularly important for deli counter products, such as breaded ham.
• Concern that choice/availability will decline if allergen labelling becomes mandatory on non-prepacked foods.
• Do not want to end up with all foods labelled as 'may contain…'
• Will there be thresholds levels/lower limits for allergens permitted in food?

Nutrition labelling

• Public health benefit to providing energy information on alcoholic drinks.
• Portion size enables comparison between product types and when amount consumed is generally less than 100g/100ml. Per 100g/100ml allows for comparison between similar products. Why not use both 'per portion' and 'per 100g/100ml'.
• Concern about cost of establishing nutritional data for small businesses.
• Possibility of exemption for small/local sales?
• Calculation of Nutritional information at 'mixing bowl' or final stage?
• Tolerance levels, for example, this could make the difference between a 'low fat' and 'medium fat' product.