jamie oliver group food labelling standards (items being...

Food Development Manual/Legal Labelling Food Team October 2014

Jamie Oliver Group – Food Labelling Standards

(Items being sold in the EU)


Contents Introduction ............................................................................................................................................ 3

FIR Regulation (EU) No 1169/2011, the Food information Regulations (FIR) Requirements: ................ 4

Declaration of Mandatory Information .............................................................................................. 5

a. The name of the food ............................................................................................................. 5

b. The list of ingredients; ............................................................................................................ 5

c. Allergen labelling .................................................................................................................... 6

d. Quantitative Ingredient Declaration ....................................................................................... 6

e. Net Quantity............................................................................................................................ 7

f. Minimum Durability ................................................................................................................ 7

g. Special Storage Conditions ...................................................................................................... 8

h. Name of Business .................................................................................................................... 8

i. Country of Origin Labelling ..................................................................................................... 9

j. Instructions of use ................................................................................................................... 9

k. Alcohol content ..................................................................................................................... 11

l. A nutrition declaration .......................................................................................................... 11

Field of Vision: ............................................................................................................................... 14

Further Mandatory Information (if required) ................................................................................... 15

1. Safety Statements: ................................................................................................................ 15

2. Condition or Treatment of Food: .......................................................................................... 15

3. Serving suggestion ................................................................................................................ 16

4. Packed in a modified atmosphere ........................................................................................ 16

5. Local Law / National Measures ............................................................................................. 16

6. Product Specific Regulations ................................................................................................. 16

Voluntary Information: ......................................................................................................................... 19

1. Marketing terms: ...................................................................................................................... 19

2. Nutrition and Health Claims: ..................................................................................................... 19

3. Logos ......................................................................................................................................... 19

Food Information and Distance Selling: ................................................................................................ 21


Introduction

Any food labelled on or after 13/12/2014, intended for sale within the EU, must comply with

Regulation (EU) No 1169/2011, the Food information Regulations (FIR), along with any national

measures within the country it is being sold and product specific requirements:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:304:0018:0063:EN:PDF

This document outlines the expectations as to how FIR requirements should be presented across all

Jamie Oliver Group branded food items.

Partners or suppliers have a responsibility to provide information that is accurate to the finished

product and in accordance with the law, as covered in Regulation (EC) No 178/2002 (Article 17).

All food businesses involved in the supply of finished food products have a responsibility not to

supply food that they know or can reasonably presume to be non-compliant based on the

information available to them as professionals.

It is the expectation that the following responsibilities will be adhered to:

Licensee / Supplier

Supplying of accurate product information (via JOSIE).

Ensuring legal compliance of information on label

To be the expert in specific label requirements unique to the product area (e.g. Product Specific Regulations and Products of Protected Origin).

Ensuring that labels comply to local law and national measures in the country it is intended to be sold.

Ensuring label content and design are in line with the Jamie Oliver Food Labelling Standards.

Jamie Oliver Group

Reviewing artwork submissions against the technical product specification (JOSIE) and FIR requirements (Food Team).

Reviewing of adherence of artwork to branding requirements.

It is important to note that “food information” is broader than just the label on the pack, and includes “other accompanying material” or any other means including modern technology tools or verbal communication.

This includes web pages, leaflets / flyers, catalogues and telesales.



FIR Regulation (EU) No 1169/2011, the Food information Regulations

(FIR) Requirements:

The FIR states that all food labels, must as a minimum, include the below mandatory food

information:

a) The name of the food;

b) The list of ingredients;

c) Allergen labelling

d) Quantitative Ingredient Declaration (QUID)

e) Net Quantity

f) Minimum durability

g) Special storage conditions

h) Name or business

i) Country of Origin Labelling

j) Instructions of Use

k) Alcohol content

l) A nutrition declaration (exempt only when largest label face is 10cm2 or less. Food Team must be contacted in this

instance.)

Mandatory information MUST be included on all food labels. In addition to this, any national

measures or product specific requirements MUST be included. This information must not be

excluded or compromised to allow any other non-mandatory information on the label (this includes,

marketing images and text):

‘Voluntary information shall not be displayed to the detriment of the space available for the

mandatory food information’ (Chapter 5, Article 37, Food Information Regulations)


Declaration of Mandatory Information

a. The name of the food

This is the legal name of the food. In the absence of such a name, it shall be the customary name. If a

customary name is not available, then a descriptive name shall be provided. This will be in

accordance with Chapter 4, Article 17 of the FIR.

b. The list of ingredients;

The ingredient list will be preceded by the word ‘Ingredient’.

Ingredients will be listed in descending order of weight, as recorded at the time of their use in the

manufacture of the food. Also known as the mixing bowl stage.

Each new ingredient will be separated by a comma and begin with a capital letter.

Additives will be declared by their full name (not E number) and be preceded by their function. The

function and additive will begin with a capital letter:

e.g. Antioxidant: Citric Acid, Salt…..

Compound ingredients are ingredients that are made up of two or more ingredients e.g. cooked

pasta in a soup should be declared by the compound ingredient name followed by its constituents in

brackets after

e.g. Cooked Pasta (Water, Durum Wheat Semolina, Egg)

Certain foods are exempt from having to bear and a list of ingredients on the label, as specified in

Article 19 of FIR.

Declaration shall be in accordance with Chapter 4, Articles 18, 19 and 20 of the FIR.

Please note: due to mandatory fortification of UK wheat flour no longer having a degrogation for

labelling its fortification, these must now also be declared as a compound ingredient e.g. Wheat

Flour (Wheat Flour, Calcium Carbonate, Iron, Niacin, Thiamine).


c. Allergen labelling

Allergens will be highlighted in bold type within the ingredient list. This will extend to raw materials

within a component ingredient.

e.g. Soy Extract (Water, Soya Bean, Salt, Wheat), Salt, Molasses,………

Where the allergen is not named within the ingredient it shall appear in bold text and in brackets

directly after the ingredient containing the allergen.

e.g. Custard (20%) (Milk, Egg, Sugar), Salt……

An allergy advice section should be provided below the ingredient declaration. This will inform the

consumer that allergens are highlighted in bold as well as providing information on allergens that are

not intentionally added to the product, but might be found in the product or also handled in the

production area.

e.g. Allergy Advice: For allergens, including cereals containing gluten see bold ingredients. Also, may

contain sesame seeds.

For further advice please refer to the British Retail Consortium (BRC) Guidance on Allergen Labelling

and the Requirements in Regulation 1169/2011:

http://www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Labelling.pdf

d. Quantitative Ingredient Declaration

Percentages of ingredients in the final product will be listed after the ingredient if:

- The ingredient appears in the name of the food (product title, legal name or sub descriptor)

or is usually associated with the product name

- The ingredient is emphasised in words, pictures or graphics anywhere on the label

- The ingredient is essential to characterise a food

QUID values will be declared as a whole value. This value will always be rounded down, regardless of

the decimal figure.

If an allergen is present in the ingredient, the % will come before the breakdown of allergens

Further information regarding the requirement s can be found in Annex VIII of FIR.

e.g. Soy Extract (5%) (Water, Soya Bean, Salt, Wheat), Salt, Molasses,….

http://www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Labelling.pdf


e. Net Quantity

Net weight will be stated in units of volume in the case of liquid products and units of mass in the

case of other products.

For those foods in a liquid medium, a drained weight must also be declared.

For those products packed to an average weight, the following e-mark provisions apply:

- 5 – 50g = 2mm

- 50 – 200g = 3mm

- 200 – 1000g = 4mm

Suppliers and licensees to Jamie Oliver Group must ensure that products packed to average weight

are in compliance with the requirements Council Directive (76/211/EEC) as amended as well as any

other national provisions and product specific requirements.

f. Minimum Durability

“Use by” date to only be used for highly perishable items.

Best before + day and month for products with a shelf life up to three months.

Best before End + year for products with a shelf life of more 18 months.

Shelf Life Term Format

Highly Perishable Use by Day + Month (+Year)

< 3 months Best Before End Day + Month

>3months but < 18 months Best Before Month + Year

>18 months Best Before Year

Subject to provisions, certain products as laid out in Annex X (d) of the FIR will not require a date of

minimum durability e.g. vinegar.


g. Special Storage Conditions

Indication of special storage conditions and/or conditions of use must be provided if required by the

product.

The below list of text is approved for Jamie Oliver branded products and should be used as

appropriate.

- Defrost thoroughly before use and consume within… hours.

- Do not exceed the “use by” date.

- Do not refreeze once defrosted.

- Freeze on day of purchase and use within...

- Keep refrigerated.

- Make sure you put the lid firmly back on to keep the product air tight.

- Not suitable for home freezing.

- Once opened, refrigerate and use within… days.

- Store at -18°c or below.

- Store in a cool dry place, out of direct sunlight.

- Store in a cool dry place.

- Suitable for home freezing.

h. Name of Business

For products produced under license to the Jamie Oliver Group, for the purpose of product

packaging, the Food Business Operator is the licensee. The licensees address should appear in the

following format.

e.g. Say hello to us at… Young’s Seafood, PO Box 51, Grimsby, DN31 3TJ.

For products being sold by a Jamie Oliver business (e.g. Jamie’s Italian), the respective Jamie Oliver

business is the Food Business Operator. Therefore, the address on pack should be that of the Jamie

Oliver Business.


i. Country of Origin Labelling

Indication of the country of origin or place of provenance is mandatory;

- Where failure to indicate this might mislead the consumer

- For meat falling within Combined Nomenclature (‘CN’) codes listed in Annex XI of the FIR

Where the country of origin or place of provenance of a food is given and where it is not the same

as that of the primary ingredient;

- The country of origin or place of provenance of the primary ingredient in question shall also

be given; or

- the country of origin or place of provenance of the primary ingredient shall be indicated as

being different to that of the food.

With regards to the names of products and/or the names of their constituent ingredients, particular

attention must be paid to terms associated geographical indication in accordance with Regulation

(EU) No 1151/2012 as amended. Licensees and suppliers are to ensure that where such terms are

used, the product and/or its constituents meet the relevant requirements.

j. Instructions of use

Instructions should be indicated in such a way as to enable appropriate use of the food. For

example, cooking of raw meat.

This should not be confused with serving suggestions used for marketing.

For consistency, the following text is approved for use on Jamie Oliver branded products, but should

be adjusted as appropriate:

To oven bake: Preheat the oven to … °c / …°c fan / gas mark …

Remove all the packaging.

Remove the sleeve and film lid.

Remove the sleeve and pierce the film lid.

Place on a baking tray.

Place on a baking tray in the centre of your hot oven and bake for… minutes.

Let it rest before carving.


To fry:

Heat a little olive oil in a heavy-based frying pan on a … heat.

Add to the hot pan and cook for … minutes, turning frequently, or until cooked through.

Heat a heavy-based frying pan on a … heat.

Add the … to the dry pan and cook for … minutes.

Turn every few minutes until cooked through.

Give the pan a shake every now and then, until cooked through.

To microwave:

Pierce the film lid and place on a microwavable plate.

Remove the film lid and place on a microwavable plate.

Tear the pouch open by a few centimetres and place onto a microwavable plate.

Heat on full power for … minutes (750 W) or … minutes (850 W).

After … minutes, give the product a stir, then stick it back in microwave for a further… minutes.

Leave to stand for a minute before serving.

Be careful taking it out of the microwave because it’ll be hot, and watch out for steam when you

open it.

To Boil:

Bring a large pan of salted water to the boil.

Add the … to the pan and cook for … minutes.

Add the pasta to the pan and cook for around… minutes, until the pasta is soft but still has a bit of a

bite, then drain.


To Grill:

Preheat your grill to a … heat.

Remove all the packaging and place on a grill pan.

Cook for … minutes, turning occasionally, until cooked through.

General:

Turn frequently, until cooked through.

Leave it to rest for… minutes before serving.

Leave it to rest for … minutes before carving.

All appliances vary, so these are only guidelines. Always check the… is thoroughly cooked and piping

hot all the way through before serving.

k. Alcohol content

Shall be adhered to as specified in Chapter 4, Article 28 of the FIR.

l. A nutrition declaration

Front of pack:

Where a Jamie Oliver business is signed up to the Department of Health front of pack nutrition

labelling pledge; follow the guidance from the Department of Health ‘Guide to creating a front of

pack (FoP) nutrition label for pre-packed products sold through retail outlets’.

Note that Jamie Oliver Licensing Limited will be displaying the front of pack nutrition labelling on all

food retail products (except for those foods exempt according to Annex V). For an example of how

we would expect to see the information displayed on the FoP, see the image below:


Please note, we would not expect to see FoP labelling on those foods listed in Annex V of the

regulations: which includes single ingredients, e.g olive oil, salt, tea, vinegars, herbs, spice and mixes

thereof.

Back of pack nutrition labelling regulations

Back of pack nutrition information is no longer voluntary. Nutrition information must appear

directly on the package or on a label attached to all pre-packed foods. Foods listed in Annex V of

the regulations are exempt from declaring nutrition information.

Nutrition information per 100g is mandatory. Nutrition information per portion must be provided

on pack although this is voluntary information. Where space is limited on pack this may be omitted

but should be agreed with Jamie Oliver Group Food Team. Where this is provided the portion or unit

used must be quantified on the label as well as the number of portion or units contained. This must

be easily recognisable to the consumer. Where reference intake (RI) information is declared it must

be expressed as ‘per portion’ if the size of the portion is indicated in close proximity to the nutrition.

Mandatory fields (declared in this order)

Nutritional information

Typical values Per 100g or per 100ml

Energy kJ/kcal

Fat g

of which saturates g

Carbohydrate g

of which sugars g

Fibre g

Protein g

Salt g

Note - Energy values must be rounded to a whole value / Nutrients which are equal to or under 10g or less

must be declared to one decimal place / Nutrients over 10g must be rounded to a whole value / Salt should be

declared to two decimal places.


The mandatory nutrition information must be presented in the same field of vision and together in a

clear format.

Voluntary fields

Where there is sufficient space available on back of pack, RI should take priority over other voluntary

information.

Where RI is declared, it should be displayed as follows:

Nutritional information

Typical values Per 100g or per 100ml

Per 1/3 pot % adult RI Per 1/3 pot

Adult RI

Energy kJ/kcal 8400/2000

Fat g 70g

of which saturates g 20g

Carbohydrate g 260g

of which sugars g 90g

Fibre g N/A N/A

Protein g 50g

Salt g 6g

Where % RI’s per 100g (or per 100ml) are provided, you must provide the additional statement

“Reference intake of an average adult (8400kJ/2000kcal)” in close proximity to the information on

RI’s.

RI%'s must be rounded down to a whole value with no decimal places. Any nutrient less than 1%,

should be declared as '<1%'

The voluntary nutrients including mono and poly unsaturated fats, polyols, starch and vitamins and

minerals are not necessary on back of pack.

Requirement for the nutrition declaration to be in linear format:

The FIR requires nutrition information to be presented in tabular format. Where space is limited on

pack then provisions allow for this to be given in linear format but should be agreed with the Jamie

liver Group Food Team. When considering if space is constrained voluntary information does not

need to be taken into account.

Application of legibility rules to the nutrition declaration:

You must print the mandatory nutrition declaration on the package or on the label in characters

using a font size where the ‘x-height’ is a minimum of 1.2mm.

If the largest surface of your package or container has an area of less than 25cm2, then your product

is exempt from the requirement to provide a mandatory nutrition declaration.


Per portion nutrition information

Where there is sufficient space, the nutrition information per portion (e.g. half a jar of pasta sauce)

may be given, as long as this information is given in addition to the mandatory per 100g (or per

100ml) information.

The number of portions and/or consumption units must be stated in the package.

Reference intakes (RI’s)

Note change from Guideline Daily Amounts (GDA’s) to RI for major nutrients. RI’s are benchmarks

for the amount of energy and key nutrients that can be consumed on a daily basis in order to

maintain a healthy diet.

Sources of nutrition information

Can be based on either:

1. The manufacturer’s analysis of food.

2. A calculation from the known or actual average values of the ingredients used.

3. A calculation from generally established and accepted data (e.g. McCance & Widdowson).

Nutrition information is based on ‘as sold’. If appropriate it can be ‘as consumed’ as long as this is

made clear to the consumer.

Field of Vision:

The following mandatory information must appear in the same field of vision on pack:

Name (Legal Name)

Net Quantity

Alcohol Content (for products containing more than 1.2% alcohol by volume)


Further Mandatory Information (if required)

Although not listed in the above, there is further mandatory information outlined in the FIR, that

should be present on pack if required. This includes:

1. Safety Statements:

If a food product requires a specific statement to be added, then it must be included on the product

label. Below are the approved statements available for use on Jamie Oliver branded products. (this is

not a definitive list)

Although every care has been taken to remove olive stones, some may remain.

Although every effort has been made to remove all bones, some may remain.

Caution this product contains sharp wooden skewers.

Check food is cooked thoroughly before serving.

Discard any mussels that do not open on cooking.

Made using unpasteurised milk.

Reject if centre button on cap can be depressed.

These are guidelines only, as all appliances vary in performance. (Mandatory for all foods which

require cooking or heating)

Unsuitable for infants under 12 months of age.

Safety statements will be declared in bold text.

2. Condition or Treatment of Food:

Foods sold defrosted

Must be named as defrosted X unless:

It is an ingredient in the final product

Freezing is a technologically necessary step

Freezing does not affect the safety and/or quality of the final product


3. Serving suggestion

If an image of the food is providing ‘serving suggestion’ must be provided

4. Packed in a modified atmosphere

If the food is packed in a modified atmosphere, then this must be indicated on the pack

5. Local Law / National Measures

As with all mandatory information, the licensee must ensure that all information provided to the

Jamie Oliver brand is correct and compliant with all local law and national measures of the country

in which the product is being sold.

6. Product Specific Regulations

Where necessary, products affected by the below regulations, must fully comply with these

requirements, as well as the FIR:

The Meat Product Regs

Regulation (EC) 853/2004:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2004R0853:20130906:EN:HTML

Jam and Similar Product Regs

Council Directive 2001/113/EC:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2001L0113:20131118:EN:PDF

Cocoa and Chocolate Prod. Regs

Directive 200/36/EC:


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2004R0853:20130906:EN:HTML




Marketing Standards for Olive Oil (Commission regulation (EC) No 1019/2002)

Regulation (EU) No 29/2012:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2012R0029:20130701:EN:PDF

Honey Regs 1976

Directive 110/2001/EC


Fruit Juices & Fruit Nectar Regs 1991


This came into force from 28th October 2013. Products placed on the market prior to this date can

continue to be sold through till 28th April 2015.

Milk Labelling Regs (1984)

This has been repealed and is covered by the marketing standards regulations: Regulation (EC) No

134/2007


Natural Mineral Water regs 1988



Coffee and Coffee Produce Regs 1987

Directive 1999/4/EC









Sugars Legislation



PDO/PGI/TSG Legislation

Regulation (EU) No 1151/2012

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:343:0001:0029:en:PDF

http://ec.europa.eu/agriculture/quality/door/list.html

This list is not definitive and the FIR (Regulation (EU) No 1169/2011) must be used as the final

document to ensure a food product label is legally compliant.


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:343:0001:0029:en:PDF

http://ec.europa.eu/agriculture/quality/door/list.html


Voluntary Information:

The Food Information Regulations state:

‘Voluntary food information shall not be displayed to the detriment of the space available for

mandatory food information’

Therefore, mandatory information must be present, before any voluntary information is included.

Voluntary information can be more prominent than mandatory information, but it must not be

misleading, ambiguous, confusing to the consumer or presented in such a way to the detriment of

mandatory information.

Any information present on pack that is not mandatorily required is regarded as voluntary and can

be considered a claim. It is the responsibility of the Food Business Operator to ensure that any

claims made on pack are not misleading to the consumer.

1. Marketing terms:

All marketing information is regarded as voluntary information. All marketing terms must be

accurate of the product being sold and not mislead the consumer in anyway.

In addition to this any terms outlined in the Food Standards Agency: Criteria for the use of the terms

fresh, pure, natural etc. in food labelling are intended to be used, they must be validated with

relevant specification information.

2. Nutrition and Health Claims:

Any nutrition and health claims must be approved by the Food Team and conform with: Nutrition

and Health Claims (Regulation (EU) No. 1924/2006).

3. Logos

Where logos will appear on the product label, they must be validated and accurate of the product. It

is the responsibility of the licensee or the manufacturer to ensure use of third party logos conform

to the labelling requirements of the third party and obtain any necessary authorisation from them

for their use. Such logos may include:

Freedom Food


Vegetarian Society

Soil association

PDO/IGP….

Recycling

Fairtrade


Food Information and Distance Selling: “Food information” is broader than just the label on the pack, and includes “other accompanying material” or any other means including modern technology tools or verbal communication. Mandatory food information must be made available before the purchase is concluded. As such, it

must appear on material supporting the distance selling.

Jamie Oliver Licensing products

It is the responsibility of the licensee to ensure that all mandatory information is available and

accurate. It is the licensee’s responsibility to ensure that this mandatory information is available to

those selling the product.

All Jamie Oliver branded products

It is the responsibility of the supplier to the Jamie Oliver Group to ensure that all mandatory

information is provided and accurate using JOSIE. It is the responsibility of the Jamie Oliver brand

under which the product is being sold to ensure that all mandatory information is available to the

consumer at point of sale.

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