LABELLING - Proposed Draft Amendment to the General Standard for the Labelling of Prepackaged Foods - Quantitative Ingredient Declarations (QUID)

The existing requirements

Section 5.1 of the Codex General Standard for the Labelling of Prepackaged Foods simply requires QUID declarations to be given when special emphasis is placed on the presence of valuable or characterising ingredients, or on the low content of one or more ingredients.

The proposed changes: the original proposal

This would replace the existing requirements with more detailed rules requiring mandatory QUID declarations to be given in the ingredient list of a food for every ingredient (including those within compound ingredients) comprising more than 5% of the food by weight.

Any ingredient emphasised on the label by words or pictures, or normally associated with the food by consumers, would also attract a mandatory QUID declaration. This would need to be given in close proximity to the words or images emphasising it, or beside the common name of the food, in lettering at least 50% as large as the common name. The same provision would apply to products bearing a name or having some other similarity with another food having a different composition.

The proposed changes: the alternative proposal

This takes the original proposal as its starting point.

Here it is proposed that QUID declarations should be voluntary rather than mandatory, but that they should follow a specified set of conditions when they are given.

If given, every ingredient (including those within compound ingredients) that

• is associated by consumers with the food, or
• is emphasised on the label in words or pictures, or ~ is essential to characterise a food, or
• is essential to distinguish a food from others with which it might be confused, or
• is mentioned in the name of the food, or

In addition, ingredients given emphasis on the label in words or pictures would attract QUID declarations, which would have to be given in close proximity to the emphasising words or pictures, or beside the common name of the food. These rules would also apply if the product has a name or bears some other similarity to another food having a different composition with which it might be confused, and to any ingredient normally associated with a food by the consumer.

The most notable differences between these two proposals and those that apply in current European and British food labelling rules are

• the requirement in the original proposal for the quantities of all ingredients present at more than 5% to be given (instead of just those that are mentioned in the name of the food or usually associated with it by the consumer);
• the specific print size requirements in the original proposal (absent from the alternative proposal) ;
• the lack of any exemptions in both proposals (such as for ingredients used in small quantities for the purposes of flavouring); and
• the voluntary nature of the provisions in the alternative proposal.

The FSA need to submit comments on the proposal to the Codex Secretariat by 15 December.