FSA Consultation Letter, 1 October 2007

LABELLING - Food Standards Agency consults on guidance on clear food labelling

A copy of the consultation document is available on this site: Draft Revised Clear Labelling Guidance

The Agency issued Clear Food Labelling Guidance in 2002 and is now seeking to issue improved Guidance by making the changes set out in the consultation documents. The Guidance sets out legislative requirements, as well as best practice advice. Responses are requested by: 24 December 2007

Consultation details

The objectives of the guidance are as follows:

• to improve labelling practice with respect to clear labelling and awareness of existing legislation on clear labelling in the manufacturing and retail sectors
• to improve consumer confidence in labelling through improved clarity, particularly bearing in mind visual impairment issues
• to provide enforcement authorities with guidance to help them improve labelling advice

The proposals are to revise the guidance to include:

• reformatted guidance to enable better accessibility by small and medium enterprises and diagrams to illustrate the best practice points for ease of reference
• an expanded rationale, so that the best practice recommendations are provided with context
• improved best practice recommendations that address the many factors that affect clarity including print size, contrast and layout
• advice on presentation features to use with care and those to avoid
• advice on small labels and how to prioritise labels that carry many items of information
• a section on key legal requirements relevant to clear labelling
• an annexe that outlines relevant legal requirements covering rules on presentation, mandatory information, information that must be present in some circumstances, and nutrition and health claims

Introducing these changes to the guidance would be helpful to consumers by providing better labelling through improved best practice advice and updated advice on legislation for industry. This will be particularly helpful for partially sighted consumers as many can read printed information if it is well designed with respect to features including good text size and contrast.

The guidance also provides a reference document covering factors that affect clarity. This may be helpful to local authorities when providing advice to industry, and also for considering whether enforcement action is appropriate in relation to food or trade descriptions legislation, (although it should be recognised that the recommendations are best practice advice and not advice on compliance with legislation).

Please see the Regulatory Impact Assessment (RIA) and Summary Impact Assessment in the accompanying document.

We particularly welcome views from:

• small business and manufacturers with regards to costs of familiarisation with the revised guidance in particular
• small business that may be affected by the proposed revisions
• all stakeholders on the costs and benefits of the proposed options
• stakeholders on how the options may affect competition in the food sector
• enforcement authorities regarding how helpful they find this guidance
• stakeholders on the extent to which the policy meets the needs of disabled consumers, particularly visually impaired consumers
• all stakeholders on the sustainability issues related to our guidance