Sir: Last week’s announcement of the new government-approved layout for front-of-pack nutrition labelling represents the culmination of many months of hard work by food businesses, the DH and other parties. However, concerns remain that this new system will be too complicated for consumers to use. The recommended format will also take up a lot of space on the pack.
Hitherto, businesses have been free to adopt the front-of-pack nutrition format they want, so the suitability of the government’s recommended format was not too important. However the legal options available will soon be much narrower.
From December 2014, the only options will be the model prescribed by the EU Food Information Regulation or an “additional form of expression” developed in a way prescribed by the regulation. The new UK system is one such expression.
The EU model bans both colour coding and the use of words such as “low”, “medium” and “high”. The UK system permits these - but will result in nutrition lozenges that will be pretty “busy”. For small packs in particular, this makes the UK system quite unattractive.
Many well-known brands have declined to indicate they will use the UK system. They may decide it is better not to give any front-of-pack nutrition summary, or may use the simpler EU format and give up on colour coding.
Alternatively, it would be possible for such businesses to undertake a public consultation and then introduce yet another alternative expression under the EU regulation. I wonder if there is any appetite for manufacturers to club together to pursue this option.
It will be interesting to see if there is resistance in other EU countries to the sale of products labelled in accordance with the UK scheme - such sale is permitted by EU law, but past experience suggests a number of countries might be very unwilling to accept a voluntary scheme that is the outcome of consultation in the UK alone.
Owen Warnock, partner, Eversheds LLP professor, University of East Anglia
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