Marketing terms: General comments from consultation
This document provides a summary of the submissions made during the public consultation on a
draft Code of Practice on the Use of Food Marketing Terms which was conducted by the Food Safety
Authority of Ireland between the 19 March 2014 and 14 May 2014.
In this document the submissions are categorised by nature of the person/group making the
submission. Please note that the original submissions will be considered in full by the stakeholder
working group in FSAI before amendment of the Code and publication later in 2014.
Enforcement officers
• Definition of use of the term ‘Home made’ would help enforcers
• Expand the document to cover the terms ‘fresh’, ‘pure’, ‘original’, ‘authentic’, ‘real’,
‘genuine’, ‘home-made’,’ hand-made’, ‘premium’, ‘finest’, ‘quality’, ‘best’. See UK guidance
for cross reference. Would be useful for enforcement and industry alike in Ireland
• The word ‘healthy’ needs to be defined to improve enforcement
• Need to account for legal definitions of natural in the nutrition claims legislation
• Footnotes to legislation need to be reviewed for accuracy and quoted in context. Other
detailed editorial comments provided.
Industry
• Artisan group for a specific sector: Definitions are not strong enough. Exemptions on use of
farmhouse for chunky soup should not be allowed. Misuse in the past should not allow
misuse in the future. Local sourcing 100km is a good idea but the opt-out clause ‘where
available in the required quantity’ provision will lead to abuse and excuse not to use local
sourcing.
• Large Trade Body: Modify purpose with suggestion taken from FSA(UK) guidance document
where use of the terms should be taken in the context of the label as a whole, the
presentation of the product and on a case by case basis. Use the word ‘guideline’ rather
than ‘rules’ in body of document. Modify scope with suggestion taken from FSA(UK)
guidance document that the advice is not an authoritative statement or interpretation of the
law and Food Business Operators (FBOs) must ensure compliance with the law. Also that
compliance with best practice advice is not required by law. Allow the use of the words
‘style’ with the term farmhouse and note qualifying wording used in the FSA(UK) guidance
document. Other detailed editorial comments provided.
• Small FBO: Need to stop the abuse of claiming coffee is roasted in house when it is actually
imported. Origin of beans and origin or roasting needs to be required.
• Small FBO: Commend the FSAI for taking the initiative. Don’t use these terms today as they
are so misused. The 1000kg limit for traditional is too low to allow viable business for small
meat producers.
• Small FBO: Roasts own coffee and describes itself as artisanal. Thinks the requirement to
source locally does not account for ingredients that are not grown in Ireland. Definition for
term ‘artisan’ needs to be amended.
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Large retailer: Supports the approach of setting general principles rather than prescriptive
guidance on individual terms, but focus on terms should only be done when there is a clear
need. e.g. consumer complaints rather than views of interest groups. Include therefore the
supporting rational for why definition of each term is required. Natural should be allowed
for compound foods made from all natural ingredients and is common usage today. Artisan
definition is too restrictive in particular the local requirement for certain types of food e.g.
chocolate, cheese, bakers. Farmhouse definition should focus on the farmhouse element
without introduction of elements of the artisan definition. Derogations should be examples
not definitive lists. Traditional should be 25 years in keeping with EU legislation (Note from
FSAI: this legislation has changed recently and is now 30 years). Retailers should be included
in the stakeholder group developing the guidance.
Trade body for a single sector: Term natural needs clarification if it just refers to a foodstuff
or also covers promotion of a specific food category e.g. natural as applied to dairy.
Large FBO: Should include the concept of qualifying language in the COP for the term
‘natural’ to reflect market reality that there are different degrees of naturalness between
different foods and food categories.
Consumers
• Representative body of consumers of a specific product category: Welcome the consultation
and think the document will help consumers make reliable and informed choices about the
products they buy. Want a definition of the word ‘craft’ as applied to drinks as this term is
more commonly used with drinks than the word artisan.
Other
• Agri-food tourism promotion body: Support the development of the COP but should be a
code of best practice. Would benefit from a more narrative style as difficult to read. Include
templates with criteria for using terms with good examples. Extend scope to All Ireland
under current cross boarder structures. Code should be compatible with UK code to address
imports and there should be an MOU with FSA(UK). Use rolling 2 year survey to monitor
adherence to the code with names being published along with FBO responses. Include brief
description of the 3 Europe and labelling schemes in an annex i.e. TSG, PGO, PDI. Extend
terms to cover ‘authentic’, ‘hand-made’, ‘home-made’, ‘original’.
• Artisan food promotional body: Commended FSAI for the initiative. For the term ‘farmhouse’
support the generality of a 1000kg production cut off but would like exemption for CAIS
members to continue to use term even though production might exceed 1000kg. Extend the
COP next to cover the terms ‘fresh’, ‘seasonal/in-season’, ‘pure’, ‘original’, ‘home-made’.
Enforce using a two step process - a) simple queries dealt with by a representative
stakeholder group similar to existing working group b) specific complaints dealt with by a 3
member grouping similar to existing employment tribunals but consisting of FDII or Taste
Council, Consumers association, National Standards Authority of Ireland.
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