Consultation Document
The following draft guidelines have been produced by the British
Sandwich Association and Monmouth County Council under the
Primary Authority scheme and are being circulated to the industry and
enforcement bodies across the UK for comment before a final version
is produced later this autumn.
Please note that Defra has been asked to clarify the use of the term
‘Use by End of’ which appears in this draft.
The closing date for receipt of comments is 1st November 2013
Reponses should be sent to The British Sandwich Association, 18c
Moor Street, Chepstow NP16 5DB or by email to [email protected]
GUIDANCE NOTES ON THE LABELLING OF SANDWICHES
CONTENTS
1. Introduction
2. General Labelling Requirements
3. When is Labelling Required?
4. Manner of Marking or Labelling
5. Names of Products
6. Ingredients Lists
7. Nutritional Labelling/Nutrition Claims
8. Other Claims
9. Additive Declarations
10. Date Marking
11. Allergen Information
12. GM Ingredient Declaration
13. Other Legal Requirements
Annex A: Food Names –Guidance
Annex B: FSA Advice on the Labelling of Sandwiches Containing Meat Ingredients –
August 2006
Annex C: Allergens Schedule
Annex D: Labelling examples
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Definitions:
Manufacturer – a business that makes sandwiches at one or more central locations
which are then sold through third-party owned outlets.
Central Production Unit – a site where sandwiches are manufactured for retail
through the business’ own retail or catering outlets
Sandwich Bar – where sandwiches are made on site or at a central production unit
owned by the same business for direct sale to the end consumer.
Sandwich Retailer – a business that sells sandwiches which are bought in for resale
from a manufacturer
1. Introduction
1.1 This guidance has been prepared by The British Sandwich Association and
Monmouthshire County Council under the Primary Authority Scheme for use by
enforcement officers solely in relation to advice on labelling to be given to producers
and sellers of sandwiches (e.g. filled rolls, baps, baguettes, French sticks, pittas,
ciabattas, wraps etc.). This guidance is not intended to cover other products such as
quiches, pizzas, pies etc.
1.2 This guidance primarily relates to compliance with legal requirements. However,
it also includes best practice advice which appears in blue in the text. Best practice
guidance is intended to provide greater clarity for consumers, however, compliance
with best practice guidance is not a legal requirement.
1.3 This guidance takes account of the new Food Information Regulations
established by the European Commission (Consumers Regulation (EU) No.
1169/2011) which comes into effect from 13th December 2014.
2. General Labelling Requirements
Responsibilities
The business or person whose name the food is marketed under is responsible in law
for the food information provided on the label. So, if a sandwich is made by a
manufacturer but sold under the name of a retailer or brand name, the responsibility
for ensuring the accuracy of the label rests with the retailer or brand owner. The
manufacturer would, however, remain responsible if the product is sold under its
own name or a brand name it owns.
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2.1 Generally manufactured pre-packed sandwiches are required to be labelled with
the following information:
(a) The name of the food**
(b) A list of ingredients
(c) QUID declarations (where appropriate), normally within ingredients list but can also be
next to the name of the food
(d) A date mark (which can also act as the lot mark)
(e) Storage advice (if appropriate)
(f) Instructions for use (if appropriate)
(g) The name and address of the operator or business responsible for the food information
(h) A list of additives (if appropriate)
(i) Identification of irradiated ingredients (if present)
(j) Identification of genetically modified ingredients (if present)
(k) A list of specified allergens (if present)
(l) A nutritional declaration
[ NOTE: ** where the term “name of the food” appears throughout this document
this refers to the true nature/legal name of the food].
2.2 When sandwiches are sold pre-packed – whether manufactured or made on the
premises - they must state the name of the food in such a way as to clearly indicate
its true nature and to distinguish it from products with which it could be confused. It
may, in addition, bear a “marketing” or “fancy” name [e.g. “BLT”] but care must be
taken not to mislead consumers by over simplifying names. It is generally
considered good practice to state an appropriate description (such as Bacon, Lettuce
and Tomato) alongside the ‘marketing’ or ‘fancy’ name to avoid any confusion.
2.3 The name given to the product must be its true legal or, in the absence of a true
legal name, its customary name. Where no such name exists, the name given to
the product must provide the key information that consumers need to make their
choice. This needs to include the presence of major ingredients (e.g. meat, cheese
etc) and characterising ingredients (e.g. sun dried tomatoes, mayonnaise etc.) that
could govern consumer choice.
2.4 It is likely to be considered misleading if the name of the food omits to declare
the processed nature of major ingredients that might affect the consumer’s
assessment of character and quality.
2.5 Care must be taken with illustrations on labels or packs that these do not mislead
consumers. For example, a generic illustration of mixed salad, including a tomato,
might be considered misleading if the sandwich within did not contain tomato.
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3. When is Labelling Required?
3.1 Full labelling (i.e. that set out in paragraph 2.1 above) is necessary in relation to
pre-packed sandwiches produced by a manufacturer but sold through a third party
outlet and which are sold in their original packaging.
3.2 Reduced labelling (the name of the food; declaration of additive
categories/GM/irradiated ingredients/allergens) may be used where sandwiches are:
(i) Produced, packed and sold within the same retail premises; or
(ii) Produced and sold non pre-packed within the same premises; or
(iii) Produced at a central location and sold (pre-packed or non pre-packed) by staff
directly employed by the same business via shops, vans or office delivery rounds; or
(iv) Produced and delivered non pre-packed to a retail premise (e.g. from a central
bakery to retail premises owned and run by the central bakery) and then sold non
pre-packed from those premises.
3.3 Limited labelling is required where sandwiches are made and sold within the
same premises (e.g. a canteen or sandwich bar). However, any descriptive/menu
names applied must be accurate and, where applicable, an indication of any
irradiated and/or genetically modified ingredient must be given together with
allergen information (see paragraph 12.3). Note: it is a new requirement under the
EC regulations that allergen information must be provided for foods sold nonprepacked or prepacked for direct sale.
3.4 Vending machines selling sandwiches must have a ‘menu’ with the “name of the
food” as well as the basics set out for limited labelling (3.2) unless this information
can be clearly read on the product pack from the outside of the machine. The
sandwiches themselves will be pre-packed and must be fully labelled.
3.5 Whilst some sandwiches require limited labelling under the regulations any
names or descriptions applied must comply with the general provisions of the Food
Safety Act 1990 and other trading standards legislation which prohibit false and
misleading labels, descriptions (including verbal descriptions) and descriptions in
advertisements.
[ NOTE: The term “pre-packed” is defined in the Food Labelling Regulations 1996 as
“put into packaging before being offered for sale in a way such that the food,
whether wholly or partly enclosed, cannot be altered without opening or changing
the packaging and is ready for sale to the ultimate consumer or to a catering
establishment”. Similarly “pre-packed for direct sale” is defined as “ pre-packed by
a retailer for sale by him on the premises where the food is packed or from a vehicle
or stall used and operated by those working for him”].
It is generally considered good practice for retailers and manufacturers to provide as
much information as possible on labels to help consumers make a reasoned choice.
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Where reduced labelling is used, retailers should ensure that those selling the
sandwiches direct to the consumer are fully briefed on information (e.g. ingredients,
allergens etc.) to enable consumers – some of whom may have allergies – with all the
information they require to make a proper selection. It is good practice for staff to
have access to a reference folder or similar checklist so that they can handle
customer inquiries accurately.
4. Manner of Marking or Labelling
4.1 For all fully labelled sandwiches, the required information must be marked:
(i) on the packaging; or
(ii) on a label attached to the packaging; or
(iii) on a label that is clearly visible through the packaging.
4.2 For sandwiches (other than those sold at catering establishments) which are
required to have reduced labelling, the information must be marked:
(i) on a label attached to the food; or
(ii) on a label, ticket or notice that can easily be seen and read at the place of sale
by an intending purchaser.
4.3 This required information must be marked in a conspicuous place, be easy to
understand, indelible, clearly legible and not hidden, obscured or interrupted by
other written or pictorial matter.
It is also a requirement that in the case of
packaged sandwiches this information must be printed in characters using a font size
where the x-height is equal to or greater than 1.2mm.
In the case of packs or containers where the largest surface area is less than 80 cm2,
the x-height of the font can be equal to or greater than 0.9 mm
4.4 Under the FIR the previous field of vision requirements have been amended, It is
now a requirement that the following shall appear in the same field of vision:
1. The name of the food
2. The net quantity (not applicable in the case of sandwiches)
Good Practice would be to continue to include the name of the food, date mark and
storage conditions within the same field of vision, as outlined in the FSA Clear Food
Labelling Guidance -
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5. Names of Products
5.1 The name of the food is a key labelling requirement for all foods and can take the
form of:
(i)
(ii)
(iii)
a name prescribed by law (in practice this is only likely to apply to
sandwiches containing certain seafood, fish and meat products as ingredients);
where there is no name prescribed by law, a customary name may be used
(i.e. names that have become commonly understood by consumers and established
over time such as BLT –bacon, lettuce and tomato); or
where no customary name exists, a name that is sufficiently descriptive to
inform the consumer of the true nature of the food and to enable it to be
distinguished from products with which it could be confused.
5.3 Most sandwiches will fall into category (iii) and require a descriptive name.
Further guidance on the true names of sandwiches and of sandwiches with meat
ingredients is set out in Annexes A and B.
6. Ingredients Lists
6.1 Where a list of ingredients is required, the list must be headed by the word
“Ingredients” and the contents must be listed in descending order by the weight of
each ingredient at the time the sandwich was prepared. Because of the manual
nature of some elements of sandwich making, it is generally accepted that some of
the quoted ingoing quantities will be subject to variation. Sandwich producers,
however, should control ingredients proportions as accurately as is reasonably
practicable given the size and scale of the business and the available technology.
6.2 The name used for an ingredient (excluding brand names) must be the name
that could be used as the name of the food if that ingredient itself was being sold as
a food.
6.3 Compound ingredients are ingredients that are themselves made up of more
than one ingredient e.g. bread, chicken roll, sausages, mayonnaise.
6.4 The full list of ingredients of a compound ingredient needs to be incorporated in
the product ingredient list. This can be done by stating the compound ingredient
name followed by, in brackets, its ingredient list or by omitting the compound
ingredient name and giving one combined ingredients list. Some compound
ingredients can be listed as generic names only (e.g. mixed cheese or flour – see
Schedule 3 of the Food Labelling Regulations 1996 for further details).
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6.5 There are some special exemptions for a few ingredients if they are present in
amounts of less than 2% of the product as sold. These are:
* ingredients for which their composition is prescribed in EC Law (i.e. honey, jam)
* herbs and spices or mixtures of both
* foods which do not require an ingredients list (e.g. cheese, butter)
For these ingredients only the compound food name and any additives or allergens
they contain need to be listed.
6.6
Quantitative Ingredient Declarations (QUID) within ingredients lists must be
made when the following criteria apply:
(i)
The ingredient is included in the name of the food and is usually recognised under
that name by the consumer (e.g. Ham and Cheddar Sandwich) except in relation to
some ingredients such as mustard, mayonnaise etc. or where variation in quantity
would not influence consumer choice; or
(ii) The category of ingredient is included in the name of the food (e.g. Cheese
Salad Sandwich); or
(iii) An ingredient/category of ingredient is given emphasis on the label in words,
pictures or graphics (e.g. made with extra sun dried tomatoes);
6.7 QUID should be the average or typical figures based on the weight of the
ingredient at the stage at which the sandwich is being assembled expressed as a
percentage. The % declaration usually appears in the ingredients list but may
alternatively appear either in or immediately next to the name of the food.
6.8 If ingredients have been irradiated this fact must be declared either on the
product or by means of an accompanying notice. The wording to be used is either
“irradiated” or “treated with ionising radiation”. Similarly, if an ingredient is present
in the form of nano-materials, this fact must be indicated in the list of ingredients.
7. Net Quantity
Although the EU Regulations require that net quantities should be declared on
products, it is accepted by the UK Government that it would be impractical to
provide weights on sandwiches due to the way they are made, provided that
consumers can clearly see from the pack what they are purchasing.
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7. Nutrition Labelling/Nutrition Claims
7.1 It is a requirement of the Food Information Regulations that the following
mandatory nutrition information must be provided on manufactured pre-packed
products as a minimum expressed as per 100g or 100ml. The information may also
be provided as per portion (e.g. half a pizza) and/or per consumption unit:
a) Energy value
b) Fat content
c) Saturates
d) Salt content
e) Carbohydrates
f) Sugars
g) Protein
This information would normally appear within the ingredients list on the back of the
pack in a pre-packed sandwich.
In addition to the mandatory information listed above, legislation allows for
voluntary supplementary nutrition information to be given on the amounts of one or
more of the following:
a) mono-unsaturates
b) polyunsaturates
c) polyols
d) starch
e) fibre
f) any of the vitamins or minerals present in significant amounts as allowed in
current EU legislation, expressed as a percentage of the reference intakes in relation
to per 100 g or per 100 ml.
The mandatory nutrition declaration and the list of supplementary nutrients must
be: in the same field of vision, presented together in a clear format and in the
following order; energy, fat, saturates, carbohydrates, sugars, protein and salt.
The information must be presented in tabular format with the numbers aligned, if
space permits, were space is limited the information must appear in linear format
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The legislation also allows for some of the mandatory nutrition information to be
repeated in the principle field of vision (i.e. “Front of Pack”) in the one of the
following two formats
a) energy value alone; or
b) energy value plus amounts of fat, saturates, sugars and salt
No other information is allowed.
The information provided must meet the following criteria:
•
Energy should be declared on its own or as ‘energy + 4’ (fat, saturates, sugars
and salt) and must always be presented per 100g.
•
The information can be provided per 100g only; per 100g and per portion; or per
portion only (only where the declaration is of ‘energy +4’. Where information is
provided per portion only for the four nutrients (energy + 4), the absolute value for
energy must be provided per 100g/ml in addition to per portion. Energy levels can be
calculated through analysis of the product by the manufacturer; from a calculation
based on the known/actual values of the ingredients; or a calculation from generally
established and accepted data. In the sandwich industry analysis of the finished
product is generally accepted as the best approach because of the complex mix of
ingredients used.
•
Percentage reference intakes (%RIs) can be given on a per 100g/ml and/or per
portion basis. (RIs are the recommended intake of a nutrient for an average person
according to the EC). Where % RI information is provided on a per 100g basis, the
statement ‘Reference intake of an average adult (8400kJ/2000kcal)’ is required to be
displayed on the label.
•
Energy values must be expressed both in kilojoules (kJ) and kilocalories (kcal).
•
Voluntary front of pack nutrition labelling cannot be given on its own - it must be
provided in addition to the full mandatory (“back of pack”) nutrition declaration, which
comprises energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1)
and (3) of the EU FIC).
•
Energy values must not be included in the colour coding but should appear against a
white background.
It is considered good practice to provide this information on the front of the pack,
usually in a ‘traffic light’ format which can be clearly understood by consumers.
The British Sandwich Association supports the Department of Health
recommendation for a red, amber and green colour coding ‘traffic light’ system on
the front of packs.
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•
•
Percentage reference intakes (%RIs) can be given on a per 100g/ml and/or per
portion basis. (RIs are the recommended intake of a nutrient for an average person
according to the EC). Where % RI information is provided on a per 100g basis, the
statement ‘Reference intake of an average adult (8400kJ/2000kcal)’ is required to be
displayed on the label.
Energy values must be expressed both in kilojoules (kJ) and kilocalories (kcal).
•
Voluntary front of pack nutrition labelling cannot be given on its own - it must be
provided in addition to the full mandatory (“back of pack”) nutrition declaration, which
comprises energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1)
and (3) of the EU FIC).
•
Energy values must not be included in the colour coding but should appear against a
white background.
Descriptions such as “High”, “Medium” or “Low” (HML) together with the colours red,
amber or green respectively, can be used to reinforce the nutritional information
It is considered good practice for sandwich makers and retailers to display calorie
information on the front of packs or at point of sale, if at all possible. However, care
must be taken to ensure that the information provided conforms to acceptable
tolerances so as not to mislead consumers.
In sandwich bars calorie information may be provided on shelf-stickers, menu boards or
written menus at point of purchase.
7.2
Wherever nutrition information is stated, the amount of each nutrient must
also be given.
7.3
Where sandwiches are offered for sale to the final consumer or offered for
consumption by mass caterers, or where foods are packed on the sales premises at
the consumers request or for direct sale, allergen information must be provided. In
addition, if a nutritional claim is made about a product, a nutrition labelling
declaration should be made. This should comprise the amount of energy and the
amount of any nutrient about which a claim is made.
All this information must be readily available to consumers, either on a label
attached the product/displayed on shelf-talkers associated with the product or on a
menu board/ information sheet displayed at point-of-sale.
8. Other Claims
8.1 Nutrition and health claims made on foods are tightly regulated to ensure that
consumers are not misled by unsubstantiated, exaggerated or untruthful claims
Regulation EC No. 1924/2006 defines how nutrition and health claims can be made
in labelling, advertising, promotional campaigns and other commercial
communications.
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Full nutrition information must be provided on pack whenever a nutrition or health
claim is made
Claims may be made (and any other promotional information given) provided that
they are true and not misleading.
Care should be taken in relation to the use of marketing terms such as “fresh”, “fresh
today”, “freshly made” etc. Advice on the use of these terms has been provided by
the FSA in a document entitled Criteria for the use of the terms fresh, pure, natural
which can be accessed at:
www.food.gov.uk/foodindustry/guidancenoteslabelregsguidance/freshpurnaturalgui
dancenote
8.2 The FSA guidance states that “expressions such as “freshly cooked”, “freshly
prepared”, “freshly baked”, “freshly picked” should have no other connotation than
the immediacy of the action being described. Where such expressions are used, it is
recommended they are accompanied by an indication (e.g. of the date or time
period – “freshly made this morning”) of when the action being described took
place.
8.3 The terms “fresh today” should only be applied to products sold a maximum of
24 hours from the time of production and “freshly made” should only be applied to
products made and sold within 12 hours of placement for sale.
9. Additive Declarations
9.1
Manufactured pre-packed sandwiches must indicate the presence of
additives by stating the category names followed by the specific additive name or E
number in the ingredients list. Sequestrants are now also included within this
requirement.
9.2
Non pre-packed and pre-packed for direct sale sandwiches (i.e. those which
can have reduced labelling) must indicate the presence of any of the following
categories of additives using the category name: antioxidant, colour, flavouring,
flavour enhancer, preservative and sweetener. This can be done on the label or by
means of a specific notice to this effect displayed in association with the food and/or
at the point of sale. There is no requirement in these circumstances to indicate the
individual additives.
10.
Date Marking
10.1 Fully labelled manufactured pre-packed sandwiches (other than those prepacked for direct sale) are required to carry a date mark, this is a “use by” or “best
before” date.
10.2 A “use by” must be applied to products with fillings that are highly perishable
and from the microbiological point of view likely, after a short period, to constitute a
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danger to the public if not eaten within a short period. Examples would include egg,
meat, fish, pates, soft cheese etc.
10.3 Whilst a ‘best before’ date might be applied to sandwiches with less
perishable fillings (such as jam), it is generally considered to be good practice in the
industry to use the term “use by” for all sandwiches.
10.4 In practice sandwiches will generally require a “use by” date. As a guide, if
any ingredient being used has a “use by” date this will trigger this form of date
marking. It should be noted that sale after the expiry of the ‘use by’ date is deemed
to be ‘unsafe’ under EC 178/2002/ Alteration of a “use by” date is a prosecutable
offence.
The ‘use by’ date of any sandwich must never exceed the ‘use by’ date of any of its
ingredients. Furthermore, if an ingredient supplier states a ‘use by’ date after
ingredient packs have been opened, this is the date that must be observed.
10.5 The date mark must state the date up to and including that which the
product will remain safe to eat in terms of the day and month e.g. “Use by 31
December”. If the product has to be stored in a certain way in order to remain safe
to eat on up to that date then storage conditions must be given (e.g. “keep
refrigerated”) and/or a reference to the maximum storage temperature
10.6 The Food Standards Agency has agreed that there is no objection to the usual
trade practice of using the format “Use by End Of”. This form of words is important
with such a short shelf-life product which might otherwise be misconstrued and
product removed early from shelves, causing excessive and unnecessary food waste.
10.7
Sandwich makers should be able to prove through shelf-life testing
that the ‘Use-by’ date they have stated is appropriate to the date they have given
the product.
11.
Allergen Information
11.1 Under the provisions of EC Regulation 1169/2011 any food containing an
allergenic constituent, with the exemption of some derivatives, must be clearly
marked in the ingredient list in a type that distinguishes it from other ingredients.
This can be done by way of a different font, style or background colour – so long as it
stands out from the rest of the list.
Allergen information may not be repeated elsewhere on the labelling other than in
the ingredients listing. In situations where no ingredient list is required, products
should be clearly marked with the word ‘contains’ and then the name of the
allergen.
Signposting to the allergen information within the ingredients list is permitted (e.g. a
statement that reads “Allergy Advice – see ingredients in bold”)
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The above are not necessary if the name of the sandwich clearly states the
ingredient
or substance concerned (e.g. Cheese and Tomato)
The list of allergens and derivatives is set out in legislation is provided in Annex C.
11.2 In determining what needs to be declared, where prepared ingredients and
compound foods are brought in from suppliers, these are required to be fully
labelled under the legislation.
However, sandwich makers are advised to check
with suppliers that these do not contain any of the prescribed allergens, particularly
where ingredients are coming from outside the EC. It is generally considered good
practice for sandwich businesses to include this requirement as part of their
procurement procedures.
11.3 It is also important to follow good manufacturing practice to avoid cross
contamination with allergenic ingredients. Where the possibility of cross
contamination cannot be avoided additional warnings of the possibility may be
advisable.
11.5 Under the Food Information Regulations allergen information must be
provided wherever sandwiches are provided whether for sale or catering purposes.
It is generally considered good practice for this information to be provided at the
point of choice, either on the pack, on a shelf card/label or on a menu. It is
considered the retailer or caterer’s duty of care to make sure that the information is
clearly visible and available for allergen sufferers.
12.
GM Ingredient Declaration
12.1 Genetically modified foods are those which contain genetically modified
organisms (GMOs) or ingredients derived from GMOs. In all sandwiches the presence
of any such ingredients must be declared to the consumer wherever and however
they are sold. There are prescribed forms of words which must be used.
12.2 For fully labelled manufactured pre-packed sandwiches containing GMOs or
GMO ingredients either the words “contains genetically modified organisms” or
“contains genetically modified X” must appear on the label. In addition where the
sandwich bears an ingredient list the specific ingredients which are GMO or
derivatives must be indicated by the words “genetically modified” or “produced
from genetically modified X”.
These statements must follow the name of the ingredient or be associated (e.g.
linked with it by an asterisk).
12.3 For sandwiches with reduced labelling and sandwiches sold via catering
establishments the appropriate indications i.e. “genetically modified” or “produced
from genetically modified X” will need to be given on an associated notice or label or
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in a menu indication. This information needs to be product specific. A general notice
to ask staff for information is not sufficient.
13.
Other Legal Requirements
13.1 The Food Safety Act 1990; parts of the Trade Descriptions Act 1968; the
Consumer Protection from Unfair Trading Regulations 2008 and EC Regulation
178/2002 prohibit false or misleading labels, descriptions and advertisements. This
includes cover menus, price lists, blackboards and verbal descriptions. These are in
addition to the specific requirements of the Food Labelling Regulations 1996.
It is particularly important to ensure that the images or graphics on labels and packs
do not mislead consumers, particularly in situations where generic labels/packs are
being used. It is the sandwich maker’s responsibility to ensure that packs/labels do
not mislead.
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Annex A: Food Names
1. General Principles
1.1 Bread: From the nature of their preparation and presentation the consumer is
usually visually able to determine when white wheat flour bread has been used and
so it is not generally necessary to specify this type of bread in the name of a
sandwich. However, for other types of bread where the nature of the bread is not
visually clear and can easily be confused, the type of bread and/or the species of
grain used should be included in the full name (e.g. malted brown bread, oatmeal
bread etc.).
[NOTE: “Wholemeal” and “Wheatgerm” have specific meanings as defined in the
Bread and Flour Regulations 1998. FSA have produce guidance on these Regulations
which can be accessed at: www.food.gov.uk/multimedia/pdfs/breadflourguide.pdf
1.2 Compositional Standards: Certain ingredients have legal compositional
standards set out in the Food Labelling Regulations 1996 themselves or in other
legislation such as the Meat Products Regulations 2003. Where there is a
compositional standard there are often reserved descriptions for products meeting a
specified composition. In these circumstances the reserved description/name should
be used as part of the name of the sandwich. Examples of such ingredients include
many meat products, such as corned beef, sausages, and burgers as well as cheeses
such as Cheddar and Gloucester. It should be noted that these names may only be
used for products meeting these compositional standards.
1.3 Protected Names: Some names have a protected status under PDO/PGI/TSG
legislation which can cover origin, method of production, and composition. The
protected name may only be used where a product meets all the conditions of the
protection and must be used as the name. PDO relates to protected designations of
origin; PGI relates to protected geographical indications; and TSF relates to
traditional speciality guaranteed.
1.4 Name of the Food: There is no requirement for the name to reiterate the
ingredients list but the name should accurately describe the product and inform the
consumer about the key value or characterising ingredients. As a general rule the
way in which ingredients are named by ingredient suppliers will act as a guide to
how the sandwich itself should be described.
1.5 Ingredient Names: These should not be changed or enhanced. For example:
* brown bread should not be described as “wholemeal”
* margarine and other fat spreads should not be described as “butter”
* cheese substitutes should not be described as “cheese”
* processed cheese should not be described as “cheese”
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* cured pork shoulder should not be described as “ham”
* chicken roll should not be described as “chicken”
* ham containing added water should not be described as “dry cured”.
2. Processes: Best Practice Guidance
Where an ingredient has been subject to a characterising treatment or process care
needs to be taken to indicate this accurately and in a manner which cannot mislead.
For example:
* steam cooked and flash roasted meats should be described accurately ( e.g. cooked and
roasted beef) and not be simply described as “roast”
* reformed ham must be described must not be described as “traditional”
* ham, chicken or turkey containing added water, hydrolysed proteins and starch etc. must
be described as such (e.g. processed ham, reformed ham) and not simply as ‘ham’,
‘chicken’ or ‘turkey’.
* ingredients treated with smoke solution/smoke flavour should be described as ‘smoke
flavoured’ and not simply as being “smoked” without further qualification.
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Annex B: Summary of FSA Advice to LACORS on the Labelling of Sandwiches
Containing Meat Ingredients – August 2006
For both pre-packed and non pre-packed sandwiches, apart from where sandwiches
are made and sold at catering establishments, a true nature name of the food is
legally required.
It is best practice for the true nature name of the food to be stated next to the fancy
name. This is consistent with the FSA Clear Food Labelling Guidelines.
Where the true nature name of the food is not placed next to the fancy name, or is
not sufficiently prominent to be easily seen, then best practice is for the fancy name
to be more informative to provide sufficient information for consumers to make a
reasoned choice.
It is considered best practice for catering establishments to be similarly explicit on
any menus, tickets or notice boards.
It is also a legal requirement to make the following clear on labels:
•
Contains added water - where water amounts to over 5% of the meat product (e.g.
“ham with added water”)
•
Contains added ingredients of animal origin from a different animal species to that
of the meat (e.g. “chicken with pork protein”, “ham with milk protein”).
•
State when meat is reformed (e.g. “reformed ham”, “chicken roll”, “processed ham”)
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Annex C: Allergens Schedule
1.
Cereals containing gluten (i.e. wheat, rye, barley, oats, spelt, kamut or their
hybridised strains); except for
(a) wheat-based glucose syrups including dextrose#
(b) wheat-based maltodextrins#
(c) glucose syrups based on barley
(d) cereals used for making distillates or ethyl alcohol of agricultural origin for spirit
drinks and other alcoholic beverages.
2.
3.
4.
Crustaceans
Eggs
Fish; except for
(a) fish gelatine used as a carrier for vitamin or carotenoid preparations
(b) fish gelatine or isinglass used as a fining agent in beer and wine
5.
6.
Peanuts
Soybeans, except for:
(a) fully refined soya bean oil and fat#
(b) natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha
tocopherol acetate, and natural D-alpha tocopherol succinate from soya bean
sources
(c) vegetable oils derived from phytosterol esters from soya bean sources
(d) plant sterol ester produced from vegetable oil sterols from soya bean sources.
7.
Milk (including lactose); except for
(a) whey used for making distillates or ethyl alcohol of agricultural origin for spirit
drinks and other alcoholic beverages
(b) lactitol
8.
Nuts, namely almonds (Amygdalus communis L.), hazelnuts (Corylus
avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts
(Carya illinoisis (wangenh) K.Koch), brazil nuts (Bertholletia excelsa), pistachio nuts
(Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia)
9.
Celery
10.
Mustard
11.
Sesame seeds
12.
Sulphar dioxide and sulphites (at concentrations of more than 10 mg/kg or
10mg/litre expressed as SO²)
13.
Lupin
14.
Molluscs
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# The exception only applies to products derived from these products in so far as the process they have
undergone is not likely to increase the level of allergenicity assessed by the European Food Safety
Authority for the relevant product from which they originated.
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Annex D: Model Label/Notice Examples
References:
EC Food Information Regulation No 1169/2011http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:304:0018:0063:EN:
PDF
Food Labelling Regulations 1996, as amended by the Food Labelling (Amendment)
Regulations 1998 and the Food Labelling (Amendment) (No. 2) Regulations 1999
DEFRA – Food Information Regulations 2013 Guidance to compliance https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/82
663/consult-fic-guidance-20121116.pdf
Nutrition Labelling – Step-by-step guide to creating a front of pack nutrition label
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/20
7588/FINAL_VERSION_OF_THE_2013_FOP_GUIDANCE_-_WEB.pdf
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