This French opinion makes recommendations on the labeling of the origin of the primary ingredient required when the manufacturer voluntarily includes that of the food product.
The National Consumption Council (NCC) is a French joint consultative body created by regulation placed with the Minister in charge of Consumption. Its mission is to allow debate and consultation, for everything related to consumer issues, between public authorities, representatives of consumer defense associations and professional organizations as well as companies providing public service missions. . It also enables the negotiation of agreements between professional organizations or public and private service providers and consumer defense associations. On February 28, 2020, a working group was set up to exchange information for consumers on the origin of foodstuffs and their ingredients and to make recommendations to strengthen the transparency and clarity of information on the consumer.
This work falls within the framework of the implementation of the implementing regulation EU 2018/775 on the methods of application of article 26 of the European Regulation on consumer information (INCO) EU 1169/2011. Paragraph 3 of article 6 of the INCO regulation requires the indication of the origin of the primary ingredient (s) of a foodstuff when the operator indicates, on a voluntary basis, the origin of the foodstuff comprising the primary ingredient (s) and that these have a different origin from that of the foodstuff. The recommendations published by this working group and submitted to the Minister responsible for consumer affairs on December 6, 2021 are therefore not binding. They aim to facilitate a shared application and applied as widely as possible of the rules for indicating the origin of the primary ingredient (s) when the manufacturer voluntarily lists the origin of the foodstuff. comprising this (s) primary ingredient (s). Indeed, the INCO Regulation defines “primary ingredient”: the ingredient (s) of a foodstuff which constitute more than 50% of it or which are usually associated with the name of this foodstuff by consumers and for which, in in most cases a quantitative indication is required. The CNC working group noted that this definition leaves room for interpretation in the concept of ingredients usually associated with the name of this food by consumers. He considered the recommendation to take into account as primary ingredients, within the limit of three ingredients:
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The ingredient present at more than 50%,
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The possible characteristic ingredient(s), common to a generic category of foodstuffs (for example milk in yoghurts),
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The ingredient(s) mentioned in the sales description taken in the order in which they appear in the list of ingredients, with the exception of ingredients used in low doses for flavoring purposes.
This recommendation did not obtain support of all the representatives of the college of professionals with regard to the recognition of one or more primary ingredients among the ingredients mentioned in the name of the foodstuff;
In this opinion, it is mainly recommended that manufacturers:
- To give priority to information on the country of origin of the main ingredients in the composition of a food (known as “primary ingredients”) rather than more general information such as “EU” or “non-EU”,
- When the main ingredients are not available ‘origin fr French, to match the representative symbols of France with a statement such as “made / elaborated / cooked in France”in order to avoid any ambiguity of the consumer,
- For processed ingredients, to favor the indication of the origin of agricultural raw material (the DGCCRF will be able to rely on this recommendation to establish its doctrine on the subject that it will implement for its controls).
In addition, the working group recommends sharing this opinion with the European Commission and the other Member States as part of the search for a harmonized application of the rules for labeling the origin of of the prymary ingredient(s).
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Labeling of the origin of foodstuffs and their ingredients: Opinion of the National Consumer Council (NCC)
This French opinion makes recommendations on the labeling of the origin of the primary ingredient required when the manufacturer voluntarily includes that of the food product.
This work falls within the framework of the implementation of the implementing regulation EU 2018/775 on the methods of application of article 26 of the European Regulation on consumer information (INCO) EU 1169/2011. Paragraph 3 of article 6 of the INCO regulation requires the indication of the origin of the primary ingredient (s) of a foodstuff when the operator indicates, on a voluntary basis, the origin of the foodstuff comprising the primary ingredient (s) and that these have a different origin from that of the foodstuff. The recommendations published by this working group and submitted to the Minister responsible for consumer affairs on December 6, 2021 are therefore not binding. They aim to facilitate a shared application and applied as widely as possible of the rules for indicating the origin of the primary ingredient (s) when the manufacturer voluntarily lists the origin of the foodstuff. comprising this (s) primary ingredient (s). Indeed, the INCO Regulation defines “primary ingredient”: the ingredient (s) of a foodstuff which constitute more than 50% of it or which are usually associated with the name of this foodstuff by consumers and for which, in in most cases a quantitative indication is required. The CNC working group noted that this definition leaves room for interpretation in the concept of ingredients usually associated with the name of this food by consumers. He considered the recommendation to take into account as primary ingredients, within the limit of three ingredients:
This recommendation did not obtain support of all the representatives of the college of professionals with regard to the recognition of one or more primary ingredients among the ingredients mentioned in the name of the foodstuff;
In this opinion, it is mainly recommended that manufacturers:
In addition, the working group recommends sharing this opinion with the European Commission and the other Member States as part of the search for a harmonized application of the rules for labeling the origin of of the prymary ingredient(s).
To find out more about this notice.
Orchidali can help you achieve regulatory compliance.
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