Food labels are the text, graphics, symbols, and all explanatory materials displayed on food packaging, providing consumers with direct and effective information about the food. For exported food, the completeness, authenticity, and readability of the labels are key regulatory focuses during border inspections or market spot checks in the target countries (regions). The results of these information checks will directly affect whether the products of export enterprises can be exported smoothly or continue to circulate in the market. Therefore, designing a label that complies with the regulatory requirements of the target country (region) and avoiding negative consequences due to non-compliant labels is crucial for food export companies. For the reasons mentioned above, we will guide you through an analysis of the risks to avoid when ensuring label compliance for exported foods.
1. Essential Elements of a Label
Except for exemptions (some countries and regions will exempt the labelling of nutrition label, such as the European Union exempts single ingredient vinegar, spices, food sold through B2B channels, etc.) do not need to label the nutrition information, exported food labels include two parts: the main label (food identification items) and nutritional label (nutritional information and claims). Therefore, when designing export labels, sufficient space must be reserved to accommodate the above information according to the requirements of the target country (region).
2. Label Items
Exported food must have its labeling items, which are the main information displayed to consumers, and none of the relevant items can be missing. After years of research and analysis on export countries (regions), the main labeling and nutritional information that must be indicated in mainstream countries (regions) primarily cover the following content:
a. Main Label
Mainly includes (6 major items): Food name, net content, ingredient list (except for exempted labeling cases), date marking (production date, shelf life), manufacturer information (producer, importer), and origin of product;
Due to differences in regulations and requirements of countries and regions, in addition to the above information, mandatory labeling items also include: batch number (EU, Australia, New Zealand), product category (South Korea), packaging material information (South Korea), food serial number (Thailand), etc. An example of the food serial number labeling in Thailand is shown in Figure 1.
Note: ①The code number of the province where the food factory or importer is located.
②The nature of the food factory or importer (Note: 1 - Approved by the Food and Drug Administration, 2 - Approved by the provincial Food and Drug Bureau, 3 - Approved for import by the Food and Drug Administration, 4 - Approved for import by the provincial Food and Drug Bureau)
③The code number of the food factory or importer.
④The Buddhist year in Thailand when the approval and registration were granted.
⑤The code number of the approving department and its approval method for the product.
⑥The product category code number.
Other labeling items (Conditional requirements)
(1) Allergen information: there are generally two ways to indicate it: 1 Highlighting in the ingredient list; 2 Following the ingredient list with the label "Contains + allergen",which is a common method of indication.
(2) Storage Conditions and Usage Instructions: If a product has special storage conditions such as temperature and humidity requirements, or if there is a lack of usage instructions that would prevent consumers from using the product properly, then it is mandatory to label the product's storage conditions and usage instructions, such as: Refrigerated storage of spices after opening.
(3) Genetically Modified (GM) Ingredient Information: The product must use GM varieties approved by the target country (region); if the product contains GM ingredients that are not adventitiously present and the content in the final product reaches a certain threshold, then the product must be labeled with GM information (except for exempt cases).
b. Nutritional label
The key points to pay attention to in the nutritional information table on food labels mainly include: design format, table header requirements, mandatory nutrients to be labeled, units of measurement, and NRV% (Nutrient Reference Values), etc. Food safety authorities in various countries (regions) have different focuses on the labeling requirements for nutritional information tables based on national consumption habits and the intensity of risk control.
Format: If the label area is sufficient, a tabular format is recommended; if not, a linear format is allowed to be used.
Table Header : The labeling forms commonly used by mainstream countries include: NUTRITION INFORMAITON, NUTRITION DECLARATION, NUTRITION FACTS, SUPPLEMENT FACTS, etc.;
Labeling Items: The requirements for labeling items vary across different countries (regions), but essentially, they all demand the indication of energy value, fat, carbohydrates, sugar, and protein content.
3. Risk Point Analysis
Combining years of label audit experience and foreign official sampling and notification information, Foodmate has organized the following labeling risk points for reference:
Labeling Items: They must be complete and not missing any items; special attention should be paid to the information in the ingredient list, such as how many levels the compound ingredients need to be expanded to, whether the additives need to be identified by function, whether the amount of related ingredients needs to be indicated, whether there is a basis for the use of spices in the target country (region); whether animal-derived ingredients used in the ingredients involve market access qualifications in the country (region). In addition, the requirements for the labeling position, labeling language, and character height should also be thought over.
Format: For the Nutrition information table, if the exporting country (region) has provided a labelling template (e.g. order of labelling items, labelling units, etc.), then use the official template form for labelling design, at present, the United States, the European Union, Australia and New Zealand, South Korea, Singapore, Malaysia have formulated a template style in labelling regulations or guidelines.
Calculation: It is crucial to focus on whether the nutrient testing methods (national standards, ISO, AOAC, etc.) are equivalent, the rounding intervals for declared values, the conversion coefficients for energy values, the method of energy value indication (calories/kilojoules or only calories or kilojoules?), the recommended dietary intake for residents, and the requirements for rounded values.
If you need assistance with label review during food export, you may consider seeking technical support from professional third-party organizations such as Foodmate. Foodmate has a team composed of more than 20 multilingual and experienced professionals who are proficient in various languages, including English, Spanish, Italian, French, German, Arabic, Russian, Japanese, Korean, Vietnamese, Thai, and Indonesian. Moreover, Foodmate has established cooperative relationships with numerous large food companies both domestically and internationally. In terms of label review, they can not only provide standardized services but also offer customized review services according to customers' needs.