As more food producers move to selling their foods online, also called “Distance Selling” whether using their own e-commerce site, via facebook, taking orders via SMS, phone, interactive TV, or supplying via on-line shops such as Amazon and others, its essential that labelling compliance is not overlooked. In summary, the same rules apply to foods sold online as they would if your customer walked into a shop to buy it in person.
For foods that are normally pre-packed, i.e, in packaging, the following rules apply:
(a) mandatory food information is still required (I covered in a previous post about food labels back in April), except for the date of minimum durability or use by date, and it must be available before the purchase is concluded and must appear either on the packaging (or it can be provided somewhere else, but you cannot charge your customers any extra for sending them elsewhere to get the information!).
(b) all mandatory particulars, including the use by or best before date, must be on the foods when they are delivered to the customer, i.e, on their doorstep!
For non pre-packed foods, the lawrequires the food business operator to provide information of any allergen in that food. (Again, if there is more information available to your Customer elsewhere, you can direct them there, but cannot charge them any extra for doing so).
In my opinion, the best and easiest thing to do is ensure you treat your online sales the same way as you would for sales through any retail outlet.
I am really encouraging small food and drink producers to set up their own e-commerce site. In Ireland, there is a 90% grant available at the moment for doing this, its called a On-Line Trading Voucher. Check it out today! And when you’ve got it set up, let me know and I’ll add you to the Directory on oonagheats.com !
Foods that are wrapped (or pre-packed) have lots of information for consumers printed on the packaging, including the list of ingredients, the nutritional information storage instructions, the weight or volume, storage instructions, cooking instructions and more. If the food isn’t pre-wrapped for sale, then the only information that’s required are the Allergens.
There might also be marketing information, pictures, offers, games, competitions….a lot to take in! In terms of knowing what is in the food you are eating, the two important pieces are the Ingredients List and the Nutritional Analysis.
So, what has to be on the label? According to EU law, the information that is mandatory and must appear on the label of a prepacked food is:
(a) the name of the food
(b) the list of ingredients (c) allergens or processing aids used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form
(d) the quantity of certain ingredients (listed as a %)
(e) the net quantity (weight or volume)
(f) either the Best Before or Use By date (g) any special storage conditions and/or conditions of use (temperature, time)
(h) the name or business name and address of the food business (i) the country of origin or place of provenance, if applicable
(j) instructions for use, if required
(k) with respect to beverages containing more than 1.2 % by volume of alcohol, the actual alcoholic strength by volume
(l) Nutrition Declaration
The Ingredients List tells you what was used to make the food, and these are listed in order by weight from largest to smallest. In other words, the first ingredient listed is the largest amount, right down to the last ingredient which is the smallest amount.
The whole E number issue can be confusing, and sometimes people may think that E numbers are all bad. In fact, many naturally occurring foods have their own E number like seaweed (carrageenan or agar), silver and gold even! Many other e-numbers are given to the substances that are extracted from natural products like those from vegetable oils used in bread.
The Allergens (if any) are highlighted in the list of ingredients, usually in bold or italics or underlined.
Nutritional Labelling is required on all foods by law unless you’re a very small producer and only selling small quantities locally (i.e., within a 100km radius).
The nutrition panel has to show:
(a) The energy value (in KJ or kcal), and
(b) The quantities of fat (including saturates), carbohydrate (including sugars), protein and salt – in that order!
The food producer can also choose to give the amount of one or more of the following if they wish to: (a) Monounsaturates, (b) Polyunsaturates, (c) Polyols,
(d) Starch,(e) Fibre, (f) Any of the vitamins or minerals.
The Nutrients must be declared per 100g or per 100ml:
Mandatory Information / 100g or ml
Supplementary Information (if desired)
Energy (kJ / kcal)
Fat of which Saturates
of which Monounsaturates of which Polyunsaturates
Carbohydrate of which Sugars
of which polyols of which starch
Vitamins & Minerals (% RI)
All of these must be listed on the label
The producer MAY include all of these if they should wish to (either all or none)
Some food labels also include an additional column to show the Nutrition information per portion. For example, per bag, per slice, per sandwich. This is useful for the consumer who may find it tricky to work it out for themselves, but it’s not a legal requirement. Front of pack labelling is also voluntary – the pack can show the Energy on its own or the Energy, fat, saturates, sugar and salt (all of these).
The terms “Best Before” and “Use By” dates often cause confusion. It’s really important to note that these terms are not interchangeable! “Best Before” generally applies to foods that have a long shelf life and “Use By” applies to perishable foods or foods that, if you eat them after that date, might cause food poisoning. Never take chances with “Use By” dates! Safefood has a great phrase – Best Before is a guideline, Use By is a deadline!