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Labeling questions about the law etc.

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Posted 06 November 2014 - 07:09 PM

I am fairly new to my job role and with even more changes in that i have been presented with a new problem.


as im sure you are all aware there is new regs coming in to effect from December to which i have now been give responsibility of ensuring our compliance ^^ not as easy as you think it might be because where as most company have had some 2 or 3 years to prepare, an npd department containing packaging and labeling specialists, my small company i work for felt leaving it until now to address the issue!!


Anyway i have some questions id like to ask and rather than spend my non working hours doing that as i have no spare time at work currently to address this with the time i need to i thought best to get on this forum to get some much needed advice.


Please note our products do not go to main stream supermarkets like tesco or marks and spark its generally aimed at restaurants and the like.



Questions 1) as a quality auditor in production i was always lead to believe that it was against the law to: place labels on labels  or where a printed label is part of the film, place a different label over that for example:


We have a fresh goods product that has a printed film with picture nutritional info and bar code and what they have been doing is for another customer is place a sticky labeled with different bar code over the top of that.


now i think this is illegal and if im right i need to call a meeting and shove some document or something in their faces to make them listen perhaps reference to a particular requirement or regulation clause would be great if at all possible.



Question 2) Our fresh product is made with a USB date of about P+10 days the product can be frozen for 6 months, defrosted and then used within 3 days of defrost. The production Film contains printed USB date and information about defrost however over the USB date Print where a date would be printed on they place  a BBD sticker of +10 regardless if it is sent out as fresh or frozen (some customers ask we freeze it before delivery)

So...am i right in thinking if the film says USB this is what we should use based on the product spec, in this case its ok to use a sticker for fresh or frozen in the space provided on film provided it says USB not BBD? and that if a customer asks us to freeze it for them on day of production then the effective USB date would be 6 months + 3 days and not from production +10 days + 6 months + 3 days. ( the issue being a difference of freezing on day 1 to freezing on day 10.......


Question 3) As we no longer have an NPD department and im reduced to performing 5 different job roles now are there any accredited/ certified businesses that for example specialist in taking information from us, either in form of a printed film or information about product. That this business can proof read / vet our products packaging/ labeling meets legal requirements? U heard SGS do this service or something similar but would not be able to perform it for us due to fact they certify us against BRC.


Again this is extremely important its out of my area of expertise and i need to resolve it asap due to fact there isn't the skills, experience, or resources in place currently to address it..



(before you all say BRC section 1 -- i have been shouting it and food safety law (HACCP) for 3 months and have even threatened to resign over the managements decisions on the plus we got a new MD and hes on the ball so i expect some changes for the better soon)



Thank you for any help in advance with the above i appreciate it...



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Posted 11 November 2014 - 12:32 AM

Being in the US, don't know your regulations, hopefully, someone else will be able to help you. 

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Posted 11 November 2014 - 08:33 AM

  • A barcode s not a legality, so if they want to cover the barcode, then I don't see any problem with this.
  • Freezing / Defrosting - the new FIR regs deals with this nicely. have a look at that, I don't know what your product is and if it falls within the FIR criteria.
  • We are a co-packer and I always check my customers labels. If their wrong I email them to tell them so (always have things in writing!) and i'll happily send to either my or their TSO for comment. If you can utelise someone else, then do so. Your TSO should help you.

Caz x

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Posted 12 November 2014 - 03:49 AM

Hi Caz,


Thks for the comments. I seem to recall the (UK) +10 days issue is  notoriously well documented for certain products.


Is it likely IYO (assuming you have any related experience) that queries such as the OP poses will be responded to by a TSO with  comments like "You need to get a lawyer / get some Insurance" ?


I ask since previous threads here have well-demonstrated IMO that UK Food Law is an eminently undefined area with respect to the manufacturer's specific responsibilities, and particularly  over labelling issues. I equally felt somewhat sympathetic towards EHOs / TSOs who presumably are the front-line for such queries.


Personally, from mostly non-UK experiences, my answers to OP queries are - 


(1) Any tampering with the original label can be grounds for rejection / recall. But sometimes locally permitted.

(2) Unanswerable as per yr data given. Often a L.mono related topic hence food safety. Hence then having reject / recall possibilities.

(3) Probably either No or item will be referred to a "Competent Authority" at your enormous expense.


Rgds / Charles


PS -

@ DavidAR - you may find this thread (and the cross-link) of interest -


Kind Regards,




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Posted 12 November 2014 - 08:58 PM

Your TSO should help you, FOC

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