This is not my product/customer area however I can make some comments which are free to be corrected if wrong just so as to start the ball rolling. Anyone is welcome to dispute/correct/clarify the following but please provide justification.
IMEX of labeling issues, there are 2 frequent scenarios –
(a) a problem concerning an “area-wide” regulation such as EC
(b) no problem of type (a) but problem concerning an additional local regulation of the importing country.
I assume the OP refers to type (a), notably the EC COOL (country of origin labeling) regs for poultry meat which came in to play 01april 2015 ? If otherwise perhaps Cristina would inform.
The latest documents I can see on the IT regarding such are this one on 21may 2015 –
and this Q/A faq of (presumably) post 01April –
Q-A new rules for labelling, 01april 2015.pdf 275.65KB
Based on the above, the COOL requirements as per EC regs seem to depend on either –
(i) whether the product is classified as “Processed” within the context of the 01 april 2015 regs or –
(ii) Possibly whether the product comes within the pre-existing requirements for “poultry” pior to 01april 2015. The latter situation seems to have been as -
MANDATORY AND VOLUNTARY LABELLING
Currently mandatory rules on origin labelling exist for several sectors, such as
honey 3 , fruit and vegetables 4 , fish 5 (not fish products such as prepared or preserved
fish), beef and beef products 6 , olive oil 7 , wine 8 , eggs 9 , and imported poultry 10 .
The FIC Regulation introduced mandatory origin labelling for fresh, chilled or frozen
meats of swine, sheep, goat and poultry, whose modalities have been fixed by
Commission Implementing Regulation (EU) No 1337/2013 11 .
Apart from these rules on mandatory labelling of origin FBOs are free to label at
their own initiative the country or region of origin, provided they fulfil the applicable
provisions of the FIC Regulation.
EC labelling_legislation, 20-5-2015.pdf 88.9KB
(note FIC = Regulation (EU) No. 1169/2011.)
reg. EU No. 1169-2011.pdf 1.12MB
The contents of the (lengthy) FIC document appear to me to lack guidelines for deciding Y/N as to “where failure to indicate this might mislead the consumer as to the true country of origin or place of provenance of the Food…….”. (article 26,2a)
I assume the product in the OP is classified as “Processed” in which case it seems to avoid any mandatory (new) COOL but I'm unclear whether still potentially included within the (semi-mandatory ??) 26,2a para. referred above ? . (unless this para. was auto-interpreted as something to be quietly "skipped over"?)
PS - @Cristina - pls confirm if "Processed". are the "nuggets" frozen raw breaded or just chunks of frozen raw chicken meat ? Is it "pre-packed"