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C of Origin vs C of Manufacture

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Posted 03 August 2016 - 12:26 PM



I am wondering if you can help with the difference between the country of origin and the country of manufacture? I read that country of origin is the place of last substantial change but is that not the same as manufacturing? manufacture of the product would be a substantial change wouldn't it? I am therefore jumping to the conclusion that the county of manufacture is the same as the country of origin. which I have been old isn't always the case and was given the below example:


someone gave me an example of sugar.....


The beet comes from Benelux - C of O

processed into sugar in UK - C of M


if the above example is the case then that goes against the information that says the country of origin is the place of last substantial change because the processing of the sugar would be the last place of substantial change and therefore the c of o and the c of m would be UK?


any help would be appreciated?






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Posted 04 August 2016 - 06:03 AM

Hi Whitney,


An interesting question and a 'grey area'


You might find this useful: Consumer Guide to Country of Origin Information on Food Labels:


What does country of origin mean?
Country of origin is not defined in the law covering food labelling.
However, when dealing with food from one country which is processed in another, the approach taken for food labelling is based on ‘the place  of last substantial change’.  Broadly, this means that the last country in  which a food is substantially changed is the country of origin.
Describing where food comes from The words “country of origin”, “origin”, “place of origin” or “place of provenance” are often used  when describing where food products come from.

What does ‘last substantial change’ mean?
Pork meat cured into bacon or ham, or meat made into sausages or pies would be considered to be a substantial change.  
The simple slicing, cutting, mincing and/or packing of meat would not be called a substantial change.  Under this rule, if bacon is cured in Scotland from Danish Pork it can be called Scottish bacon.
However, in line with the Food Standards Agency’s best practice advice, more and more producers now go beyond the legal minimum and also give the origin of imported foods.

Kind regards,





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Posted 04 August 2016 - 07:00 AM

Hi Whitney,


I anticipate that there will be substantial discussion over these nuances in the legal traceability Proceedings/Consequences of HorseGate. (FSA/Hanzard perhaps).


Once bitten .........

Kind Regards,



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