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#1 permada

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Posted 24 November 2016 - 08:30 AM

Hallo everybody!

I have a doubt about the labeling of spirits.

According to REG. 1169 is not required to indicate the list of ingredients for beverages with alcohol content > 1.2% vol (art. 16 par. 4).

Is this also valid in the event that the image of an ingredient is present in the label? Or according to the article 22 par. 1 b I must indicate the QUID?

Thank you in advance! :helpplease:

Roberta



#2 Ryan M.

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Posted 24 November 2016 - 03:10 PM

Roberta,

 

Is this for Italy?  I'm from the US and familiar with US regulations around alcohol labeling.  In terms of it as a food or nutrition there are no guidelines and nothing is required (In the US).  Many companies use pictures of food, including fruits,on the label.  The one item that needs to be declared is addition of sulfites, or if sulfites are present at 10PPM or higher due to it being a sensitive agent in the US labeling.

 

I would think most other countries follow this...but then again, you'll have to decipher your country's labeling requirements.  What is the "QUID"?



#3 permada

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Posted 24 November 2016 - 03:51 PM

Yes! It's for Italy and Europe.

Here it is in force the Reg. UE 1169/2011:

 

Article 9

List of mandatory particulars

1. In accordance with Articles 10 to 35 and subject to the exceptions contained in this Chapter, indication of the following particulars shall be mandatory:

(a) the name of the food;

(b) the list of ingredients;

...etc.

 

 

Article 16

Omission of certain mandatory particulars

4. Without prejudice to other Union provisions requiring a list of ingredients or a mandatory nutrition declaration, the particulars referred to in points (b) and (l) of Article 9(1) shall not be mandatory for beverages containing more than 1,2 % by volume of alcohol.

 

Article 22

QUID: Quantitative indication of ingredients

1. The indication of the quantity of an ingredient or category of ingredients used in the manufacture or preparation of a food shall be required where the ingredient or category of ingredients concerned:

(a) appears in the name of the food or is usually associated with that name by the consumer;

(b) is emphasised on the labelling in words, pictures or graphics; or

© is essential to characterise a food and to distinguish it from products with which it might be confused because of its name or appearance.



#4 Ryan M.

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Posted 24 November 2016 - 03:54 PM

Got it.  Looks like it doesn't apply and you can use that picture if you wish.  AT least...if I'm interpreting this correctly.  Others can chime in perhaps and confirm or state otherwise.



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#5 permada

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Posted 24 November 2016 - 04:02 PM

This was also my interpretation...I hope it is correct!

Thank you!



#6 Charles.C

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Posted 25 November 2016 - 05:28 AM

Hi Roberta,

 

I assume you mean the spirits are initially only for sale in Italy.

 

I anticipate that the  Regulation "UE" mentioned is only an official Italian language  translation of the Original  EU regulation of the same number. Similarly yr English language quote.

 

The reality might be that yr officiallocal Italian Regulation differs from the EU Regulation. The Reason = "Sovereign Right".

 

I suggest yr question is also directed to an appropriate local legal authority within Italy if certainty is important to you. (Would probably, I suspect, be 'Weights and Measures" in UK).

 

If by "Europe" (Post3) you include non-EC members, the regulations will surely vary.

 

It is not impossible that in this case, all EC members do follow a single (ie the original one) Standard but Labelling Regulations IMEX (non-EC) can be a highly variable feature with respect to local interpetation/implementation.


Kind Regards,

 

Charles.C


#7 permada

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Posted 25 November 2016 - 08:18 AM

Hallo Charles, thank you for your answer.
The Regulation which I quoted is the English version... and the meaning does not seem different from the Italian version.
The problem is that I have already asked the opinion of two different legal authority and ... they gave me two different interpretations!
I was curious to know how the regulation was being applied in other countries.
Thanks again.
Roberta


#8 Charles.C

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Posted 25 November 2016 - 09:19 AM

 

Hallo Charles, thank you for your answer.
The Regulation which I quoted is the English version... and the meaning does not seem different from the Italian version.
The problem is that I have already asked the opinion of two different legal authority and ... they gave me two different interpretations!
I was curious to know how the regulation was being applied in other countries.
Thanks again.
Roberta

 

 

Hi Roberta,

 

Not sure if you are talking specifically about Italy or EC members in general ?

 

I am totally no expert on European Food law but, afaik, there is a hierarchy of EC legislation regarding food safety, weight, volumes etc. Labelling is just one topic within the overall framework.

 

IIRC, some top categories (one?)  are obliged to be implemented by all Members verbatim  (presumably assuming an absolute interpretation exists).

Others are acknowledged to be capable of local individual modification as desired by Members although how much variation is "permitted" I have no idea.

The details of this "Power" tree is from memory available on the Europa website or somewhere similar.

 

In many cases,  "interpretation" is often the Name of the Game. A famous example is the requirements of all EC members to implement the EC food safety legislation as involving HACCP. This was ingeniously re-interpreted as a necessity to implement  HACCP "Principles" thereby avoiding tricky haccp topics such as Risk Assessment/Identification of CCPs while still using the results of such studies to generate appropriate monitoring forms for routine use by relatively non-technical personnel.

 

Again, afaik, a Country's Sovereign Right is, i believe, considered to overlay (supercede?) agreements such as above although as recently illustrated, actions based on such may involve "consequences".

 

I think many manufacturers rely on their desgnated importing agents to resolve export labelling issues. Theoretically one's own Country should be easier but perhaps, as per yr comment, not always.


Kind Regards,

 

Charles.C





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