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Packaging incorrectly cut not showing complete ingredient list


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#1 Paula da Silva

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Posted 05 November 2018 - 04:34 PM

Hi everyone,

 

I was hoping you can give me advice on this issue we have had with the packaging of our products!- never happened before- not sure on how to proceed!

 

The packaging of the products affected is a printed foil wrap with the labelling info on it.

 

Packaging was incorrectly cut and now we have some products (it didn't affect the whole production run) that are not showing the whole ingredient list and the nutritional values you are able to see are just per 100g, you can't see the nutritional values per portion! :S

 

The allergy advice is visible and all the allergens from the ingredient list are visible as well.

 

Having in mind the above, would we have to issue a product withdrawal or recall? or any of these would be necessary? what would you do in this case?

 

:helpplease:  :helpplease:  :helpplease:

thank you in advance!!

Paula



#2 Scampi

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Posted 05 November 2018 - 04:55 PM

Withdrawal........better safe than sorry

 

If i'm not mistaken the ingredients is a mandatory item on the label so this issue has deemed your product "not labeled for individual sale"

You didn't mention front of pack.......is all the legally required information still present

 

Would you buy a product that looked like this one when you're grocery shopping?


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#3 MsMars

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Posted 05 November 2018 - 04:58 PM

Not sure of UK specifics or language on labeling, but in the US (and Canada, I'm assuming from Scampi's input), the ingredient panel is required. So, if you're shipping over here, then yes a withdrawal may be in order. Do you happen to have outer bulk packaging printed with the same information?



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#4 pHruit

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Posted 05 November 2018 - 05:02 PM

What Scampi said.

Nutritional per portion is not mandatory, but full ingredients list definitely is. If it's not compliant with e.g. Article 9 of reg 1169/2011 then I don't see how you can offer it for sale.

If it's already out in the trade and you've only just found it then try discussing with your local Trading Standards perhaps, as they used to be reasonably pragmatic and may decide a full recall isn't required.

Having said that, consider also from the consumer perspective - how do they know they can see all of the allergen info if part of the ingredient list is missing?



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#5 Paula da Silva

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Posted 05 November 2018 - 05:37 PM

Hi thank you all for your advice!

 

is literally one letter (the first letter of the sentence) what you can't see on the label.

 

I don't see as a big issue? but again, like you said, how would customers know this?

 

do you still suggest to raise this with Trading Strandards?

 

thanks so much for your help!



#6 Scampi

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Posted 05 November 2018 - 07:40 PM

I would raise the issue..........it's far better for you to be transparent and ask questions then to say.........oops my bad

 

Worst case scenario, you've probably got to label the affected packages by hand to correct the error. Let Trading standards decide.........then if they decide it's a none issue, you have documentation on hand stating as much and you've performed your due diligence!


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#7 pHruit

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Posted 06 November 2018 - 08:17 AM

Agree with Scampi (again).

The problem does sound very minor in real terms, and IME Trading Standards are pretty flexible and accommodating if you're up front and take the time to discuss with them. If nothing else they've got nowhere near enough time/resource these days to go looking for unnecessary fights. Their response is likely to be very different if you just go for it anyway and they find out when someone complains to a TSO in another region and it gets flagged back to them that way. Clearing it with them first also means that if they get any queries like this about people kicking up a fuss (there's always one ;) ) then they can immediately advise they've already ok'd it.



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#8 Gerard H.

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Posted 06 November 2018 - 08:58 AM

Dear Paula,

 

In the BRC standard (and IFS), the labelling activities fall under the Fundamental clauses. Please, consider that, when you decide what to do with the products. All to avoid, that you have trouble with customers or with your certification in the (near) future.

 

Kind regards,

 

Gerard Heerkens



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