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Question about the Responsibilities 1169/2011

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Posted 01 April 2019 - 05:45 PM

Hi everyone,

I have a question about proper product labeling :)

In our factory we produce liqueurs and syrups ... but we also buy finished products from the EU - we put the seal of the Italian State (only for spirits) - and we sell everything.

I have a question about Article 8 of 1169/2011:

Article 8


he food business operator responsible for the food information shall be the operator under whose name or business name the food is marketed or, if that operator is not established in the Union, the importer into the Union market.

Does the article refer to the manufacturer of the finished products? Should we include our name (or company name) and address on the label?

Many thanks


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Posted 02 April 2019 - 08:23 AM

My understanding is that the purpose of Article 8 is to allow consumers / regulators to identify and contact the party who is responsible for the product.

For example, if you go to your local supermarket and buy an own-brand liqueur it will almost certainly have the name/address of the supermarket's head office on it, rather than the details for the co-packer/co-manufacturer by whom it was almost certainly made and packed.

If you are the responsible party / brand owner then yes, I'd put your own details on the label.


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Posted 19 April 2019 - 01:58 PM



as Art 8 mentions EU-law makes the difference between in and out the EC. Within the EU law each distribution level is responsible for certain things.

The declaration on pack for distribution within the EU is in the responsibilitity of the brand owner/FBO mentioned on pack. Your job is the dirtributor-job in Italy.

a) if no declaration in Italian is on pack -> you can not distribute the material in Italy

b) if the put the italian declaration on pack (e.g. by stickering) it is your responsibility (I guess the name of your company is mentioned as "distributed in Italy by..."

c) if the italian declaration is already on pack you have to cross check that the declaration is correct

d) if the italina declaration is already on pack and the product is distributed by the manufacturer/FBO itself, the repsonsibility is with him.

The trade has the responsibility to cross check too, but to a lower extent and only for things which are obviously wrong (as long as the trade is not mentioned as FBO e.g. private label)




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