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Claims on flapjack packaging where customer provides artwork


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#1 StevieP

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Posted 12 August 2019 - 08:45 AM

Good Morning Everyone,

Claims on packaging aren’t my strongest area of expertise, but I have been given some new Primary Packaging that is owned by my Customer (they do the artwork designs etc). The Product is a Flapjack, and they have put ‘source of fiber’ on the front of pack.

For me, this is now a claim, and as such, my due diligence means I would have to carry out traditional analyticals with my lab????? Would I also need to bench mark it against something? Does anyone know if there is a standard that states the level of fiber in a flapjack?

 

Also, they put pictures of fruit on the packaging. But I thought there had to be a minimum fruit content in the ingredient dec for them to do that. There is guidance in place for this isn’t there? Welcome your comments.

 

Thanks,



#2 pHruit

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Posted 12 August 2019 - 09:28 AM

The annex to Regulation (EC) 1924/2006 is the benchmark of which you're probably thinking:

 

SOURCE OF FIBRE

A claim that a food is a source of fibre, and any claim likely to have the same meaning for the consumer, may only be made where the product contains at least 3g of fibre per 100g or at least 1.5g of fibre per 100kcal.

 

If the exact wording they are using on FoP is "source of fibre" then this is the one the recipe would need to meet, but if the wording is different then you may also need to be aware of the additional "high fibre" claim option and check that either the product complies, or that the wording doesn't inadvertently imply this one over the lesser "source of fibre" version above.

 

HIGH FIBRE

A claim that a food is high in fibre, and any claim likely to have the same meaning for the consumer, may only be made where the product contains at least 6g of fibre per 100g or at least 3g of fibre per 100kcal.

There are three entries for Flapjack in the current McCance & Widdowson's dataset, available for free here: https://www.gov.uk/g...d-dataset-cofid

Nonetheless as there is a specific nutritional claim involved I certainly wouldn't be comfortable with relying solely on reference data based on flapjacks of unknown composition, so IMO yes this really should be analytically confirmed for your customer's particular formulation.

 

Pictorial representation can be a minefield!
I've attached a guide from the FDF that is potentially useful, but this was developed in association with the UK Flavour Association and therefore does lean very heavily towards interpretation in cases of flavourings rather than ingredients.

Nonetheless the same principle as per Article 7(1)(d) of Regulations (EU) 1169/2011 applies:

Food information shall not be misleading, particularly... by suggesting, by means of the appearance, the description or pictorial representations, the presence of a particular food or an ingredient, while in reality a component naturally present or an ingredient normally used in that food has been substituted with a different component or a different ingredient.

 

Is there actually fruit in the product and does the product also taste of the pictured fruit(s), and/or reasonably characterise the nature of the product?

If the answer is yes then you're probably fine to use the pictures.
Nonetheless if unsure then ask your local TSO - they'll review labels for a tiny fee (compared to the normal research associations) so you have a bit more certainty if needed.

I'd also recommend having a wonder through the relevant aisles of your local supermarkets - see what the big retailers / large brands are doing with these types of product, as they've usually got a significant amount of regulatory/legal resource behind them ;)

 

As a tangential consideration - Are the pictured ingredient QUID'ed in the ingredient dec? They should be if there is a picture of them on the label, in accordance with Article 22(1)( c) of 1169/2011.

 

Attached Files



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#3 StevieP

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Posted 12 August 2019 - 12:48 PM

Thanks, pHruit, there is a wealth of information here. I'm going to have to digest this information, and then maybe get back to you.

 

Thanks in advance!



#4 pHruit

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Posted 13 August 2019 - 08:40 AM

No problem, StevieP - nice that other people can get some benefit from the many hours I've had to spend reading this stuff to find the references required to illustrate that the daft ideas of various clients, marketing people etc really aren't acceptable...



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#5 StevieP

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Posted 16 August 2019 - 07:06 AM

It is a great help and has caused some interesting conversations with the sales managers!!



#6 pHruit

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Posted 16 August 2019 - 08:39 AM

Ah yes, this is a longstanding feud that archaeologists will tell you goes back many thousands of years to the time that sales managers were just starting to evolve.

It's said that in those days claims regulations roamed the African plains in large hunting groups, and preyed upon sales managers. Eventually the sales managers started to band together, and formed groups known as a "sales conference". Between them they started constructing defences made of primitive PowerPoint presentations, and fashioned rudimentary weapons from infographics. As their techniques became more advanced, they used their technology to mercilessly hunt the claims regulations, almost to the point of extinction.
For many centuries the lack of a natural predator allowed the sales managers to get somewhat out of control, but towards the end of the 20th century conservationists at the FDA and EFSA started to successfully bring claims regulations back from the brink of extinction, and their numbers are now large enough for a viable wild population to exist again.

The sales managers remember the old feuds with their ancient enemy, and thus these increasing numbers make them very nervous as evolution has ingrained in them a natural fear of claims regulations... :ejut:



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