Please can I have some input on this.
We have on the Back of Pack (BOP) "Produced in the UK by ..." statement that confirms that our product is produced in the UK.
We source ingredients from the UK, EU and World in the form or raw materials, and turn them into a completely different product. Article 2(3) of Regulation (EU) 1169/2011 states:
"Goods the production of which involves more than one country or territory shall be deemed to originate in the country or territory where they underwent their last, substantial, economically-justified processing or working, in an undertaking equipped for that purpose, resulting in the manufacture of a new product or representing an important stage of manufacture."
Under this, our product is most certainly Produced in the UK.
However, I am getting conflicting information when it comes to Guidance on Commission Implementing Regulation (EU) 2018/775 of 28 May 2018 on the provision of food information to consumers, as regards the rules for indicating the country of origin or place of provenance of the primary ingredient of a food.
The guidance notes from the BRC would indicate that adhering to the upper most statement would actually be in conflict with the regulations - putting my brain in a loop.
The largest ingredient in our product is Fortified Wheat Flour, of which, wheat and statutory additives are sourced from the UK. EU and outside the EU and blended to make a specification of flour for us. This is milling is done in the UK.
Where do we stand in regards to this regulation. Does the product meet Article 2(3) of Regulation (EU) 1169/2011, or does it not as per 2018/775??