9 replies to this topic

[Blynele]

Hello,

If our company changes product composition can we put stickets that cannot be removed without leaving marks on packaging with new ingredient list on top of old ingredient list until we use up our old packaging? It would cover old ingredient and nutritional info completelly. Our company is in EU. I cannot find any regulation specifically about this, only that the product information must not mislead the consumer. If you could attach relevant document about this I would appreciate it. Thank you

Edited by Dyvinil, 24 March 2023 - 04:03 PM.

[olenazh]

I don't have a document, sorry, just using a common sense: did you take into account those people who could potentially remove a new label and blame your company of misleading label? Just playing devil's advocate:) Because, I know what this kind of people (e.g., bored, mean, sue-persons, crazy, etc.) are capable of. 

[AJL]

Not OK... You just can't have two labels. How are you supposed to know which one is 'right'. What olenazh said...

[Blynele]

Yes, we have thought about that. The problem is we have changed the composition and it solves our product quality issue we have been having. The management is willing to risk this if sticker on top is not against the law because they do not want to throw out old packaging

[AJL]

So if both labels have a different ingredients list its an issue...
Because you might end up with a consumer that complains. Its not OK because the food law states that labelling shouldn't be misleading, and you can't tell for sure which one is right

[Scotty_SQF]

Depends on your country's and the country(ies) you are selling it to, food safety laws.  For instance I know in the US for a USDA product, you can file for and get approved (if you meet all the requirements) a label to go over top your existing label if you meet certain requirements and you can only do it for set period of time.  I know one of the requirements is the label cannot easily be removed.  I would check into the laws and see if there are any exemptions such as what I described that you can file for.

[olenazh]

Depends on your country's and the country(ies) you are selling it to, food safety laws.  For instance I know in the US for a USDA product, you can file for and get approved (if you meet all the requirements) a label to go over top your existing label if you meet certain requirements and you can only do it for set period of time.  I know one of the requirements is the label cannot easily be removed.  I would check into the laws and see if there are any exemptions such as what I described that you can file for.

That would be very interesting and useful if you could post here those legislations! I guess, not only me would be extremely grateful for that.

[AJL]

Yes Scotty I had no idea! Thanks for sharing. Getting it approved in advance equals peace of mind

[Scotty_SQF]

See this link from the USDA:

 

https://www.fsis.usd...ired-requesting

[Ian R]

Hi Blynele

 

I have over labelled for similar reasons on a couple of occasions.

This was always done with the prior approval of the Food Safety Authority

we had to submit the reasons for the need to over label and how this was to be done.

 

The label needs to completely cover the incorrect information but must not cover any other mandatory information.

 

Within the UK there is no legislation that covers over labelling but there are guidelines and the FSA has it listed as an option for dealing with certain changes in production.

In my case the local authority deferred the approval to the FSA

 

The key factors are,:

The new label must cover all the information that needs to be changed

No other information must be covered

The label should be highly adhesive and ideally not be able to be removed without damaging the original label

 

But get approval from your local authority to carry out the process.

 

reds