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FIC readiness less evident with small brands

27/08/14 - With just over 4 months to go until the main elements of the Food Information to Consumers EU 1169/2011 Regulation (FIC) are due to come into effect in the UK, analysis of the industry’s journey toward compliance has revealed that larger brands are showing more visible progress than smaller brands.

In the second in a series of quarterly reports, GS1 UK commissioned a snapshot of progress by analysing a basket of 20 products*. It was also apparent that confusion remains over what is required by some parts of the regulation.

The following trends were noted from our research:

  • Two tiers of readiness are emerging –generally speaking larger brands, , have made considerable progress toward compliance. This is perhaps to be expected as large companies have more resource to assign to FIC, but also more product lines so may have to start earlier. This is in contrast to smaller brands (including imported products) where progress is not so visible; however, this is not to say work is not currently underway by smaller brands, just that it has not yet been completed.

  • Nutrition information labelling exemptions are causing confusion – FIC makes nutrition information mandatory on food labels; previously this was only the case if a nutrition claim was made in the product marketing. Some aspects, such as the reordering of nutrients in the mandatory nutrition panel, appear to be fairly well known, but there are a number of exceptions where nutrition is not legally required by the FIC at all and these seem to be less well understood. Nutrition is not a mandatory requirement on unprocessed meat or produce (such as a box of fruit) for example, and if a product label is under a certain size exemptions may apply.

  • There has been a shift to presenting ingredients as a single list – it was notable that the inclusion of compound ingredient declarations beneath the main ingredient lists, a style that was becoming the standard, was not in evidence. This might be a possible effect of the increased font size for mandatory information meaning space on a label is at a premium. This represents a more space-efficient way of presenting such information, and can reduce the space required by up to 50% on more complicated products.

  • Declaring voluntary information requires careful thought – there is a clear distinction in FIC between ‘back of pack’ nutrition (the mandatory information) and that repeated on the ‘front of pack’ which is voluntary. Some still wish to display nutritional information on the front of pack for marketing purposes, but the placement is important as it has to appear in what is referred to as the ‘principal field of vision’ - the part of the pack most likely to be seen at first glance by a consumer at the time of purchase. How a particular product is stacked on a shelf may impact the principal field of vision so voluntarily repeating nutrition information requires careful thought.

FIC also places an obligation on retailers to provide all the mandatory label information (excluding expiry dates) to potential customers through distance selling channels, such as websites. This means that brand owners need to present the label data and associated images in a format that retailers can easily integrate into the systems that populate their websites. At present we are seeing this process happening too slowly, and have concerns of a backlog emerging that may lead to businesses having to join lengthy processing queues and facing delays in making updated products available through the associated digital channels.

Gary Lynch, CEO of GS1 UK: “There were encouraging signs from this survey, which revealed some general improvements on the findings from the last one undertaken in April. However the larger brands have made far more visible progress than the smaller brands and we are concerned about possible bottlenecks at the printers toward the end of the year. We recommend all suppliers of food and drink products make FIC compliance across all channels a priority or they risk not being able to sell their products legally after 13th December.”

Notes to Editors

* The 20 samples were taken across four food categories, those categories being the same as the ones checked in the April survey:

  • Prepared ready meals

  • Primary foods (meat and fruit)

  • Confectionery and gift foods

  • Flour and flour-based products

A wide range of retail outlets were visited to purchase samples:-

  • Premium retailers

  • High street retailer

  • Discounter

  • Farm shop

  • Department store

  • Garden centre

GS1 commissioned Campden BRI to undertake the survey.

About GS1 UK

For further information or requests for interviews, please contact Tim Haidar: 020 7092 3584 /

For more than 35 years GS1 UK has been working with its members to enable the efficient movement of goods and sharing of information. It drives supply chain efficiency alongside 111 other not-for-profit GS1 member organisations in 150 countries worldwide.

Having introduced the first truly global bar code numbering system in 1973, at least five billion GS1-compliant bar codes are now scanned everyday – making it the most widely used supply chain standards system in the world. GS1 identification numbers are now also commonly used in RFID tags, Electronic Data Interchange (EDI) messages and for real-time global data exchange.

Providing independent support, GS1’s team of technical and business consultants also assist members with on-site implementation of appropriate supply chain information solutions.

Its 28,000+ UK members range from SMEs to major UK companies and include grocery retailers and food service companies, food manufacturers, healthcare and pharmaceuticals companies, and NHS Trusts. Its supervisory board includes senior directors from Tesco, Morrisons and Sainsbury’s, as well as Unilever, P&G, Diageo and the NHS.
GS1 UK actively supports The Food Chain – a UK charity set up to ensure that people living with HIV can access the nutrition they need to lead healthy, independent lives.

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