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From April 1, 2020, the implementing regulation (EU) No. 2018/775 with concrete provisions for mandatory information on the origin of so-called primary ingredients will apply.
Quote Article 26(3)*: “3. Where the country of origin or the place of provenance of a food is given and where it is not the same as that of its primary ingredient:
(a) the country of origin or place of provenance of the primary ingredient in question shall also be given; or
(b) the country of origin or place of provenance of the primary ingredient shall be indicated as being different to that of the food.” …
Primary ingredients have been defined as one or more ingredients which together make up more than 50% of the content of a foodstuff or which the consumer*expects to be the main ingredient based on the designation of the foodstuff. Two examples for explanation:
- Strawberry jam from Germany (with strawberries from EU countries)
- Italian cream cheese (with milk from Germany)
The correct presentation on the label is described in Article 13 of the Implementing Regulation EU 2018/775. Essential is the placement of the indication of origin and legibility, which is determined by the minimum font size.
Our food chemists at AGROLAB Food Laboratories will provide you with the necessary information in the expert report as part of the label testing of your food so that there are no objections during official controls.
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Author: Dr. Frank Mörsberger
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