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25.03.2020 - Foods

ALS – Multi-page labels allowed?

For pre-packaged foods, especially dietary supplements, multi-page labels are used in addition to the usual single-page labels.

With these labels, only the top page is visible, and the inner pages are often referred to only through words or pictograms. The consumer must detach the pages of the labels in retail to read all the information. The ALS (Working Group of Food Chemistry Experts of the Federal States and the Federal Office of Consumer Protection and Food Safety) addressed the question at its 114th meeting from September 30 to October 2, 2019, whether such labels are compatible with Art. 13 para. 1 of Regulation (EU) No. 1169/2011 (Food Information Regulation, LMIV).

According to Art. 13 para. 1 LMIV, mandatory information must be provided in a conspicuous place, clearly, legibly, and permanently if necessary. They must not be obscured, made unclear, or separated by any other information, images, or inserted material, and the view must not be distracted from them.

In the opinion of the ALS, multi-page labels where mandatory information has to be continued on the inner pages due to space constraints only meet the requirements of Art. 13 para. 1 sentence 2 LMIV if a clear and conspicuous indication of the multi-page nature (e.g., through words or with the help of a clearly visible arrow) is provided on the visible outside.

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Source: Federal Office of Consumer Protection and Food Safety, www.bvl.bund.de