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09.07.2019 - Foods

LMIV - Questionnaire on the Origin Labelling of Primary Ingredients

The European Commission has revised the draft of the question-and-answer catalog on the new Implementing Regulation (EU) No. 2018/775 on Article 26(3) of the Food Information to Consumers Regulation (FICR) regarding the origin labeling of primary ingredients that are not identical to the origin of the food. Examples include a French croissant whose primary ingredient, flour, does not come from France, or Danish cheese made from German milk.

The new version is set to be published on the European Commission's website in October or November of this year, after further consultation by the Commission, and will remain largely unchanged.

The new draft includes, for example, the requirement that information about the origin of the primary ingredient that does not match the origin of the food must be provided at every place on the packaging where the place of origin or country of origin of the food is indicated, whether directly or indirectly.

Despite this interpretive guidance, many questions will continue to remain open regarding the mandatory origin labeling of primary ingredients, depending on the case.

The new implementing regulation on the origin labeling of the primary ingredient applies from April 1, 2020.

We will keep you informed about further developments.

If you have any questions, our customer service representatives will be happy to assist you.

Sources: KWG Lawyers: www.kwg.eu; Federation for Food Law and Food Science e.V.: www.bll.de