By Dr Verner Wheelock, Chairman of food industry training specialists, VWA.
Why do we label food? The answer to this question seems so obvious that you may wonder what the point is of asking it. Obviously we label food so that, a) the consumer can identify it and b) to make the food attractive to the consumer so that they will buy it. There are a group of people, however, who disagree with this answer: The European Commission and the European Parliament.
By passing the Food Information for Consumers Regulation (FIC) they have clearly signalled that they believe the primary function of the food label is to give the information that they deem necessary to allow consumers to make informed choices about food.
So how does this affect the future of food labelling? In short, it totally alters the dynamic of how we construct a food label. Currently when designing a label the tendency is that we will identify the branding messages, the marketing messages and any other key information we wish to communicate. We will ensure that these are prominently displayed on the label and then size the label to ensure that the product, if appropriate, is visible. Finally we allocate the remaining space to legally required information – the font size of which will be determined by what is needed to fit it into the residual space.
Under the FIC it is very clearly stated that the provision of mandatory information takes precedence over the provision of voluntary information. Not only is the information that must be provided defined, but also the font size of that information is defined dependent upon the size of the package. It will therefore be necessary to allocate sufficient labelling space for the mandatory information as required before considering what space remains for the selling message.
The difference in the mandatory information which must be provided is not huge: e.g. legal name of the food, ingredients etc. The main difference is that nutrition information must be provided. This tends to occupy considerable space especially since it is expected that it would normally take tabular form.
Where the biggest difference lies, however, is in the specified font size in which information must be provided. For example: where the largest face of a package is 80cm2 or greater the minimum height of lower case lettering x must be 1.2mm. Allowing for ascenders, descenders and line spacing we are probably looking at approximately 3mm per line. At present a relatively good food label would be in about a 5 point font size. This is equivalent to about a 7 point font size. 5 point would only be good enough for a package with a largest face of less than 80cm2. Under the new Regulation you will only be allowed to forego nutritional information if the largest face is less than 25cm2. Only at less than 10cm2 will you be able to start leaving off other mandatory information.
Given these constraints, the solution would seem obvious: let’s just make the package bigger. There are two main drawbacks to this. Firstly we all have responsibilities to reduce packaging under WRAP and secondly we would not automatically gain labelling space because if by increasing the size of the packaging we crossed one of the thresholds then we could actually lose labelling space.
The solution offered by food industry experts, Verner Wheelock Associates, is simple, yet viable: Let’s not get bigger, let’s get smarter. Let’s train delegates not to think in terms of large descriptors of the product or large images that take up a lot of space but to seek out simple messages that resonate with the consumers.
To do this we not only need to train people in the requirements of the FIC in order that they know what they have to say; but train them in other areas of the law and guidance that can help them think creatively but simply about the food label and the message that is being conveyed.
We already have a lot of positive messages defined in the Nutrition and Health Claims Regulations, messages that have a meaning to the consumer such as ‘low fat’, ‘low salt’ or ‘reduced sugar.’ Simple messages that do not need a complex expansion to make them attractive. If we understand i.e. have been trained in the Regulation then we can use these messages effectively and, if space allows, expand them to give the consumer more information about the health benefits of our products.
We have everyday terms that have a long history with consumers: ‘fresh,’ ‘pure,’ ‘natural,’ ‘farmhouse’ and a host of other messages all have a feel -good factor for the consumer. But in order to use them effectively and without fear of challenge we have to understand what they mean and in what circumstances we can use them. For example, what is the difference between fresh and freshly -frozen? Again, if we have been trained in the rules and guidance governing these terms we can use them effectively.
If we go forward into this new environment for labelling with our eyes blinded we will be at a significant competitive disadvantage. Only by ensuring that relevant staff are adequately trained can we hope to reap a competitive edge. And we don’t have long to do it.
With the exception of a few of the smallest businesses who have an exemption until 2016, all food labels must be compliant with the FIC by 14th December 2014. You might say ‘what’s the panic? It’s 20 months away.’ But is it? Companies will want to make sure that all of your old packaging is used up so that you are not throwing any away. Equally you will want to ensure that you have new labels in place when the old ones run out. You have to schedule time for your staff to develop new labels that are compliant and finally you need to find print slots, when everybody else wants them. Time is short and the swiftest and best trained will be leading the pack when the change comes.
To find out more about VWA’s ‘Creative Legal Labelling’ courses, please visit www.vwa.co.uk