Following previous communications concerning the reformulation of products due to supply chain issues linked to the current conflict in Ukraine, the FSA has now issued further guidance.

This latest guidance concerns the provisions within the existing legal framework for labelling where there is grouping of vegetables oils and provides further clarification on the application of labelling provisions in the Food Information to Consumers (FIC) Regulation.

Please note that previous guidance sent out to Local Authorities (LAs) still applies and the request for LAs to adopt a pragmatic approach in relation to supply chain matters linked to Ukraine is still in place.

The guidance describes the relevant labelling rules, including on grouping refined vegetable oils on the ingredients list when there is expected to be a variation in the use of one or more oils. It also provides guiding principles for how to provide compliant consumer information when the use of oils is expected to vary.

It is fairly self-explanatory, but in summary there are two options:

1)            Grouping oils on an ingredients list in ‘varying proportions’

Refined oils of vegetable origin are exempt from the usual requirement to list each oil separately by weight, when grouped together. The ‘in varying proportions’ provision in the FIC Regulation means that:

• Refined vegetable oils may be grouped together as ‘vegetable oils’. The oils must then be specified to allow consumers to express their preferences e.g. ‘vegetable oils (sunflower; rapeseed)’.
• When the use of two or more refined vegetable oils is expected to vary, the phrase ‘in varying proportions’ may be used after the information about the vegetable origin. For example: ‘vegetable oils (sunflower; rapeseed) in varying proportions’.

When using the wording ‘varying proportions’ we would expect a percentage (more than 0%) of each specified oil remains included in the product. For example, if sunflower oil and rapeseed oil are specified, there must be an expectation that both oils will be in the product

2)           Using ‘and/or’ when mutually substitutable oils make up less than 2% of the finished product

When two similar or mutually substitutable ingredients (for example similar refined vegetable oils) make up less than 2% of the finished product. In this case, using ‘and/or’ is acceptable in the ingredients lists when at least one of the oils is present in the finished product. For example, “contains sunflower oil and/or rapeseed oil”.

The use of “and/or” should not be used for vegetable oils listed in FIC Annex II as known to cause allergies or intolerances.

If you have any queries relating to this matter please do not hesitate to contact deniserion@bfff.co.uk or the FSA directly at receiptandmanagement@food.gov.uk

Members may be interested in a new initiative recently launched by WRAP to help businesses understand their scope 3 emissions.  These are emissions that are created from the products and raw materials members purchase.

For many companies, their Scope 3 emissions may well be the single highest contributor to their GHGs.

One of the key issues is that a lot of data in the market varies which results in potentially inaccurate data.  The WRAP protocols are designed to bring some consistency to the data.

They have created a Footprint Questionnaire for the following categories:

• Beef
• Lamb
• Pork
• Poultry
• Cheese
• Warm water prawns
• Coffee
• Bananas
• Tomatoes
• Wine

They have then created a template guide for any product outside of the above list.

Members can access details about the initiative and the assets available by following this link

As we advised in the Weekly on 5^th May, the Government have announced they have delayed further import controls on POAO and High-Risk Goods that are imported from the EU.

It was planned that S.P.S checks would be introduced on a staged basis from 1^st July.

Defra have now advised us on several calls that they will design a new process with three key strands:

1. It will be digitised
2. It will be simplified
3. It will be proportionate

They have also said they are keen to engage with industry as they design this new process.  Therefore, we are inviting members to contact us to discuss if they would like to engage directly with Defra or be part of a group of BFFF members that feed information into Defra via the BFFF,

Please can you contact Holly Jones if you want to be part of this consultation process.