Aug 10th, 2022
5 mins

Members will recall that on 24th June the FSA published further guidance to help industry make informed choices about the substitution of sunflower oil with other oils as a result of supply chain issues due to the Ukraine conflict.

At that time, they also wrote to food law enforcement, and port health authorities in England stressing that “during the current uncertainty, packaging and labelling choices should be guided by the availability of vegetable oils alongside what each business can reasonably foresee being in its products. This provides businesses with a degree of flexibility, particularly in the face of supply chain volatility”.

Whilst not set in stone, the FSA’s expectation has always been that businesses would return to labelling compliance by 31st October 2022. However, over the last month BFFF members have raised several concerns with us which strongly support the view that this date is unrealistic and unworkable.

To name but a few, we are hearing of lead times of between 16 and 22 weeks for board, planned shutdowns at processing plants and printers during August, ongoing backlogs and delays at printers due to Covid and unavailability at laboratories for analysis.

As I’m sure you are all aware, the complexity, scale and cost to businesses is tremendous. One BFFF member alone has estimated that around 600 of their lines have been impacted which would mean over 1000 labelling changes would be required. Taking into consideration the cost of a plate change at the printers this could equate to somewhere in the region of £35,000!!

In light of the above, the BFFF have been working on behalf of the membership to ensure your voices are heard. All concerns have been fed directly into the FSA, and we’ve been assured that they will be included in their assessments.

We’ve also drawn their attention to the recent FSA Ireland press release announcing a 6-month extension to the return to compliance date. Assuming no change in the current situation, this would seem a more sensible timeframe and we would hope that the FSA follow suit.  It is vital the FSA make a decision quickly to provide peace of mind to members trying to get high quality food on the shelf for consumers whilst battling against extraordinary challenges in the supply chain.

The FSA have thanked us for highlighting the above to them but as yet, have not commented further as to their intentions.

As always, we will keep members updated but, in the meantime, please continue to share your comments and concerns with us as the more information we can feed back to the FSA the more informed their decisions will be. Please forward any information to


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