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Introduction. Patrick Farrell Audit Manager Food Safety Authority of Ireland (FSAI) My role in the FSAI is to manage the various types of audits we are involved in. Audits of official agencies Under service contract to FSAI Focused Audits Labelling & Traceability SRM

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  • Patrick Farrell

  • Audit Manager

  • Food Safety Authority of Ireland (FSAI)

  • My role in the FSAI is to manage the various types of audits we are involved in.

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  • Audits of official agencies

    • Under service contract to FSAI

  • Focused Audits

    • Labelling & Traceability

    • SRM

  • Special Investigations

    • Food Fraud

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Misleading advertising,presentation & labelling of foodstuffs

  • Legislation

    • Directive 2000/13/EC…. On the approximation of the laws of Member States relating to the labelling, presentation and advertising of foodstuffs

    • Article 16 of Regulation 178/2002

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  • Labelling legislation

    • Where are the rules on food labelling?

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European horizontal labelling legislation

  • European Directive 2000/13/EC

    • Meat products amendment: Directive 2001/101/EC

      • (as amended Directive 2002/86/EC)

    • Allergens amendment: Directive 2003/89/EC

      • (as amended Directive 2005/26/EC)

        • (Directive 2005/63/EC correcting 2005/26/EC)

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Article 16 of 178/2002

  • States as follows:

    • Without prejudice to more specific provisions of food law, the labelling, advertising and presentation of food or feed, including their shape, appearance or packaging, the packaging materials used, the manner in which they are arranged and the setting in which they are displayed, and the information which is made available about them through whatever medium, shall not mislead consumers.

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  • ‘labelling’

  • shall mean any words, particulars, trade marks, brand name, pictorial matter or symbol relating to a foodstuff and placed on any packaging, document, notice, label, ring or collar accompanying or referring to such foodstuff

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  • ‘pre-packaged’ shall mean any single item … consisting of a foodstuff and the packaging into which it was put before being offered for sale……

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Derogationwhere a prepackaged foodstuff is:

For supply only to mass caterers (for preparation, processing, cutting, etc)


Intended for the ultimate consumer, but marketed prior to sale to the ultimate consumer and where sale to mass caterers is not involved (such as supply to wholesalers)

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In such cases the labelling information may appear on the commercial documents accompanying the foodstuff.



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Information on label must be clear and unambiguous

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Must not mislead the consumer to a material degree:

  • As to the characteristics of the foodstuff and, in particular:

    • as to its nature

    • identity

    • properties

    • composition

    • quantity

    • durability

    • origin or provenance

    • method of manufacture or production

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Must not mislead the consumer to a material degree:

  • By attributing to the foodstuff effects or properties which it does not possess

  • By suggesting that the foodstuff possesses special characteristics when in fact all similar foodstuffs possess such characteristics.

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LABELLING must not attribute to any foodstuff the property of preventing, treating or curing a human disease or refer to such properties

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The information provided on the label must be:

  • easy to understand

  • be clearly legible

  • it must also be indelible

  • easy to see and not obscured in any way

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  • The labelling of foodstuffs must be in a language easily understood by the consumer e.g.

  • In Ireland it must be in English or English & Irish

In Slovakia it may have to be in Slovakian. Will it have to be in another language ??

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  • When do the labelling rules apply?

  • General requirements

  • Compulsory labelling requirements

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When do the labelling rules apply?

  • Pre-packaged foods

    • and

  • Available for sale to consumers and/or the catering trade

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General requirements

  • Purchaser must not be misled

  • Medicinal claims prohibited

  • Information must be easy to understand, clearly legible etc.

  • Language – English (depending on Member State language)

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Overview of labelling requirements

  • name of food*

  • ingredients

  • quantity of certain ingredients (QUID)

  • net quantity*

  • date of minimum durability*

  • special storage instructions

  • name and address of manufacturer/packer/seller

  • origin

  • Instructions for use

  • alcohol content*

* must appear in the same field of vision

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  • Field of Vision:

    • The name of the foodstuff

    • the date of minimum durability

    • the net quantity

The intention is that all the information can easily be seen at the same time under normal purchasing conditions

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The food we eat today is a key part of our lifestyle. We ask ourselves 'is this food good for me?' or 'how much of this should I eat?'.

What we eat is becoming more important as we move toward healthy, self improved lifestyles.

As consumers become more conscious of food ingredients, it is in the interests of manufacturers to highlight product contents and health or nutritional benefits.

Labelling is just one way of providing consumers with appropriate information.

Labels are of particular importance when we consider processed or fresh foodstuffs as well as perishable fast moving consumer goods. Labelling needs to be accurate, particularly at the point-of-sale

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How often do you buy something without looking at the product label? How many of us understand the details presented on product labels? Labels should not mislead consumers and information should be easily seen. This is the principle of 'the field of vision'.

By law, packaged food must show:

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What is the difference?

'Smoked Irish Salmon' versus 'Irish Smoked Salmon'Could any of these products have been made in Ireland?

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Case StudiesBeef & Poultry

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  • Beef supplied by cold store (mixture of Irish & imported)

  • Export refunds

  • Cooked in plant

  • Not labelled as Irish leaving the plant

  • Brazilian beef with SEL stating Irish

  • Delivered to multiple

  • Multiple delivers to retail

  • Shelf Edge Label (SEL) states Irish

  • SELs Produced centrally

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Chicken Fillets

Caps imported from Belgium

Skinned and cut in half

Packaged and labelled as ‘Produced in Ireland’

Irish Health Mark

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We guarantee that all our

fresh whole chickens,

chicken breast fillets and

portions are 100% Irish”




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Adare Farm Chicken

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Inish Glora Farm

Chicken Fillets

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Examples of Fishy Labelling

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  • Traditional


  • Seafresh Ltd, Castletown, Co.Galway

Nutritional Information


xxxxxx xxxxxx


xxxxx xx.xx


xxx x.xx


PRICE x.xx WEIGHT xxxx

USE BY xx/xx/xxxx


Irish Atlantic Salmon (farmed), Salt,Oak Smoke


Salmone Irlandese Atlantico (di allevamento ) Sale, Fumo di Quercia


Farmed = Correct


di allevamento = incorrect

prodotto di acquacoltura

= Correct

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Farmed Salmon



Machine Sliced

  • Traditional


  • Seafresh Ltd, Castletown, Co.Dublin


Nutritional Information


xxxxx xxxx

__________________ __________________

xxxxx xxxx


xxxxx xxx



USE BY xxxxxx

Ingredients: Salt, Smoke & Salmon




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  • Traditional


  • Seafresh Ltd, Castletown, Co.Dublin

Production Method

Not Indicated

Our Smoked Irish Salmon is Harvested in the crystal clear waters of the North Atlantic and off the rugged West Coast of Ireland

Catch Area

Not Specific


USE BY xxxxxx

Nutritional Information


xxxxxx xxxx


xxxxx xxxx


xxxxx xxx


Ingredients: Salt, Smoke & Salmon

Terminology Used

Misleading in the absence

of Production Method &

Specific Catch Area




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Wet Fish Display Counter

“All our fish are caught off the west

coast of Ireland”

Nile Perch

Farmed Scottish Salmon

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Case StudiesFishery Products

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Complaint Wild Salmon


Contact HSE


Non Compliance

Cautioned by


Audit of Premises

(Processing Plant

+ Fishmongers)

Invoice Not the Same

- Altered

Visited Supplier

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Wild Salmon Displayed on Menu

Checked Product


Checked Invoices/

Delivery Docket

from Distributor


  • Poor traceability

  • At Processors

Contacted DCMNR

to verify

Product Codes

After Investigation

Verified Product

Farmed Salmon

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Salmon Country of Origin + Production method not Specified

Salmon being sold

by Processor/Distributor

to Retail Outlets

Checked Packaging /

Labelling +

Commercial Documentation

Buys Irish + Also


Through Importer

COO + Production Area

Not always Specified

Irish – Labelled as Farmed Irish

Scotish/Norwegian – Labelled as Caught NE Atlantic

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  • Substantial Transformation

  • When can a product produced in Slovakia be labelled as ‘produced in Slovakia’ if the raw material is from a different country

  • Must not mislead the consumer

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Press Clipping- The China Daily

“And finally, a restaurant in northeastern China that advertised illegal tiger meat dishes was found instead to be selling donkey flesh-marinated in tiger urine. The story explains that the restaurant had advertised stir-fried tiger meat with chillies as well as liquor flavoured with tiger bone. The sale of tiger parts is illegal in China and officers shut down the restaurant, only to be told by the owner that the meat was actually that of donkeys, flavoured with tiger urine to give the dish a “special” tang. The report didn’t say how the urine was obtained… ”

World Food Regulation Review

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It is OUR job to protect this Person !

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