LOOSE FOODS Mr Chris Dabner British Retail Consortium

1. LOOSE FOODSMr Chris Dabner British Retail Consortium

2. What are Loose Foods? • non pre-packed foods • foods sold non prepacked at catering establishments • foods pre-packed on the premises from where they are sold (pre-packed for direct sale) • NB Pre-packed for direct sale is not defined in the Directive.. however it is mentioned in Article 14.

3. Are loose foods important? • Sales of loose food including food sold at catering establishments are enormous and are growing. • A large proportion of the food sold by specialist, craft producers and retailers is sold loose i.e. bakers (bread and patisserie), butchers, fishmongers, delicatessens, cheesemakers, etc • A very large proportion of the producers, retailers of loose food are SMEs employing less than 10 people. • Sales of loose foods via markets and specialist shops are essential for the survival and well-being of rural communities and a vital part of many rural economies.

4. Consumers expectations for the labelling of loose foods • Consumers want very little, if any, information. • In the UK there are over 500 Farmers Markets and over 4000 Farm Shops. The labelling information provided is minimal. • In catering establishments most consumers are not interested in having information about their food. • The exceptions are those who have allergies, religious or ethical concerns or who want to follow a particular dietary regime e.g. vegetarian, organic • Additional labelling requirements are not really necessary - the consumers can ask in contrast that to pre-packed food.

5. Consumers expectations for labelling of pre-packed foods • Full disclosure of information. • Manufacturers and retailers are being told that consumers want still more information to be required by legislation. • Consumers are also saying that: • there is too much information on the pack • they find it difficult to read • they do not understand the information (this can be because of the • technical language required by legislation e.g. what is a humectant?) • They want: • less information, • the information to be simplified, • easier to read • to be more understandable

6. What are the labelling requirements for loose foods? • Directive 2000/13/EC relates to labelling, advertising and presentation • All/majority provisions apply to pre-packed food • Loose foods are covered by article 14

7. Article 14 “Where foodstuffs are offered for sale to the ultimate consumer or to mass caterers without prepackaging, or where foodstuffs are packaged on the sales premises at the consumer's request or prepackaged for direct sale, the Member States shall adopt detailed rules concerning the manner in which the particulars specified in Article 3 and Article 4(2) are to be shown. They may decide not to require the provision of all or some of these particulars, provided that the purchaser still receives sufficient information”

8. Article 14 in practice • Allows Member States to decide how much labelling information they want for food sold • The majority of Member State require very little labelling information be to be provided • The definition of foods pre-packed for direct sale can vary from Member State to Member State. • In the UK it means foods pre-packed by a retailer for sale on the premises where they were packed/produced or from a vehicle or stall trading under the same name as the premises where they were packed. • If consumers want the information they can ask

9. Additional requirements for loose foods • Allergens • food contains allergenic ingredients. • food "may contain" an allergenic ingredient. • food may become contaminated with an allergenic ingredient during handling. • Durability Date. • required for all loose foods? • are there demonstrable and real safety concerns? • loose foods are meant to be consumed "immediately" • loose foods will spoil before they become hazardous? • Where there is no packaging how do you provide this information? E.g. market stall, specialist shop, catering establishment (cafe, restaurant), retail establishments

10. Additional issues to be considered • Majority of businesses affected will be SMEs • There appears to be little or no consumer demand for additional labelling information. • Providing additional information will be difficult and costly. • How do you provide the information e.g. label stuck on the bag in which the food is placed at point of sale? • Hi-tech, off pack solutions. • e.g-web sites • customer help, advice lines • information encrypted in the bar code • information terminals in store • If feasible, are only an option for the major retailers and catering chains

11. Provision of Additional Information • Technical issues: • complexity of the legislation • where to get the legislation and advice • amount of information required • how should the information be presented • lack of technical background/knowledge • no experience

12. Provision of Additional Information • Practical issues: • responsibility falls on the owner • use a hand written notice or ticket • write the use by date on the paper bag • use a ticket gun to provide a use by date ticket • use a computer and software package to generate notices, tickets labels • use a consultant to compile the notices, tickets, etc • feasibility (including cost) of having the notices, tickets printed by a printer (one of each!)

13. Cost of Providing Additional Information • The owner’s time • Label gun (best before date labels) £ 46.00 / 69 Euros • Ink rollers pack of 5 £ 12.50 / 19 Euros • Labels (1 box 22.5 thousand) £ 7.50 / 11 Euros • UK 500 farmers markets, 20 stalls per market, one label gun each. 500x20x99 Euros = 990,000 Euros • The UK also has normal street and indoor markets. • Computer prices vary • Software package prices vary ( £400 /597 Euros) • Basic label printer £ 346.00 / 516 Euros • Labels per 1000 £10.50 / 16 Euros (1.6 cents/label) • Would a market stall trader be expected to have a specific allergen label for each type of product and take a stock of labels each day to stick on the paper bags?

14. What would the Food Industry like regarding the future labelling of loose foods? • Retention of the principles outlined in the existing Article 14 • Introducing no additional labelling requirements at EU level • Any requirements to be clearly based on safety. • There must be clear and demonstrable need (justification) for new requirements as distinct to there being a want (desire) • The practical implications on implementation to be fully understood • In particular the affects on SMEs and micro businesses • Any additional requirements must be properly costed • There is need to achieve a balance. • All information/labelling must be; understandable, useful and used