1. Introduction
   Foods must not be presented in such a way that is likely to mislead the purchaser as to its nature, substance, quality or quantity.
   UK law and/or EU regulations already lay down certain labelling requirements and further amendments are in the course of introduction.
   This code incorporates both existing and known future changes to the regulations and should be adopted by all NEODA members as forming part of the Association's Guarantee of Confidence scheme. Only the sections of the legislation which are directly applicable to NEODA members have been outlined below. A full copy of current labelling legislation is available from HMSO.

2. Products Covered
   These requirements cover all oils, fats, margarines and similar products intended for direct or indirect sale to the public and for sale to hotels, restaurants and other mass catering establishments.

3. Labelling
   All labelling, which must be easy to understand, clearly legible and indelible, must appear on the packaging itself or on a label securely attached to or clearly visible through the packaging. Labelling must be marked in a conspicuous place in such a way as to be clearly visible. Legislation forbids misleading purchasers as to the nature, substance or quality of the food.
   Certain figures must be of a minimum height, as laid down in Annex I.

4. Label Details
   All foods covered by this Code shall be marked or labelled with the following:-

   1. Name of the food

   2. Net contents by weight or volume

   3. List of ingredients (where required)

   4. Indication of minimum durability

   5. Name and address of party responsible

   These requirements are explained more fully in points 5-9 below.
   The labelling may contain or be required to contain additional information, as set out in points 10-13 below.

5. Name of the Food
   In addition to any brand applied, the product must be labelled with a specific name (e.g. corn oil) or by a general descriptive name (e.g. "vegetable/animal" oil). Too general a description (e.g. 'cooking' oil or 'frying' oil) is inadequate unless accompanied by a reference to a specific named oil or the description vegetable or similar. A trade mark or brand name must not be substituted for the name of the food, but may be used in addition to it.

6. Net Contents
   The net quantity of volume (for liquids) or by weight (for solids) must be shown in the same field of vision as the name of the foods.

   There are minimum height requirements for figures used, related to the size of the container and the mass or weight of the contents as set out in Annex II.

7. List of Ingredients

   A list of ingredients is required whenever the product contains more than one ingredient, including additives and must be listed in descending order of weight at the time of their use in the preparation of the food. A blend of more than one oil under the description vegetable is not considered as more than one ingredient for this purpose.

   The list of ingredients must be headed or preceded by an appropriate heading which consists of, or includes the word 'ingredients'.

   The words 'oil' and 'fat' may be used to cover any refined oil or fat (other than olive oil) but must be accompanied by the description 'animal' or 'vegetable' or both, as is appropriate, or by stating the specific animal or vegetable oils(s)/fat(s) concerned. In the case of hydrogenated oils or fats, the generic name must also be accompanied by the description 'hydrogenated'.

   Additives used in a food to serve the function of one of the categories of additives listed in Annex II shall be identified by the name of that category followed by the additive's specific name or serial number (if any). Where an additive is added to or used in a food to serve more than one function, it shall be identified by the name of the category that represents the principal function followed by the additive's specific name or serial number. Any additive which is required to be named in the list of ingredients of a food and which does not serve the function of one of the categories listed in Annex II, it shall be identified by its specific name.

8. Indication of Minimum Durability

   1. For all products covered by this Code, the minimum durability (being the date up to which the product can reasonably be expected to retain its specific properties if properly stored and referred to below as "shelf life") must be indicated by:-

      1. for products with a shelf life of three months or less, the words "best before" followed by the day, month and year, or by the day and month only.

      2. for products with a shelf life exceeding three months, but not more than eighteen months, the words "best before" followed by the day, month and year, in that order or the words "best before end" followed by the month and year only.

      The date can be abbreviated providing it is in a form which consumers are going to understand. For example, 1 January 1999, 31 Mar 99, 1.6.99, 01.08.99 as will be 1 January 2006, 31 Mar 06, 1.6.06, 01.08.06.

   2. The indication of minimum durability must be in the same field of vision as the name of the food and net contents. The actual date may appear elsewhere (i.e. on the cap or lid) provided the words "best before" or "best before end" appear in the appropriate field of vision and make reference to the place where the date appears.

   3. Lot marking Regulations require that food produced, prepared or packaged as part of a lot must be marked or labelled so that the 'lot' can be identified. A lot is a batch of products manufactured under similar conditions. The lot mark must be sufficiently informative in the event of product recall. The lot mark must be easily visible, clearly legible and indelible. Foods correctly marked with the minimum durability i.e. given in uncoded form and shows at least the day and the month, are exempt from the requirement to lot mark. This must stand alone from any other marks and if not obvious, must be preceded by the letter L.

9. Name and Address

   The labelling must include the name or business name and an address or registered office of the manufacturer, packer or distributor established in the EU.

10. Special Storage Conditions

    If special storage conditions need to be observed in order to retain the product's specific properties until the date of minimum durability or if the product needs to be used in a particular way or if certain conditions or limitations on use need to be observed, these must be stated on the labelling.

11. Claims

    1. In order to make a claim for "high in polyunsaturates", the following must apply:

       1. Product must contain at least 35% oil/fat (by weight).

       2. At least 45% of the fatty acids present must be polyunsaturated (cis-methylene interrupted).

       3. The amount of saturated fatty acids present must not exceed 25% of the total fatty acids present.

       4. The claim must be accompanied by the words "low in saturates" or "low in saturated fatty acids".

       5. The product must be labelled with the amounts of total fat or oil, polyunsaturates and saturates, all given equal prominence and all expressed in ml/100ml (for liquids) or g/100g (for solids).

    2. In order to make a claim for "low in cholesterol", the following must apply:

       1. The product must not contain more than 0.005% cholesterol (equal to 5mg/100g).

       2. The product must be declared as "high in polyunsaturates" and both conform to and make the same declarations as those given in a. above.

       3. The cholesterol claim must not precede, nor be shown in larger letters than the polyunsaturates claim and must not be in larger letters than the statement of which it forms a part.

    3. In neither case is it permitted to claim or suggest, whether implied or express, any benefits to human health or claim to be a remedy for any illness or medical condition.

    4. The food shall be marked or labelled with the prescribed nutrition labelling as detailed below.

12. Nutrition

    Nutritional information may be given on a voluntary basis. Where this information is provided, it must be in the form of one of the following groups, showing the values in the order given:

    Group 1	Group 2
    Energy Value Protein Carbohydrate Fat	Energy Value Protein Carbohydrate Sugars Fat Saturates Fibre Sodium

    Nutrition labelling is compulsory only when a nutrition related claim is made on the labelling, in presentation or in advertising. Any voluntary listing of saturates or any claim made relating to saturates makes it necessary to list all eight nutrients given in group 2.
    Where the amount and/or type of fatty acid and/or the cholesterol level is declared, this declaration must immediately follow the declaration of total fats, inserting the necessary information (as given in Section 11) in the following format and order:

    Energy Value	-	KJ/KCal/100g
    Protein	-	g/100g
    Carbohydrate	-	g/100g
    Fat	-	g/100g of which
    		Saturates	-	g
    		Monounsaturates	-	g
    		Polyunsaturates	-	g
    		Cholesterol	-	mg

    (For information, a typical energy value for oils and fats is 3700 KJ or 900K cal per 100g and the figure for both protein and carbohydrate levels in oils and fats is zero).

    For example, a claim "low in cholesterol" does not require the listing of monounsaturates. Similarly a claim for "high in polyunsaturates" does not require the listing of cholesterol or monounsaturates. However, it should also be noted that a claim regarding monounsaturates does require the listing of the saturates.

    Nutrition information must be presented together in one place in tabular form with the numbers aligned except where space does not permit, it can be presented in linear form.

13. Olive Oil
    Names and descriptions which may be used for the sale of olive oils are strictly controlled by EU legislation.
    Current names/descriptions which may be used to sell olive oil on the retail market, are as stated below:

    1. Extra Virgin Olive Oil

    2. Virgin Olive Oil

    3. Olive Oil

    4. Olive-Pomace Oil

14. NEODA Logo
    Members may only use the NEODA Guarantee of Confidence Logo on pack sizes which are laid down by prescribed quantity legislation from time to time in force in addition to those listed below:

    • 10L, 15L and 20L for liquid edible oils and,

    • 10Kg, 12.5Kg, 20Kg and 25Kg for solid fats.

    The use of the logo shall also be restricted to packages which are filled to their nominal weight or volume and which shall have been packed in the UK by a NEODA member.

15. Weights and Measures

    1. Declaration of the net quantity must be made in the same field of vision as the name of the food and the minimum durability.

    2. There is a minimum height for figures used to express quantity relating to the size of container and mass or weight of goods as stated in Annex I.
    3. Any marking of a container with information as to quantity:-
       1. Shall be easy to understand, clearly legible and indelible.
       2. Shall be easily visible to an intending purchaser under normal conditions of purchase.
       3. Shall not in any way be hidden, obscured or interrupted by any other written or pictorial matter.
       4. If it is not on the actual container or on a label securely attached to the container, it shall be so placed that it cannot be removed without opening the container.
    4. The Weights and Measures (Packaged Goods) Regulations 1986 provides for the "average" system of quantity control for prepacked goods. Any product packed in a quantity between 5g/5ml and 10kg/10L may be packed to the average system if it is 'e' marked. During the course of packaging there will be fluctuations in the measured quantities and to ensure that these variations are within acceptable tolerance, packers must comply with the following:-
       1. The average quantity of the packages shall not be less than the declared quantity.
       2. No more than 2½% of packages may be non-standard i.e. be underweight by an amount greater than the Tolerable Negative Error (T.N.E.)
       3. No package may be inadequate i.e. be underweight by more than twice the T.N.E.

       The 'e' mark must be indicated next to the weight declaration on the pack. The 'e' mark also acts as a passport for packaged goods which pass between EU countries, allowing such items free passage without any further quantity checks being necessary.

       For further details of packers requirements' please see the NEODA guidelines on The Packing of Liquid Edible Oils - Guidelines to Weights and Volumes or contact your local Trading Standards Office.

Note:
NEODA has taken every possible care in compiling, preparing and issuing these guidelines. However, we cannot accept liability in connection therewith.

While the contents are believed to be accurate at the time of issue, legislation is constantly changing. In view of this, members are recommended to seek advice from their local enforcement officers on proposed or revised labels at the proof stage, prior to printing.

References:

• MAFF Guidelines on Nutrition Labelling
• Weights and Measures (Quantity Marking and Abbreviations of Units) Regulations 1987
• Food Labelling Regulations 1996
• MAFF Guidance Notes: Food Labelling Regulations 1996
• Food (Lot Marking) Regulations 1992
• Weights and Measures Act 1985

Annex I

Table of Size of Figures in Quantity Marking of Containers

Annex II
Categories of Additives which must be identified in a list of ingredients by their category name.

The above table is taken from Schedule 4 [Regulation 14(9)] of the Food Labelling Regulations 1996.