There is so much happening in the food law arena, it is sometimes helpful to distil horizon gazing into the biggest themes affecting food businesses in 2014:
This is the year when labels must be substantially reformulated to adhere to the Food Information Regulation 1169/2011 requirements. Although a number of grey areas remain, it is likely that enforcement authorities will take a light touch approach to enforcement until these are clarified.
Supply lines / authenticity/ due diligence
There is a new era of suspicion: where market and supply information indicate certain price levels, businesses should be put on notice where products become available that are significantly below that market rate. Due diligence can no longer be a dusty paper trail but rather must be something to be actively reviewed. There is greater emphasis placed on companies sharing information with regulators alongside the creation of a new Food Crime Unit, as recommended by Professor Elliott in his report into UK food supply chains.
Health and nutrition claims
This area will remain key for industry. Health and nutrition claims on food generate increased consumer demand but food businesses must operate within the Nutrition & Health Claims Regulation 1924/2006 (NHCR) and interpretative guidance provided by Member States that can influence whether or not such a claim may be implied. The front line remains reformulation and interpretation of health claims.
Country of Origin Labelling (COOL) / sustainability / welfare
These issues are now caught up in the consumer consciousness after horsemeat contamination of 2013. Customers want to know where their food was produced as well as how it was produced, and this is now a major purchasing point for them (after price). The report on COOL for meat as an ingredient indicated this was an area for future legislative consideration.
Brands / joint ventures
The power of the brand remains paramount but consumer trust is vitally important to this. Companies will be increasing their transparency and their products’ “story”.