Manufacturing & Logistics IT spoke with David Taylor, business development manager, manufacturing, at Zebra Technologies, and Ken Moir, marketing director at NiceLabel, about a new food allergen regulation due to come into force on 13 December, the implications for manufacturers and retailers, and the type of printing & labelling solutions regime necessary in order to ensure compliance.

On 13 December 2014 a new law EU regulation 1169/2011 on the provision of food information to consumers comes into force that changes existing legislation on food labelling. For food manufacturers or food retailers time is running out to become compliant with this new legislation.

The new rules will apply from 13 December this year, while the obligation to provide nutrition information will apply from 13 December 2016. The new law essentially combines 2 directives into one piece of legislation:

• 2000/13/EC - labelling, presentation and advertising of foodstuffs.

• 90/496/EEC - nutrition labelling for foodstuffs.

The new EU Regulation 1169/2011 on the provision of food information to consumers changes existing legislation on food labelling including:

• Mandatory nutrition information on processed foods.

• Mandatory origin labelling of unprocessed meat from pigs, sheep, goats and poultry.

• Highlighting allergens e.g. peanuts or milk in the list of ingredients.

• Better legibility i.e. minimum size of text.

• Requirements on information on allergens also cover non pre-packed foods including those sold in restaurants and cafés.

Small yet critical adjustments

Zebra Technologies’ David Taylor explained the background: “In 2011 the EU first announced that a new regulation around food allergen and ingredients labelling was due to come into force on 13 December of this year. In practice the rules surrounding this type of labelling may seem to be largely unchanged.

However, there have been small yet critical adjustments in two main respects. One is in the format of the information and the way it’s displayed, and the other is the people who are affected by it. The format of the data is something that fits predominantly within the manufacturing area, while the increase in the number of people who are affected by it presides more within the retail space.

From this December, food producers and outlets could be breaking the law simply by continuing to list the allergens separately to the ingredients list. This is because new European legislation states that, on or after this date, anyone packaging edible goods must highlight whether this food contains any of the 14 allergens (cereals containing gluten, crustaceans, eggs, fish, peanuts, soya bean, milk, nuts, celery, mustard, sesame, sulphur dioxide, lupin and molluscs), which should now be named within the list of other ingredients; not separately. This legislation aims to make allergens more legible and prominent on food packaging, and thereby limit the number of allergic reactions suffered by misinformed consumers.”
 
Taylor added that many manufacturers and retailers could easily be forgiven for thinking this change in legislation could prove to be a logistical nightmare for their business. “Not only will they need to identify the 14 allergens within each of their products, but they will also need to automatically combine this allergen information with the rest of the ingredients in the product, and make this particular information stand out before printing it onto new labels and re-labelling all of their existing stock,” he explained. However, he added that, with 17 million Europeans suffering from food allergies, this legislation is important, and will no doubt benefit them.
 
Ken Moir, marketing director at NiceLabel, added: “The requirements of the new food labelling regulation make the label design and printing process particularly challenging for the companies producing many different food items in smaller quantities and thus printing labels on-demand. Their biggest challenge is highlighting allergen ingredients within the ingredient list and if they decide to have separate label templates for each product, this approach is time consuming, hard to maintain, and even more importantly, there is still risk of printing wrong information.
 
Moir continued: “To help food suppliers achieve compliance as easily as possible, NiceLabel has developed a food allergens software solution that produces smart templates. This means food suppliers can use just one template design for all products, print it to any kind of printer and highlight allergens automatically without changing the product database. They only need to add the list of allergen ingredients in a table and the label automatically highlights them before printing.

Smart templates automatically and clearly emphasise the 14 substances listed within the EU regulation. The solution is compatible with any label printer. Once implemented, the database of allergens is easily maintained, also in the case of multi-lingual labels. NiceLabel allows users with no programming knowledge to create their own printing solutions.”

Making things easier

Although it may not be immediately apparent, Taylor explained that the legislative change doesn’t necessarily complicate the way manufacturers or retailers package their products. “With the right printing and labelling hardware and software in place, companies can make things easier by providing the technology to make this change quickly, affordably and efficiently,” he said. “In order to ensure they are ready for compliance, manufacturers and retailers should check their existing food label printer and software in order to have the peace of mind that it is fit for purpose and is able to adapt to the necessary impending regulatory changes.”
 
Taylor added that, together with printing & labelling hardware and software, label media is also a key part of any food labelling solution. “It is not a case of ‘any label will do’,” he said. “Regulation (EC) No. 1935/2004 sets out the rules on chemical migration from all materials and articles in contact with food. It includes provisions for materials and articles that are expected to come into contact with foods or to transfer their constituents to food (such as printing inks and adhesive labels). Zebra Technologies recommends that users look for FDA approval for printing and labelling devices that come into direct and indirect food contact with food.”
 
Moir pointed out that most label printers don’t support the highlighting of allergens without special software. “If food suppliers do not have the right labelling software in place yet, right now is a good moment to upgrade to a complaint and future proof solution,” he said. “Interestingly, we also see many customers further streamlining their labelling process by using a touchscreen.”
 
He added that print productivity and allergens compliance comes from software. “Software is a critical part of the solution,” he remarked. “A simple touchscreen-based allergens application helps small companies de-skill, increase productivity and reduce error. Larger companies should consider automating their printing from their MES systems or consider using web based printing solutions for franchises, shops or remote locations.”
 
Taylor concluded: In terms of the technology involved in remaining legally compliant in the wake of the new rules due to come into force on 13 December, there are a number of software providers who are fully aware that their solutions must facilitate the easy management of data and label formatting, whether at the manufacturing or retail level. At Zebra Technologies, we are committed to ensuring that our technology partners, our resellers and the end-users of printing & labelling systems are aware that this new legislation is just around the corner. The bottom line is that if manufacturers and retailers don’t comply with the new legislation, together with other potential changes to come into play, they could find themselves on the wrong side of the law.”

No one single out of the box solution for compliance

By Chris Ayres, ISV programme & development manager EMEA, and vertical marketing manager Transport & Logistics, Zebra Technologies.

Although not complicated, there is no one single out of the box solution for compliance – retailers and manufacturers have a number of choices. The solution involves a printer, label media and labelling software, all of which can vary depending on the type of labelling system being managed.

Zebra can provide the printer; media and static labelling software, but for dynamic labelling systems, we recommend software from one of our Independent Software Vendor (ISV) partners. These ISVs specialise in labelling solutions and have products available to meet the specific requirements of regulations such as EU 1169/2011. Our ISV Partner Programme facilitates testing and integration of our hardware with ISV software, so users can be assured that the heavy lifting of integration has already been completed, and the software will run with our printers.

We believe that this regulation will have far-reaching implications for the market, and as such needs to be addressed as soon as possible. We have put together a dedicated 'food allergen' page, which outlines a full Zebra labelling solution. We also include links to our ISV Partners, to full information about the regulation, and to the EU Q & A document.

The page can be found here: http://www.zebra.com/food-allergen-labelling