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Guidance on Food Labelling Challenges Caused by the Crisis in Ukraine and Russia

Friday, 25 March 2022

Due to the current crisis in Ukraine and the sanctions on Russia and Belarus, the Food Safety Authority of Ireland (FSAI) is aware that food business operators (FBOs) may be experiencing difficulties regarding the supply of some foods, in particular, sunflower oil, but also other raw materials and ingredients used for the production of certain foods. This may result in FBOs having to omit or substitute certain ingredients or change the manufacturing process or recipe, at short notice.

The need to quickly switch to other ingredient(s) in some cases may prevent FBOs from fully complying with all food labelling requirements under Regulation (EU) No 1169/2011, and in particular, the specific requirements regarding the list of ingredients, the nutrition declaration or the country-of-origin indications.

Guidance for FBOs on the food labelling flexibility has been prepared by the FSAI. The flexibility permits the use of additional stickers or inkjet printing to be over labelled on existing food labels.

The guidance also advises FBOs to discuss the situation with their food inspector before placing products or ingredients with additional over labels or inkjet printing on the market. It also reminds FBOs to keep traceability records and update HACCP plans where ingredients have been substituted.

Guidance on food labelling challenges caused by the crisis in Ukraine and Russia