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Updated Guidance on Food Labelling Challenges Caused by the Crisis in Ukraine

Friday, 22 July 2022

The FSAI has published revised guidance on food labelling flexibility in response to the challenges caused by the ongoing crisis in Ukraine and the sanctions on Russia and Belarus. The FSAI is aware that food businesses are continuing to experience 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 food businesses 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 present difficulties for food businesses in 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.

In March 2022, the EU Commission recognised that some flexibility in the implementation of certain labelling requirements may be necessary, and this flexibility could be applied by individual competent authorities on a case-by-case basis. The FSAI, in consultation with Government published initial guidance on food labelling challenges caused by the crisis in Ukraine and Russia on 25 March 2022, outlining the flexibility in terms of labelling of food. Since then, the FSAI has carried out a survey of the food industry to consider the extent of the ongoing labelling challenges faced by food businesses and following further consultation with Government and the food inspectorate, has reviewed and revised the guidance on labelling flexibility.

The revised guidance offers two flexibility options of over-labelling or inkjet printing; and front-of-pack stickers. These options will ensure that consumers can clearly access accurate information when an ingredient has been substituted. These options will not be sufficient on their own where a new ingredient introduces an allergen. There are several other exclusions listed in the guidance where the flexibility options are not suitable or where there are additional obligations on food businesses. The flexibility options are permitted for a period of six months, subject to any changes/updates. It is expected that food businesses will revert to normal labelling practices as soon as possible.

The FSAI will continue to monitor and review the situation, considering any future issues with the supply of additional ingredients, in line with any further advice from the European Commission. This guidance will be updated as necessary and food businesses should continue to check the FSAI news alerts.  

Updated Guidance on Food Labelling Challenges Caused by the Crisis in Ukraine