The Food Safety Authority of Ireland (FSAI) has provided guidance for food business operators including the flexibility of food-labelling requirements amid challenges caused by the Russian invasion of Ukraine.
The use of additional stickers or inkjet printing labelled over existing food labels is permitted in the short term, as food business operators may have to omit or substitute certain ingredients.
Difficulties affecting the supply of certain foods, in particular sunflower oil and other raw materials and ingredients, the FSAI said, could potentially force operators to make changes at a short notice.
In some cases, this might interfere with the full compliance of food-labelling requirements under EU regulation regarding the list of ingredients, the nutrition declaration or the country-of-origin indications, the FSAI explained.
However, food business operators are advised to discuss the situation with their food inspector before making changes to labels and to keep traceability records, the FSAI added.
FSAI guidance
The FSAI’s short-term support does not cover other legal requirements of food safety and production, therefore operators must still fully comply with all other legal obligations.
Consumers’ health and safety interests must be ensured and only safe food can be placed on the market, including information on allergens and durability which must always be on the label, the FSAI added.
The placement of additional labels, however, according to the authority, must not impact the display of other mandatory information which must be visible to the consumer.
Products supplied to other food businesses should include the indication of any temporary non-compliance with EU law on the accompanying documents, the FSAI said.
Hazard Analysis and Critical Control Point (HAACP) plans must also be reviewed by operators and necessary adjustments must be made to address potential hazards where ingredients have been substituted.
The FSAI expects that food business operators will revert to normal labelling practices as soon as possible, and granted flexibility is subject to regular review in line with advice by the European Commission.