New rules on what’s butter and what’s not butter

The Food Safety Authority of Ireland (FSAI) has published a guidance note on the use of the term butter in the labelling and advertising of fat spreads to aid in the compliance by the food industry with relevant food law.

The ultimate aim is to ensure that consumers are not misled and that when ‘butter’ is used, it complies with the specific legislation governing its use.

The guidance document is available on and was developed in light of a complaint received by the FSAI which indicated that some fat spreads were using the term ‘butter’ in marketing materials when it was not appropriate.

According to Dr Pat O’Mahony, Chief Specialist in Food Technology, FSAI butter is defined as a churned-cream dairy product consisting primarily of milk fat, water, non-fat milk material and if necessary, salt.

Application of the following marketing conditions should ensure that fat spreads are correctly labelled and that the word ‘butter’ and derived terms are used appropriately:

  • The word ‘butter’ should not be displayed in isolation on packaging or advertising material associated with fat spreads that cannot legally be designated as ‘butter’ in line EU regulations;
  • The use or emphasis of the word ‘butter’ in phrases or sentences on the packaging or advertising of fat spreads must not mislead consumers;
  • The use of the word ‘butter’ or ‘butter preparation’ in relation to composite products must adhere to the rules set out in Commission Regulations;
  • Terms derived from the word ‘butter’ such as ‘buttery’ or ‘butterly’ amongst others should only be used on packaging or advertising associated with fat spreads if it is clear to consumers that they relate to organoleptic properties of the product, e.g. ‘buttery’ taste, ‘buttery’ flavour etc.

Specific EU legislation is in place that establishes a common organisation of the markets in agricultural products. A section of this legislation is dedicated to ‘milk and milk products’, whereby products like butter and other types of fat spread are clearly defined.

Dr O’Mahony says the legal onus is on food businesses to ensure that they are compliant with all relevant legislation so that consumers can have trust in the product they are purchasing and make informed choices using reliable information.

“It is natural that marketing specialists will use every means at their disposal to gain a competitive edge over their rivals, but this must not be achieved at the expense of consumers’ trust.

“We hope that our guidance document will assist the industry to comply with the complex legislation in this area, so that consumers can be confident that the foods they purchase and consume are accurately and truthfully described on the label or in associated advertising,” Dr O’Mahony said.