Friday, April 30, 2021

Food Labeling - II

Information Asymmetry
Food labeling is recognized as an effective tool to protect consumer health in terms of food safety and promote nutritional well-being. Labeling laws prevent fraud and misleading information that protects consumers. Food labels have been used to convey information about the product identity and contents traditionally while providing information on how to safely handle and prepare the food product. Nonetheless, food labels have become vehicles to inform specific food products and their health benefits in recent decades. The consumer could not detect the quality and quantity of the food through their senses of sight, smell, taste, and touch when foods were packaged in bags, boxes, bottles, cans, and wrappers. Hence, the producer has information about the product that is unknown to the consumer, which is called “information asymmetry.” The difference between sellers and buyers or the information asymmetry must be corrected to ensure that the market functions well because consumers need information about what the product is before they decide whether to purchase the product, whereby knowing the product identity, quantity, and qualities, consumers determine whether the price is satisfactory according to their needs and desires.
 
Date Marking
Date marking is one of the oldest and most widespread types of information found on food labels, whereby providing a date mark, the food manufacturer is advising subsequent food chain operators, mainly retailers, distributors, importers, and consumers, on the appropriate shelf-life of the food. Date marks are determined by the shelf-life of a product, after which time the quality or safety of the product may be compromised. As of now, date marking is a mandatory requirement on packages of perishable and semi-perishable foods and may be used on products with a long shelf-life. Date marking serves multiple purposes and is often presented in different ways on packages, which may be specific to the country or region.
 
Different terms have included, but are not limited to Use By, Best Before, Sell By, Date of Manufacture, and Date of Expiry, where the format of the label can vary as well. The date mark often includes the day, month, and year for the food products with a durability of three months or less. Retailers and food outlets use date marking information to manage stocks, and manufacturers use the information with other information on the label to trace and recall products. Hence, consumers use date marking to determine whether the food is safe to eat and if it will meet their quality expectations. If there are multiple types of date marking, there can be a misunderstanding of the label, which can lead to food waste if a consumer throws away food that could have been eaten safely even though the “best by” date has passed due to confusion. On the contrary, lack of clarity may cause consumers to take a safety risk if they eat food, which should have been discarded because the “use by” date has passed.
 
Date Marking Policy
Improvements in date marking can be made by assessing the food products found in the local market (domestic and imported), gaining feedback from food manufacturers and consumers, and by considering the requirements for food products that will be exported to other countries. Policy-makers can also gain essential guidance from Codex provisions on date marking, as well as considering approaches from other countries, where it is important to note that date marking is based on the assumption that the foods are properly stored from the time they leave the manufacturer to the time the food is served to eat. Thus, the label should outline any special storage conditions to enable the transporters, sellers, and consumers to maintain the quality of the product. In addition to the date of minimum durability, any special conditions for the storage of the food must also be declared on the label, such as ‘refrigerate after opening’ or ‘store in a cool, dry place.’ The label should contain instructions on how to use the product to enable the consumer to make appropriate use of the food, such as cooking, reheating, preparation, or reconstitution instructions or declarations such as ‘not suitable.’
 
Essential questions to be asked before designing the date marking regulations can include, but not limited to:
  • Which food products must have date marking?
  • Will the date mark be used to convey whether a food is safe to consume?
  • Will the date mark be used to inform the consumer that the quality of the food may deteriorate after the date, but it is still possible to consume the product safely?
  • What is the recommended range of date marks admissible in the country (for all foods, including imports)?
  • What should be the recommended language/terminology to present the date mark, and what is the recommended format?
  • What are importing countries’ requirements for food exports from the country?
  • How much discretion will the food manufacturer have in deciding about the type of date mark and the dates used?
  • What specific technical information is needed to determine the date marking for different categories of products?
  • What are the typical conditions for storing food in the home in the country?
  • How will the public be informed and educated about the meaning of the date mark?
  • Is research needed to understand the ways that date marking is used and understood in the country?
 
Codex date marking provisions/requirements
The Codex Alimentarius Commission updated the section on date marking in General Standard for the Labelling of Prepackaged Foods in 2016, which requires compliance with the codex standard.
  • “Date of Manufacture” means the date on which the food becomes the product as described, which is not an indication of the durability of the product.
  • “Date of Packaging” means the date on which the food is placed in the immediate container in which it will be ultimately sold, which is not an indication of the durability of the product.
  • “Best Before Date” or “Best Quality Before Date” means the date, which signifies the end of the period, under any stated storage conditions, during which the unopened product will remain fully marketable and will retain any specific qualities for which implied or express claims have been made. However, beyond the date, the food may still be acceptable for consumption.
  • “Use-by Date” or “Expiration Date” means the date which signifies the end of the period under any stated storage conditions, after which the product should not be sold or consumed due to safety and quality reasons.
  • The date shall be introduced by the words: “Use-by” or “Expiration Date” or “Best before” or “Best Quality Before” as applicable where the day is indicated; or “Use-by end” or “expiration date” or “Best before”; or “Best Quality Before” as applicable in other cases.
  • The day and year shall be declared by uncoded numbers, with the year to be denoted by 2 or 4 digits, and the month shall be declared by letters or characters or numbers. Where only numbers are used to declare the date or where the year is expressed as only two digits, the competent authority should determine whether to require the sequence of the day, month, year, be given by appropriate abbreviations accompanying the date mark (for example, DD/MM/YYYY or YYYY/DD/MM).
  • A date mark shall not be required for food if the safety is not compromised and quality does not deteriorate because of the preservative nature of the food is such that it cannot support microbial growth (for example, alcohol, salt, acidity, low water activity).
  • Besides, a date mark is not required where the deterioration is evident to the consumer, where the key/organoleptic quality aspects of the food are not lost. The food is intended to be consumed within 24 hours of its manufacture. In such cases, the “Date of Manufacture” or the “Date of Packaging” may be provided. Any special conditions for the storage of the food shall be declared on the label if where they are required to support the integrity of the food. 
 
References:
http://www.fao.org/fao-who-codexalimentarius/sh-
proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FMeetings%252FCX-714-44%252FWD%252FREP%2B16_FL%2BAPPENDIX%2BII.pdf
http://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FMeetings%252FCX-714-44%252FCRDs%252Ffl44_crd06x.pdf
https://ec.europa.eu/food/sites/food/files/safety/docs/codex_ccfl_43_cl-201430-fl_date-marking.pdf