Steve Spice, Regulatory Manager from Ashbury, looks at some of the less common labelling errors prompting product recalls.
Looking back over rapid alerts in the EU’s RASFF system over the past few years, labelling issues relating to allergens declarations certainly stand out. But a food label contains many other pieces of information and recalls regarding expiry dates, traceability and language usage for example are less widely reported but still just as important for labelling compliance.
Use by dates:
Use by dates are used on highly perishable foods that could be considered unsafe after the date and constitute an immediate danger to human health. ‘October’ was recently erroneously used in place of ‘September’ on beef tartare from Italy thereby extending the use by date by a month and causing a recall. With such a long difference in date on a short shelf-life product it is easy to see why that happened. However, a far shorter extension of two days for chilled beef products from Belgium produced a similar outcome.
As required by the BRC Global Standard, routine checks on date coding should always be included as part of a quality inspection system at the beginning, end and throughout a production run to avoid mistakes with dates labelling.
The global sourcing of ingredients means that traceability throughout the supply chain is more important than ever and it is of course, a vital tool when a problem is identified. For this reason, products must, by law, carry traceability information. The absence of a lot code or an identification mark hampers traceability but there are a surprising number of rapid alerts where essential traceability information is missing from the pack: peanuts from China, frozen octopus from Peru, rice noodles from China and eggs from Spain are just a few examples.
It is a long-established foundation of the EU that goods can move freely between Member States and yet there are numerous RASFFs where this has not happened and are simply down to language errors on-pack. Mandatory food information needs to appear in a language easily understood by the consumers of that country. Hence chocolate candies sold in The Netherlands but not labelled in Dutch were subject to a rapid alert in July 2019 and there have been others relating to the wrong language being used to declare allergens.