Consumer

Innovation and substitute ingredients, what label news?

June 1, 2022

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Food innovation has reached the mass market in recent years, and it is still unclear, however, how substitute ingredients should be disclosed on the label. Insight.

Table of Contents

1) Innovation and ingredient substitution

Plant-based foods have now become part of the assortment of the biggest brands in the animal food industries-such as the giant Veronesi, most recently in Italy-and in the foodservice industry.

Foods for athletes and those that cater to various diets (e.g., keto diet, or ketogenic diet) in turn have become part of the mainstream of consumption in retail and ecommerce. (1)

Substitution of classic ingredients-e.g., meat, milk, cereals-is the distinguishing feature of products presented in ways sometimes similar to those of traditional foods.

2) Substitute ingredients and label news

‘In the case of foods in which a component or ingredient that consumers assume is normally used or naturally present has been substituted with a different component or ingredient, the labeling shall bear–in addition to the list of ingredients–the following A clear indication of the component or ingredient used for partial or complete substitution:

(a) in the vicinity of the product name, and

(b) in characters whose median part (height of x) is at least 75% of that
used for the product name‘ (EU reg. 1169/11, All. VI.A.4).

3) Transparency and fairness of information

Consumer information must be fair and transparent. To meet the criteria set out in the Food Information Regulation (EU reg. 1169/11, Articles 7 and 36), but above all to allow consumers to put their trust in the brand, without surprises.

‘Food information does not mislead, particularly (…) by suggesting, through appearance, description or illustrations, the presence of a particular food or ingredient, while in fact a naturally occurring component or ingredient normally used in that food Has been replaced with a different component or ingredient‘ (EU reg. 1169/11, Article 7.1.d).

4) Food name

The name of the food plays a crucial role in helping the consumer ditinguer its nature, composition and characteristics. (2) In all cases of
meat-sounding
,
milk-sounding
,
egg-sounding
and other substitutions of characteristic ingredients should therefore be referred to by a descriptive name, followed by appropriate specifications highlighting the specific commodity characteristics of the food. (3)

The reference to customary names that consumers associate with the presence of a characteristic ingredient (e.g., hamburger-beef, breadstick-wheat flour) may be allowed if certain essential conditions are met:

– the name of the food must describe its characteristics exactly,

– substitute ingredients must be displayed next to the name itself (see supra, para. 1),

– the information as a whole must in no way mislead the consumer (see supra, para. 3).

5) Interim Conclusions

The courage to innovate requires equal courage, as well as fairness, in communicating innovation. With facts and data-all the better if attested with innovative technologies, such as public blockchain (4)-rather than self-referentiality.

Dario Dongo