Product packaging and labelling have grown in importance as an effective marketing tool for attracting customers. Craig Murrell, Agri Enterprises’ head of advisory services, shares his expertise on the importance of understanding the South African food law and the essentials to put on your packaging as a manufacturer.
Product packaging refers to the physical materials used to wrap or protect goods, whereas product labels are placed on the product package to convey information such as the product’s maker, date of manufacturing, expiry date, ingredients, how to use the product, and how to handle it.
Consumers’ primary point of access to information about the food they consume is printed on the food packaging. It’s onerous to make consumers have to further research the food they are consuming, and sometimes impossible to determine the composition of nutrients in the food they are eating.
So, if you are looking into becoming a agri-processor, there are certain regulations you have to adhere to when it comes to food packaging and labelling.
Understanding South African food law
Specific labelling requirements for food products are outlined in the Foodstuffs, Cosmetics and Disinfectants (FCD) Act (Act No. 54 of 1972) (No. R146) and the regulations created in accordance with it. These standards are part of South African food legislation. The laws and regulations are connected to one another. For instance, the Consumer Protection Act (2008)’s labelling part is based on or relates to the FCD.
“The FCD is currently being amended by an act that is open to public comment. These are the Regulations Relating to the Labelling and Advertising of Foodstuffs Act (RRLAF). The RRLAF reinforces some basic requirements like ingredient lists, allergen warnings and nutritional tables, as well as introduces lots of changes for food naming descriptions,” he says.
Murrell makes reference that you will see the croissant nutritive info on the outer bag of Woolies croissants but not on each individually packaged croissant. This is all per the Consumer Protection Act (2008).
At the end of the day, food labelling encourages public access to information about the foods consumed by customers, however, food safety responsibility is transferred to the point of sale.
Food labelling has forbidden materials to ensure food safety (for example, lead-free and mercury-free ink must be used when printing on food labels), as all packaging and labelling must be HACCP (hazard analysis and critical control points) 22001 food contact safe.
It is the labeller’s responsibility to guarantee that labelling is done in line with the law and, if it is not, the labeller will be penalised.
What is compulsory to have on a label and why?
According to Murrell, the labelling must be unambiguous and not confusing or misleading to customers. Food labelling must be clear. The nutritional content of food, as well as a list of ingredients and an allergen warning, must be posted on the food’s outermost packaging.
The following must be clear:
- Name and physical address: The label must include the name and physical address of the manufacturer, packer, distributor, or importer of the food product.
- List of ingredients: The label must list all ingredients used in the product, in descending order of predominance by weight. This list must be accurate and not misleading.
- Nutritional information: The label must include a nutritional information table, which provides information on the energy, protein, carbohydrate, fat, and other nutrient content of the product.
- Allergen information: The label must indicate if the product contains any allergens, such as gluten, dairy, eggs or nuts.
- Date marking: The label must include a date marking to indicate the shelf life or expiry date of the product.
- Country of origin: The label must indicate the country of origin of the food product if it is imported.
- Health claims: Any health or nutritional claims made on the label must be truthful, accurate, and not misleading.
- Language: The label must be in one of the official languages of South Africa and must be clear and easy to understand.
“These labelling requirements apply to all food products sold in South Africa, whether they are locally produced or imported. Failure to comply with these requirements can result in legal action and penalties,” he explains.
Final words of advice
He adds that the fundamental needs remain the same. The RRLAD Act would require that claims such as “grass-fed,” “free range”, and “Karoo lamb” be tied to a specific process that has been approved or registered with the department of agriculture. This is done to reduce customer misunderstanding caused by labelling that is purposely deceptive.
- Do your homework first. Read the proposed RRLAF Act, which amends the FCD Act. Or look at a summary online especially if you want to produce new-age agro-processing.
- Products like no-meat patties. You will not be allowed to call it “no-meat”, because unless the patty has at least 25% meat in it, the word “meat” cannot be used in the item description. This comes from a rule that you cannot refer to a product unless your product is made up of at least 25% of the product you are referring (or not referring) to.
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