Food labelling e-learning course
'Foreign' primary ingredients

'Foreign' primary ingredients

Label stating - Made in the UK with Australian stem ginger

The FIC requires that when the origin of a whole product is volunteered and the origin of its primary ingredient is different, information must also be given about the origin of that primary ingredient. The application of this requirement is subject to further rules, yet to be published, and so the date of its application is unclear.

This provision addresses the situation where, for instance, the origin of a meat ready meal is stated (e.g. 'produced in the UK'), but the origin of the meat is another EU Member State or a third country.

Key to this requirement is having a clear idea of what, if any, is a product's primary ingredient. This is defined in the FIC as the ingredient(s) of a food:

  • that represent more than 50% of that food or which are usually associated with the name of the food by the consumer
  • for which in most cases a quantitative indication is required ('QUID' - see Ingredients: lists, quantities and allergens module)

In a case where the provision applies, either:

  • the country of origin or the place of provenance of the primary ingredient must be given

Or

  • the origin of the primary ingredient must be indicated as being different from that of the food, e.g. 'made in the UK using fruit juices from various countries'

The provision, as it stands, applies to all products for which an origin is volunteered, but which have primary ingredient(s) from a different origin. Note, therefore, that where no whole product origin is volunteered, there is no obligation for a primary ingredient origin to be given even if it was obtained from somewhere distant from the site of final product manufacture.

The publication of a further Commission Implementing Regulation (an 'implementing act') detailing further rules is awaited and this will delay the application of this provision beyond December 2014. The Implementing Regulation may also limit the scope of the provision to particular categories of food and primary ingredients.