New food labelling rules: what to expect?

On December 6, 2018, the Verkhovna Rada of Ukraine adopted the Law "On Information for Consumers on Food Products" which provides for more stringent rules for labelling food products (including dietary supplements and baby food products).

The new Law will apply to business operators on the food market at all links of the food chain (beginning from the manufacturer and ending with actors distributing food products to the final consumers).

In particular, the Law provides for new requirements regarding:

• size of the font placed on the label;
• placing of information about the food product;
• the name of the food product (for example, the food product must have an official name if it is established by law or a common name);
• conditions indicating the list of ingredients and methods of food processing (in particular, the mandatory requirement to specify the full list of ingredients and highlight allergens in a different font, size or colour);
• specification of the quantitative content of ingredients;
• expiration date (the minimum expiry date or "best before" mark and the date of freezing for the foods concerned must be indicated);
• information on the nutritional value of food products (expanded as a list of information to be indicated on the label as well as a list of products for which the requirement to indicate the nutritional value is not mandatory. For example, labelling of dietary supplements may not include information on the nutritional value).

The Law also strengthens the responsibility of market operators for violation of labelling rules and/or not providing consumer with information about the food product.

The Law comes into force 6 months after its publication and contains a transitional period which provides that foods which do not comply with the requirements of the new Law may be produced and/or approach the market within three years after the Law became effective. Such foods may remain in circulation till the end date of consumption or expiration date.

In spite of a long transition period, let’s not put off till tomorrow what can be started today.

Contact the author: Nataliia Abramovych, associate of Legal Alliance Company, abramovych@l-a.com.ua