What’s the latest with e-labelling for food and beverage products?

Packaging reduction strategies for food and beverage products have significant implications for product labelling. Less packaging means less space. Yet information such as ingredient listings and nutritional details must remain clear and legible. What’s more, with consumer demand for product transparency increasing, many manufacturers want to expand what they include on labels.

In this context it’s easy to see the attraction of machine-readable e-labels such as QR codes and barcodes. They allow manufacturers to provide more information than on physical labels alone, and they can also aid waste reduction. However, unless specific exemptions apply, they cannot replace physical labels in conveying mandatory information to consumers.

Several global authorities are currently modernising regulations that affect e-labelling for food and beverage products. This is a welcome development, but unless a joined-up approach is taken, it could hinder global trade and innovation. For instance, Mexico, Turkey and Russia allow the use e-labels to avoid fraud and ensure traceability in certain categories. Mexico also permits their use for complementary information or error correction on any consumable product. However, in Taiwan e-labels can be used for mandatory information when product packaging is less than 20cm2, providing the product name and expiry date is included on-pack. Meanwhile, South Korea allows their use to provide nutritional information for products other than drinking water.

Codex Alimentarius has stepped up to address this disharmony by developing core principles for food and beverage e-labelling. It recently launched an initiative to address gaps in the General Standard for the Labelling of Pre-packaged Foods (CXS 1‐1985). While the scope of this future guideline is currently unknown, the draft text is expected to be ready for discussion at the Food Labelling 47th Meeting in May 2023.

From December 2023, it will be mandatory for wine and wine products sold in the EU to inform consumers about ingredients and nutritional factors. An exemption allows the information to be made available electronically. To facilitate this, the U-Label platform was developed by the CEEV (Comité Européen des Entreprises du Vin) and SpiritsEUROPE. Consumers can now access mandatory and complementary information in their own language via an on-pack QR code. Manufacturers using the tool must ensure their e-labels do not contain any marketing information or advertisements. Further amendments may be made to these provisions as part of the delayed review of Regulation (EU) 1169/2011.

Recent crises affecting the food and beverage industry, such as supply chain issues caused by COVID-19 and the war in Ukraine, have underlined the advantages of e-label systems. They quickly enable consumers to be informed about product changes, including temporary ingredient substitutions.

EU Regulation 1169/2011 dictates that food and beverage ingredients lists must specify any oils used, so the sudden scarcity of sunflower oil last year posed a problem. In member states where e-labelling is permitted, manufacturers were able to avoid the disruption that would have been caused by redesigning and printing labels to account for alternative oils. For instance, potato product manufacturer Lamb Weston simply added ‘may contain rapeseed oil’ to affected products’ labels, along with a QR code offering additional information.

All markets require information displayed on food and beverage labels to be clear, legible and indelible. Many also specify a minimum font size and the on-pack location for mandatory information. Outside these general principles, there is scope for alternative ways to communicate with consumers.

Many innovations in this space have the potential to help reduce the use of plastic. Some governments have released regulatory decrees to promote environmentally-friendly packaging and labelling. Meanwhile, the industry is exploring technical solutions to mitigate plastic waste and pollution. PET bottles are the focus of much of this activity.

One option is to limit the size of labels. However, this can conflict with the requirements of general labelling principles surrounding clarity and legibility. South Korea’s Ministry of Environment addressed this with the introduction of amendments and revisions to its Standards, Specifications and Labelling Standards of Drinking Water and Guidelines of Separate Discard of Recyclable Resources in December 2020. The changes allow manufacturers to include mandatory information (e.g. product name, shelf life, sourced from) on a wraparound tag attached to the lid of drinking water bottles. What’s more, multipacks can carry information on the outer package or on a handle instead of on individual bottles.

In some situations, a label still needs to be affixed to individual PET bottles. However, there can be contradictory requirements, such as one regulation dictating that labels must be securely fixed when another says they must be easily removed to enable recycling. Japan’s eco-label concept aims to fulfil both requirements, with a trial product being sold in vending machines.

Including information on PET bottles through embossment or direct printing is another method gaining attention in some markets such as Argentina and Japan. This can eradicate the need for separate plastic labels or sleeves, as mandated by some governments to improve recyclability.