National authorities have issued a range of guidance because of the conflict in Ukraine affecting the food supply chain.
The Food Safety Authority of Ireland (FSAI) said it was aware that businesses may be having difficulties with the supply of some foods such as sunflower oil and other raw materials plus ingredients used to produce certain foods. The EU requires the type of oil used in products to be indicated.
The crisis in Ukraine and sanctions on Russia and Belarus, is resulting in food companies having to omit or substitute certain ingredients or change the manufacturing process or recipe, at short notice.
Regulatory agency guidance
A need to quickly switch ingredients could mean firms may not be able to comply with EU food labelling rules in regulation 1169/2011, and the requirements on the list of ingredients, nutrition declaration or country-of-origin indications.
FSAI is allowing use of additional stickers or inkjet printing to be put over existing food labels. Guidance reminds firms to keep traceability records and update HACCP plans where ingredients have been substituted.
Food Standards Scotland and the Food Standards Agency said that some products labeled as containing sunflower oil may instead contain refined rapeseed oil.
Most of the UK’s sunflower oil comes from Ukraine with Russia making up a substantial portion of the rest. Firms are reporting that supplies of sunflower oil are likely to run out in a few weeks.
Some food manufacturers have replaced sunflower oil with refined rapeseed oil before being able to make the change on the label.
Emily Miles, FSA chief executive, said the agency has been trying to understand the interim measures needed to make sure foods like crisps, breaded fish, frozen vegetables and chips remain on sale.
“We have looked at the immediate food safety risk of substituting sunflower oil with refined rapeseed oil — particularly to people with a food allergy – -and it is very low. We know allergic reactions to rapeseed oil are very rare and — if they do occur — are mild.”
Andrea Martinez-Inchausti, deputy director of food at the British Retail Consortium, said: “Where sunflower oil exists as an ingredient in products, retailers will be substituting it with other safe oils, such as rapeseed oil. Retailers are looking to change product labels as soon as possible; where sunflower oil is a key ingredient, such as crisps, retailers will imprint information on substitute oil onto existing labels.”
EU countries act
Sunflower oil has also been replaced by palm oil, soybean oil and rapeseed oil, according to FEDIOL, the EU vegetable oil and protein meal industry association.
Another issue is sourcing imports from other countries being hampered by stricter Maximum Residue Levels (MRLs) in the EU compared to these countries or Codex limits. However, member states that face acute shortages can set temporary national MRLs.
Spain is one of a number of European countries that have introduced temporary measures. The Swedish Food Agency (Livsmedelsverket) said companies that need to make quick changes should be able to use pre-printed packaging without modifying the label, until it runs out.
But they have to show the shortage is due to what is going on in Ukraine, that substitute ingredients cannot cause allergies, incorrectly labeled packaging is replaced as soon as possible, and consumers should be informed in another way.
In Denmark, problems have arisen for companies with the supply of items including flaxseed, sunflower oil and lectin.
The Danish Veterinary and Food Administration (Fødevarestyrelsen) has temporarily accepted that until already printed packaging is used up, some of the labels may be incorrect. This is conditional on the legislation around allergens being complied with and consumers are not misled.
There is no requirement to put a sign in shops with the change of the ingredient list on a given food. However, in cases where the change is judged to be “significant,” it may be necessary to put up a notice to avoid misleading consumers. Food producers are responsible for this assessment.
The Finnish Food Agency (Ruokavirasto) said companies must report changes in ingredients and substitute raw materials on their website and provide information to the trade. Written records of affected food must also be kept separately as part of self-monitoring. Measures will remain in force until Sept. 30, 2022.
The EU Commission believes food security in the region is not at stake but prices will increase and is against countries protecting domestic supply with export restrictions or bans.
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