How is the process of informing the consumer about a change in the composition of the product? According to the legislation, it is allowed to use a sticker that will be glued on top of the package, where the current information about the composition is indicated. From a legal point of view, what is more powerful - a sticker with all the mandatory points on it, or the packaging?
The proper way to inform consumers about a change in the composition of food products, as well as about a change in other characteristics, is their relabeling.
Currently, the current legislation of Ukraine does not provide for a clear procedure for relabeling products.
Despite this, the Law of Ukraine "On Information for Consumers Regarding Food Products" stipulates the obligation of business entities to ensure the availability and accuracy of information about food products.
Yes, there must be information about the food product accurate, reliable and understandable for the consumer. At the same time, mandatory information about prepackaged food products must be included directly on the package or label, attached to it.
When carrying out relabeling, it is necessary to comply with all the above requirements.
For example, in the Procedure for marking and packing seed batches and the form of the label approved by the order of the Ministry of Agrarian Policy and Food of Ukraine No. 348 of 10.07.2017, it is reported that in the case of repackaging/relabeling of products, the previous label and seals are removed, and a new label is affixed instead.
Therefore, if the composition of the food product has changed, then the label (sticker) with the new composition of the product must be pasted on top of the already outdated information indicated on the package, so that the information for the consumer is clear and he cannot confuse it.
If it is not possible to replace all outdated information with a new one, then the new label (sticker) must clearly inform the consumer about the need to pay attention to this particular label, as it reflects the current composition of the food product.
Note! During the period of martial law, mandatory information on the labeling of a food product may differ from the actual composition of this product. At the same time, the manufacturer must, in any possible way, inform the consumer about the presence of substances in the food product that can cause allergic reactions or intolerance.
The original article is published in the publication Quality management
