E-labels on foods

Consumers and producers alike complain that labels on food products are hard to understand. Could the solution for crowding in too much information be an electronic label where data of interest to the consumer could be checked using a smartphone app?

How is it now?

The EU’s Food Information to Consumers Regulation (1169/2011), which has been in force for nearly two years, was designed to simplify the rules on labelling of foods so that food labels would be clear, legible and understandable for consumers. The regulation intro­duced requirements covering such aspects as the placement of information on the product, the size of the font, and the colour contrast between the characters and the background. But it is turning out to take too much time to wade through the quantity of mandatory information (such as ingredients, nutritional value and storage conditions) and additional informa­tion (such as country of origin, the natural origin of ingredients, or the absence of certain substances) to find any specific item of information. This is a clear message to the food industry: it’s not enough to provide consumers the right information—it must also be accessible.

Paper vs QR codes

Some manufacturers are testing the possibility of providing information about their products in the form of QR (quick response) codes. When consumers scan the code with their smartphone, information about the product pops up on their screen. Various applications and websites are also being launched enabling display of the properties of products in tabular form (e.g. Smart Label Technology, www.smartlabel.org), comparison of products, and searching according to specified criteria. Apps of this type particularly assist diabetics, allergy suffers and overweight people in making the optimal choice of products, and have a great influence on purchasing decisions.

Is digitisation of labels already possible?

It does not seem that Regulation 1169/2011 forecloses the introduction of electronic labelling of foods. The regulations adopts a broad understanding of food information, which covers information concerning the given food provided to the final consumer via the label, other accompanying materials, or other means, including modern tech tools or oral messages. But totally abandoning the use of paper labels in favour of e-labels could open sellers up to the charge of prevent­ing people without smartphones or the ability to obtain information via QR codes from learning about the characteristics of the product.

Electronic labels across the ocean

A debate on the possibility of providing some food information in electronic form was held this year in the United States. It was a particularly heated discussion because it concerned the duty to provide information about ingredients containing genetically modified material. Despite doubts surrounding potential difficul­ties in delivering information for example to the elderly and the disadvantaged, a compromise was reached which requires food producers to place information on product packaging concerning the presence of geneti­cally modified ingredients, but also permits producers to share this information in electronic form, accessible via QR codes. This type of solution can simplify the label on the product. This allows the consumer to review the most detailed information and allows the manufacturer to provide the information in an acces­sible form and to explain to the consumer for example what certain ingredients of the product are, where they come from, and why they are used in the product. A better understanding of the properties and ingredi­ents of products is after all the overriding goal of all labelling regulations. Digitisation of information about consumer products, including foods, therefore appears unavoidable. The question is no longer whether it will occur, but how fast and who will be the first to do so on a wide scale.

Joanna Krakowiak, Life Science and Regulatory Practice, Wardyński & Partners

The article is a part of the New Technologies Newsletter, October 2016