Labelling of small packages and bulk stock
Must small packages and bulk stock comply with the same labelling requirements as for other foodstuffs? If not, what must they have on their labels?
The regulations relating to labelling and advertising of foodstuffs (R. 146/2010) state the following:
Small packages:
Pre-packed foods that have a total exterior area of 2 000mm2 or less (including single, once-off-use, 10g-or-less-sized packages of herbs and spices) need only the following to appear on the label:
- Product name
- Address of the manufacturer
- Date marking
- Declaration of common allergens (if applicable; the rest of the ingredient list is not required)
- Declaration of irradiation (if applicable)
Bulk stock:
‘Bulk stock’ means either a container that is used to display several individual units suitable for sale by themselves, or several units which are pre-packed or wrapped for the purpose of bulk sales, or foodstuffs that are offered for sale to consumers in a quantity of the consumer’s choice from a large-scale container.
If a food is sold from bulk stock and the contents are NOT individually labelled:
The bulk stock container must be labelled in accordance with all the labelling requirements for individually packed foodstuffs; and the lettering must be of such a size and so displayed that it is easily legible.
If a food is sold from a bulk stock container and only the contents are sold and are individually labelled:
The outer container need not contain all the information required for labelling purposes.
Where a food is sold in a bulk container other than by retail (whether the individual units are labelled or not), e.g. to the catering industry:
All particulars required to appear on the label of a pre-packed foodstuff shall accompany the product in the relevant trade documents, i.e. they do not need to appear on the container. ‘Trade documents’ are not defined, but can include a product information file or product specification; however, you must make sure that it contains all the relevant information that would normally appear on a food label.
Important notes:
- All other pre-packed foodstuffs, even if not sold to the consumer, must be fully compliant with the labelling requirements of R. 146.
- There are specific foods that are exempt from the labelling requirements under R. 146 – see the exemptions under regulation 54.
- The above exemptions for small packages and bulk stock are only applicable to products that fall only under R. 146. If the product is also required to comply with other departments, such as DALRRD and DTIC, then it must comply with all the labelling requirements stated in the regulations, specifications and standards for those departments.
As a general rule of thumb, any packaging which the consumer will be purchasing (including a bulk container) must comply fully with the information that R. 146 requires on the label. You will find our infographic on the minimum labelling requirements useful. If you are unsure what information your food label must contain, please contact our Regulatory Team to assist.
To view the full reference list of this article, please contact us.
Other articles, resources and videos you may be interested in:
Minimum labelling infographic
What to keep on file, according to R. 146
South Africa’s Regulatory Framework
Distinguishing date markings