Are your food product labels compliant? Do you know which regulations apply to your products?
There are various regulations with which your product label must comply, whether the product itself is produced locally or imported from another country. The FACTS team will evaluate and provide suggestions on how to adapt your product label(s) to comply with South African legislation. If required, we will test your compliance against the regulations for the Department of Health (DoH); Department of Agriculture, Forestry and Fisheries (DAFF); and Department of Trade and Industry (DTI).
Our team of food scientists and dieticians will assist you in identifying and understanding your regulatory requirements. We have over 17 years of experience in working with South African food regulations, and can assist from the product development stage to managing any testing that may be required, all the way to label design. The services we offer include but are not limited to the following:
- The minimum information legally required on a food label, e.g. product name, address, date marking, country of origin
- Typography and layout
- Quantity indication (according to SANS 289)
- Pictorial representations
- Ingredient list, including QUID (quantitative ingredient declaration) and allergen declarations, presented in a ready-to-use format
- Acceptability of health and other claims and statements
- Nutritional information format and calculations, presented in a ready-to-use format
- Recommendations for serving-size values (with the assistance of our in-house dietician)
- Calculation of Nutrient Reference Values (NRVs)
- Requirements pertaining to DoH, DAFF or DTI regulations and specifications (including NRCS requirements) that may be applicable to your product
- Evaluation and identification of the product’s advantages; assisting with marketing and leveraging over competitor products
- Analysis of the product(s) for proof of nutritional or substance claims, and interpretation of the results within the regulatory context
- Arrange analysis of the product(s) for any content or quality aspects that are required by regulations, and interpret the results within the regulatory context
- Check compliance with additive regulations (e.g. whether the additives used are allowed for the specific product)
- Presentation of the labelling evaluation report to your company at your premises
- Regulatory audits: As part of your Consumer Assurance Programme we can develop a regulatory audit system, whereby we sample products from the shelves to be evaluated for their labelling and/or testing compliance.
FREQUENTLY ASKED QUESTIONS
WHAT IS THE PROCESS OF LABELLING EVALUATION?
Speak with one of our FACTS regulatory team to discuss your needs. This will include the scope of the South African regulations that will be consulted in the evaluation.
Send electronic copies of your labels to [email protected] (or the FACTS Team member you spoke to). The list of needs and the labels will guide us in providing you with a cost estimate. If you don’t have a label yet, we can guide you on the information that is required to be declared on the label, before you even start with your design.
A quotation will be sent to you, accompanied by an acceptance note. Please complete the acceptance note and return to [email protected] (or the FACTS Team member you spoke to).
If possible, deliver physical labels of all products being evaluated to our offices. This way, letter sizes can be evaluated accurately. During the evaluation process we may have some questions for you to answer, to enable us to do a thorough evaluation – e.g. information on the ingredients, country of origin, address, and nutritional values. If the product is required to comply with a DAFF regulation, we will send it to an Inspector for their input.
The evaluation will be presented in an easy-to-read report format which will focus on the areas of the label(s) that are in contravention with regulations. The regulations to which the contravention pertains will be quoted, and a recommended change will be suggested.
Who will be evaluating my labels?
Karen Horsburgh is a Registered Dietician with over 17 years of experience in offering regulatory services to food industry clients. In this time, she has experienced the journey of many regulations published or still in development; she has built relationships with both the regulatory authorities and the food industry; and she has gained insight into how the various regulatory authorities and their regulations interact.
Gaby Jackson is a registered dietician in private practice who assists with nutrition, health and food labelling projects, bringing a practical approach to the health aspects of food labelling.
How long will it take for my labels to be evaluated?
Once the initial deposit has been paid, FACTS will begin the project. The duration of the evaluation will depend on the number of labels, their complexity, and whether we require input from any of the regulatory bodies or from you or your suppliers.
How much does it cost? Do you have a fee per label?
Each project is individually quoted; the cost is dependent on the complexity of the labels, how many regulations must be taken into account, and whether regulatory authorities need to be consulted. There is no set fee per label.
Do you check compliance with the Department of Health labelling regulations (R. 146) only, or with other regulations too?
We are able to check any South African regulations that you would like to include in the evaluation, including DoH, DAFF and DTI (which includes NRCS).
Can I use the same label for South Africa and for export markets?
Most countries have different regulations pertaining to labelling, which makes it difficult to design one label that will fit more than one country’s requirements. You will probably need to have a label for each country you export to, depending on that country’s requirements.
Can you assist with testing our products in terms of nutritional information?
Yes – we will manage this analysis, which we will then use to create a nutritional table according to the current regulatory requirements.
Will you help us identify what claims we can make on our product label?
Yes – if requested, we can make suggestions as to what claims can be made, along with managing the analysis of the product.