Yesterday, March 29, the Council of Ministers approved a royal decree law with exceptional measures on food labeling, including the National Response Plan to the consequences of the war in Ukraine. As the Ministry of Consumption already announced on the 17th, it is a temporary measure while the problem of supply of raw materials continues.
The decrease in imports of sunflower oil and other essential raw materials in the Spanish food industry, caused by the Russian invasion of Ukrainian territory, has motivated the Government to temporarily modify the labeling regulations for make it easier for companies to make reformulations limiting the possible damages to the maximum, but without this entailing risks for the consumer.
The measures announced by Consumption have already been transferred to the European Comissionwhich on March 18 endorsed the exceptional changes in food labeling and communicated the decision to all Member States, since their regulations depend on Regulation (EU) 1169/2011.
Royal Decree-Law 6/2022, of March 29, according to the BOE as an “urgent measure”, sets the conditions that companies may meet to temporarily modify their labels, while guaranteeing the transparency and complete information to the consumer. It must also be guaranteed that the new information is “easily visible to consumers and ensures clear legibility”.
Thus, it is possible to relabel the containers that have already been manufactured using overlay stickers or inkjets applied a posteriori, canceling the declaration of the ingredient that has been replaced, both in the sales name and in the list of ingredients. It is also still mandatory to indicate the possible presence of allergens, if any.
The measure also contemplates that the operator can complement these changes with Additional Information to avoid doubts or consumer confusion, adding complementary supports such as a QR code, web pages or physical signage at the point of sale, always as a complement to the modified label, which in no case may replace it.
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