The Mandatory Information of the EU Regulation 1169/2011 on Food Information for Consumers vs. GDSN

We are currently working on a project where GDSN product data, especially those relating to the new European regulation, are being received and edited into consumer-friendly formats for an online shop. I would like to highlight this challenge in the second article of our blog series on the EU regulation No 1169/2011.

What characterises the mandatory information of the new European  regulation in relation to a real product example?

Lets recall article 9, "List of mandatory particulars" (see also http://themdmblog.blogspot.de/2013/12/eu-regulation-11692011-on-provision-of.html ):

1. The name of the food ("Product Name" in the illustration: "Double-filled biscuits with cocoa cream filling 46%".
2. The list of ingredients ("Ingredients" in the illustration): "Ingredients: flour, sugar,..."
3. Any ingredient or processing aid causing allergies or intolerances ("Allergens" in the illustration): "May contain traces of: Soy". The additional nutritional information "Suitable for vegetarians" is no mandatory declaration according to the European  regulation.
4. The quantity of certain ingredients or categories of ingredients. The product example provides here no more detailed declaration in its list of ingredients 
5. The net quantity of the food: ("Net Content" in the illustration): "400 g".
6. The date of minimum durability or the 'use by 'date ("Best Before Date" in the illustration)
7. Any special storage conditions and/or conditions of use ("Storage Instructions"in the illustration): "Protect from heat. Store in dry conditions"
8. The name or business name and address of the food business operator as well as
9. The country of origin or place of provenance where provided for ("Origin / Manufacturer" in the illustration)
10. Instructions for use (if necessary) - not relevant in case of the product example
11. With respect to beverages containing more than 1,2 % by volume of alcohol, the actual alcoholic strength by volume - not relevant in case of the product example
12. A nutrition declaration (mandatory only from 13. December 2016) ("Nutrition Info" in the illustration)

Who will be affected by the European regulation?

European  regulation applies to industry and commerce, both stationary stores and online stores.

The product example is largely European regulation compliant and therefore meets its stationary trade standards: the customer can take the product into his hands and decide on the basis of the information printed on the package whether it fits his needs.

How does the online shop get the relevant data via GDSN though?

Let's look, for example, at the allergy information on the product example: "May contain traces of : Soy". The GS1 manual for the use of GDSN for the European  regulation makes the following recommendation:

In the GDSN data model, there is the repeatable attribute group "foodAndBeveragesAllergen" with which a lot of the allergens contained in a food product can be described. 

The attributes of this group are defined as follows:

• allergenSpecificationAgency - organisation that defines the allergen information 
• allergenSpecificationName - name and version of the definition informing the transmitted allergen information 
• allergenTypeCode - code that identifies the allergen contained 
• levelOfContainment - code that specifies the amount of the allergen contained 

Using our specific example, this will look as follows (attribute = value -> explanation)

• allergenSpecificationAgency = EU -> pre-defined default referring to the recommendation 
• allergenSpecificationName = 1169/2011 -> pre-defined default  referring to the recommendation 
• allergenTypeCode = AY -> GDSN code list code "allergenTypeCode"
• levelOfContainment = MAY_CONTAIN -> GDSN code list code "Level of Containment Type Code"

In this example, the actually relevant allergen information is transmitted via the two codes "MAY_CONTAIN AY" contained in the pre-defined GDSN code lists. 
So what do these codes actually mean?
As a code of the "allergenTypeCode" code list, AY is defined as: "AY: Refers to the presence of soybeans and their derivatives in the product, as listed in as listed in the regulations specified in AllergenSpecificationAgency and AllergenSpecificationName". Or, to put it simple: "soy".

As a code of the "levelOfContainment" code list, MAY_CONTAIN is defined as: "The substance is not intentionally included, but due to shared production facilities or other reasons, the product may contain the substance". Or, to put it simple: "can contain".

How is this information contained in the GDSN Catalog Item Notification (CIN) message which any data recipient gets from the GDSN data pool? 

In our example it looks, in a highly abridged version, as follows:

What is necessary to format this for the online shop?

The task is now (in addition to the technical details of the GDSN data pool connection and transformation of the GDSN messages, which I will not look at in this article) to extract the consumer-friendly notice "Can contain traces of: soy" from the GDSN compliant product information "MAY_CONTAIN: AY".

This means that for the relevant codes of the GDSN code lists the desired text fragments must be deposited and mapped. In our example these would be text fragments for the notice if an allergen is contained ( "Level of Containment Type Code"):

• "MAY_CONTAIN" => "May contain traces of:" 
• "CONTAINS" => "Contains:"
• "FREE_FROM" => "Does not contain:"

As well as the text fragments or declarations for potentially allergy-causing substances ("Allergen Type Code") - here are some examples:

• "AX" => "gluten"
• "AY" => "soy"
• "AS" => "sesame"
• "SH" => "hazel"

Following this final text module mapping, the consumer-friendly text passages for display in the online shop can be extracted from the coded GDSN product information:

There are of course quite a few more delicacies regarding the mandatory product declarations according to the new European regulation - we will come back to them in our in our next article ...

EU Regulation 1169/2011 on Food Information for Consumers in Brief Overview

In response to different food scandals of younger history the EU issued the regulation 1169/2011 as a directive on the provision of food information to consumers.

This regulation states

• General goals, as in chapter II, article 3: “ The provision of food information shall pursue a high level of protection of consumers’ health and interests by providing a basis for final consumers to make informed choices and to make safe use of food, with particular regard to health, economic, environmental, social and ethical considerations.”.
• Basic requirements, as in chapter III, article 7: “(1) Food information shall not be misleading, … (2) Food information shall be accurate, clear and easy to understand for the consumer. …”.
• As well as responsibility for the supplied information.

         In addition the regulation contains a number of specific, detailed requirements on mandatory information, the presentation and placement on food packaging, guidelines for language used and labeling as like as lists of ingredients, additives, allergens which may cause intolerances or allergies etc.

List of mandatory particulars:

1. The name of the food;
2. The list of ingredients;
3. Any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form;
4. The quantity of certain ingredients or categories of ingredients;
5. The net quantity of the food;
6. The date of minimum durability or the ‘use by’ date;
7. Any special storage conditions and/or conditions of use;
8. The name or business name and address of the food business operator referred to in Article 8(1);
9. The country of origin or place of provenance where provided for in Article 26;
10. Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions;
11. With respect to beverages containing more than 1,2 % by volume of alcohol, the actual alcoholic strength by volume;
12. A nutrition declaration (becoming mandatory on 13^th of December 2016).

This directive affects both manufacturers and retailers. It applies to food business operators at all stages of the food chain, where their activities concern the provision of food information to consumers. Stationary shops as like as online shops. 
It becomes effective 13^th of December 2014. Thus it is only 12 month time, to learn about the requirements and get the implementation done.

How GDSN may help with these requirements is part of upcoming blog articles.

Source: REGULATION (EU) No 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 October 2011