Labelling of Pre-Packaged Sandwiches
The aim of Warrington Borough Council’s Trading Standards Department is to ensure there is a fair trading environment for businesses in Warrington. It deals with problems which consumer’s encounter when they buy goods and services; they also advise traders on the complex issues of trading law.
As you are a producer of pre-packed sandwiches, there are certain laws with which you must comply. This leaflet sets out the law surrounding the labelling of pre-packed sandwiches.
INTRODUCTION
The Food Labelling Regulations 1996 require foods to be labelled with certain information, so consumers can compare, judge and choose between foods.
If the sandwiches are prepared at one location but sold through various other retail outlets, please read SECTION 1 of this leaflet.
If the sandwiches are made and sold on the same premises, including a vehicle or stall used by the packer, AND that premise is a non-catering establishment, please read SECTION 2 of this leaflet.
If the sandwiches are sold on the same premises they are made AND that premise is a catering establishment, please read SECTION 3 of this leaflet.
If sandwiches are sold through a vending machine on the same premises they are made, (catering or non-catering), please read SECTION 4 of this leaflet.
SECTION 1
This section applies to sandwiches, which are made up and packaged in advance, then sold through outlets, which are different to the premises where the sandwiches were made.
The sandwiches must be labelled with the following:
1. NAME
If there is a name prescribed by law for a food, then that name must be used. A list of prescribed names, which relate to potatoes, melons, fish & shellfish, can be found in Schedule 1 of The Food Labelling Regulations 1996.
If there is no name prescribed by law for a food, a customary name can be used. A customary name is one which, in time, has been accepted by consumers as the name of the food without it needing further explanation. For example salami has become a customary name in the UK.
If there is no name prescribed by law and no customary name, then the name used must be sufficiently precise to inform a purchaser as to the true nature of the food. It must also distinguish it from other products with which it may be confused.
2. INGREDIENTS
The ingredient list, headed "Ingredients", should list the ingredients in descending weight order. If a compound product is used, (one which contains more than one ingredient, e.g. mayonnaise), there are two ways it can be incorporated into the ingredients list.
a. Name the compound product, and then list the ingredients in descending weight order. For example "mayonnaise: (egg, vinegar, oil); or
b. List the ingredients of the compound product in the ingredient list, without naming the compound product.
There is no requirement to list the ingredients of a compound product if it makes up less than 25% of the finished sandwich.
All additives must be listed. An additive, which falls into the categories of colour, preservative, sweetener, emulsifier, antioxidant or flavour enhancer must be declared with the category name, followed by the additive name or serial number.
For example PRESERVATIVES (Potassium Propionate); or
PRESERVATIVES (E283).
A list of all serial numbers can be found in the accompanying leaflet "About Food Additives".
3. EXPIRY DATE
This can be either a "best before" or a "use by" date. A "use by" date is used in the case of a food which is highly perishable and is likely to constitute an immediate danger to human health after a short period. Sandwiches generally require a "use by" date.
The "best before" or "use by" date should be in the same field of vision as the other information.
4. STORAGE
Consumers must be informed of any special storage conditions. For example "Keep refrigerated".
5. IRRADIATED INGREDIENTS
Any ingredient, which has been irradiated, must be labelled in the ingredient list as "Irradiated" or "Treated with ionising radiation".
6. SWEETENERS
If any sweeteners are added to the sandwich then this must be indicated on the label.
7. MANUFACTURERS NAME & ADDRESS
The address should be sufficient to send mail to the manufacturer. Therefore just the name of the business and the postcode would be sufficient.
The above information should appear on:
The packaging; or
A label attached to the packaging; or
A label visible through the packaging; or
If the sandwiches are being supplied in bulk for serving in a restaurant, the information can be supplied on an invoice or similar document delivered before or with the food, EXCEPT for the name of the food, the expiry date and the manufacturers name & address. This information should be marked on the packaging.
The information should be:
Easy to understand; and Clearly legible; and Indelible; and Easily visible.
SECTION 2
This section refers to non-prepacked, or prepacked sandwiches which are sold on the premises where they are prepared or from a vehicle or stall used by the manufacturer; and this premises is a non-catering establishment.
The sandwiches must be labelled with the following:
1. NAME
If there is a name prescribed by law for a food, then that name must be used. A list of prescribed names, which relate to potatoes, melons, fish & shellfish, can be found in Schedule 1 of The Food Labelling Regulations 1996.
If there is no name prescribed by law for a food, a customary name can be used. A customary name is one which, in time, has been accepted by consumers as the name of the food without it ending further explanation. For example salami has become a customary name in the UK.
If there is no name prescribed by law and no customary name, then the name used must be sufficiently precise to inform a purchaser as to the true nature of the food. It must also distinguish it from other products with which it may be confused.
2. ADDITIVES
All additives must be listed. An additive, which falls into the categories of colour, preservative, sweetener, emulsifier, antioxidant or flavour enhancer must be declared with the category name, followed by the additive name or serial number.
For example PRESERVATIVES (Potassium Propionate); or PRESERVATIVES (E283).
A list of all serial numbers can be found in the accompanying leaflet "About Food Additives".
3. IRRADIATED INGREDIENTS
Any ingredient, which has been irradiated, must be labelled in the ingredient list as "Irradiated" or "Treated with ionising radiation".
The above information should appear on:
On a label attached to the food; or
On a menu, ticket or label which can easily be seen at the place where the purchaser chooses food; or
If the food is not going directly to the consumer, in commercial documents, which are guaranteed to accompany the relevant food, or are sent before or at the same time the food is delivered.
The information should be:
Easy to understand; and Clearly legible; and Indelible; and Easily visible.
SECTION 3
This section refers to non-prepacked, or prepacked sandwiches which are sold on the premises where they are prepared; and this premises is a catering establishment.
The sandwiches need only be labelled with the following:
1. IRRADIATED INGREDIENTS
Any ingredient, which has been irradiated, must be labelled in the ingredient list as "Irradiated" or "Treated with ionising radiation".
This information should appear on:
On a label attached to the food; or
On a menu, ticket or label which can easily be seen at the place where the purchaser chooses food; or
If the food is not going directly to the consumer, in commercial documents, which are guaranteed to accompany the relevant food, or are sent before or at the same time the food is delivered.
The information should be:
Easy to understand; and Clearly legible; and Indelible; and Easily visible.
SECTION 4
This section refers to non-prepacked or prepacked sandwiches, which are sold through a vending machine on the premises where they are prepared; this premises can be a catering or a non-catering establishment.
The sandwiches need to be labelled with the following:
1. NAME
If there is a name prescribed by law for a food, then that name must be used. A list of prescribed names, which relate to potatoes, melons, fish & shellfish, can be found in Schedule 1 of The Food Labelling Regulations 1996.
If there is no name prescribed by law for a food, a customary name can be used. A customary name is one which, in time, has been accepted by consumers as the name of the food without it needing further explanation. For example salami has become a customary name in the UK.
If there is no name prescribed by law and no customary name, then the name used must be sufficiently precise to inform a purchaser as to the true nature of the food. It must also distinguish it from other products with which it may be confused.
2. ADDITIVES
All additives must be listed. An additive, which falls into the categories of colour, preservative, sweetener, emulsifier, antioxidant or flavour enhancer must be declared with the category name, followed by the additive name or serial number.
For example PRESERVATIVES (Potassium Propionate); or PRESERVATIVES (E283).
A list of all serial numbers can be found in the accompanying leaflet "About Food Additives".
3. IRRADIATED INGREDIENTS
Any ingredient, which has been irradiated, must be labelled in the ingredient list as "Irradiated" or "Treated with ionising radiation".
The above information should appear on:
On a label attached to the food; or
On a menu, ticket or label which can easily be seen at the place where the purchaser chooses food; or
If the food is not going directly to the consumer, in commercial documents, which are guaranteed to accompany the relevant food, or are sent before or at the same time the food is delivered.
The information should be:
Easy to understand; and Clearly legible; and Indelible; and Easily visible.
Should you require any advice on nutritional claims or labelling, please contact the Duty Officer on 01925 442658.
If you need further advice on this, or other trading issues, please contact the Duty Officer on 01925 442658.
Should you require any advice on food hygiene issues relating to sandwich production, please contact:
Environmental Health, Palmyra House, Palmyra Square North, Warrington. WA1 1JN.
01925 442577.
environmental.health@warrington.gov.uk
Only the Courts can interpret the law with any authority.
The information contained in this guidance note is, to the best of our knowledge and ability, correct on the date of publishing. The law may change at a future date.
