1. Scope and accuracy principle
This policy sets the internal controls for food information, allergens, composition, nutrition values and digital product content. Information must be truthful, documented, intelligible and not misleading, including through images, omissions, visual emphasis or context.
2. Product classification and legal name
Final legal classification will depend on formula, ingredients, process, presentation and intended use. The legal name of the food will be determined before launch and distinguished from fanciful names or marketing claims. The addition of vitamins does not automatically make the product a food supplement.
3. Master label and FBO responsibility
Before printing lids and multipacks, a Master Label Specification must be approved for each SKU and market, with version, date, approvers and supporting sources. The food business operator responsible for food information will be identified according to the actual supply and distribution model.
4. Mandatory food information
Where applicable to the final SKU, controls will cover at least: name of the food; ingredients; allergen emphasis; QUID; net quantity; date of minimum durability or use-by date where required; special storage/use conditions; name/business name and address of the responsible operator; origin/provenance where required; instructions for use where needed; nutrition declaration; lot and other applicable mandatory particulars.
5. Allergens and cross-contamination
Intentionally present allergens will be emphasised as required by law. Precautionary statements such as “may contain” will only follow a documented cross-contamination risk assessment and will not replace appropriate hygiene and control practices.
6. Nutrition declaration and micronutrients
Energy and mandatory nutrients will be declared in the required manner. Vitamins and minerals will only be declared where permitted and on validated values, including applicable nutrient reference values and tolerances. Formulation must also consider stability, process losses and content at end of shelf life.
7. Nutrition and health claims
No statement such as “source of”, “high in”, “energy”, “defences”, “growth”, “concentration” or equivalent may be published merely because it sounds plausible. Every claim must be entered in the approval matrix with exact wording, legal basis, conditions of use, evidence, SKU, portion, language, market and authorised media.
8. Distance selling and online product pages
If e-commerce or other distance selling is activated, the required mandatory food information will be made available before purchase in accordance with applicable law; required information must also accompany the product at delivery. Online product pages will be synchronised with the current Master Label.
9. Images, fruit and visual representations
Photos, renders and illustrations of fruit, vegetables or other ingredients must not create a false impression of composition, quantity, nature or actual presence of ingredients. Concept visuals will remain identified as such until recipe and packaging are finally approved.
10. Language, legibility and markets
Mandatory information will be provided in a language easily understood by consumers in the target market, with legibility and presentation requirements checked on the actual packaging. Commercial translation does not replace local legal/regulatory validation.
11. Packaging, environment and food-contact materials
Cup, lid, inks, adhesives and materials intended for direct or indirect food contact will be supported by the applicable food-contact documentation. Environmental and disposal information will be defined market by market based on current rules and the actual material composition.
12. Change control and withdrawal of obsolete content
Any change to formula, supplier, process, serving size, packaging, claim or market must trigger review of labels and digital content. Superseded versions must be withdrawn from the website, catalogues, marketplaces and trade materials under a documented process.
Main legal references
Regulations (EC) 178/2002, 852/2004, 1924/2006, 1925/2006 and 1935/2004; Regulation (EU) 1169/2011; Regulation (EU) 10/2011 where applicable; and relevant EU/national rules governing ingredients, additives, flavourings, materials and packaging.