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UK Voluntary Health Labelling Scheme

The Portman Group has revised its guidance for voluntary health information labelling following the amended guidelines issued by the UK Government Chief Medical Officers (CMO) in 2016.  The new guidance can be found here, as can examples of the new recommended pictograms and wordings.

Although there is no legal requirement to provide health information or warnings on labelling in the UK, and the Portman scheme remains voluntary “best practice” guidance, the FSA (the UK Regulator) has suggested that there could be a legal sanction where a producer continues to label its products, albeit voluntarily, in accordance with the old guidance.  Because such labels would not accurately reflect the current CMO guidelines, the FSA considers that they could be misleading, and thus in breach of the EU Regulation on the Provision of Food Information to Consumers (Reg (EU) No 1169/2011).

The FSA has said it expects labels on higher turnover products to begin reflecting the new CMO guidelines over the next 12 months.  However:

  • the agreed transition period for introduction of new labelling will run until 31st August 2019;
  • products labelled during the transition period can be sold until stocks are exhausted;
  • the FSA has requested that where labels do continue to follow the old guidelines, enforcement officers take no enforcement action before 1st September 2019.

Except where otherwise stated, all information given and any legal opinions expressed on this website assume that English law applies.  See Conditions of use.