On 11 March, the Italian Ministry of Economic Development (MISE) published a note containing exceptional temporary measures on the labeling of products containing vegetable oil to replace sunflower oil.
Following the conflict in Ukraine –which holds 60% of production and 75% of exports and is the largest sunflower grower in the world– it is possible that this oil will no longer be available and companies will therefore have to reformulate their products.
As is well known, this oil is the essential basis of many food products and many labels and packaging ordered and used by the companies list “sunflower oil” among the ingredients.
In compliance with the safety and correct information of consumers, the Italian Ministry allows producers –temporarily and in view of the progressive adaptation of the labels– to introduce a sentence indicating which oils and / or fats have been used to replace sunflower oil, indicating the possible presence of allergens (through ink or other equivalent systems such as stickers).
In addition, claims indicating the presence or absence of certain vegetable oils or comparative claims, in the case of replacement of sunflower oil, must be appropriately amended possibly through additional labeling or other similar methods to ensure correct information for consumers. Retailers will have to resort to suitable tools aimed at promptly informing the consumer about the possible replacement of sunflower oil by means of notices in the points of sale with special signs, placed in a clearly visible way, near the shelves of products containing sunflower oil. In the future, the Ministry will announce further information to be included in other communication channels (social networks, company websites).
Furthermore, taking into account the possible persistence of uncertainties in terms of the supply of vegetable oils and fats, for the printing of new labels –on a transitional basis and always indicating the possible presence of allergens– the generic term of the vegetable oils and fats category followed by plant origins potentially present, in consideration of the supplies available, e.g. “Vegetable oils and fats (sunflower, palm, corn, soy, etc.)” can be found in the list of ingredients.
The services of the European Commission will be interested as for this aspect. In the absence of harmonized provisions by the Commission, this note is valid for the national market only.
Other European authorities are also evaluating and starting to publish notes and indications on the subject. For example, with a note dated 17 March 2022 Spanish authorities allowed food operators to enter updated information on which oils and / or fats have been used to replace sunflower oil, indicating the possible presence of allergens, by means of labels or stickers, ink printing or other equivalent systems. The spirit and purpose of all these notes always focuses on avoiding misleading communication for the consumer.
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