French guidelines on products in which an ingredient or taste is highlighted with
texts or images.
Food products can be flavored by directly adding specific ingredients and / or flavors in
different forms. Such additions must be reported clearly in the ingredient list, in the case of
a prepackaged food product.
The current legislation on the designation of food flavorings in the list of ingredients
generally leaves no room for interpretation; however, these rules may prove insufficient if
the graphic representation (photo or drawing) of an ingredient appears on the label. The
reason is simple: it can be erroneously suggested that the characterizing ingredient was
used alone in the product to give flavor, therefore without the addition of flavoring.
For this reason, the French Antitrust Authority has been publishing specific Guidelines on
the labeling of products that fall within this category, based on a stringent interpretation of
EU Regulations no. 1169/2011 and no. 1334/2008. The Guidelines provide that further
information on characterizing ingredients and flavorings must be reported on the label and
integrated into the sales name of the product to prevent the consumer from being deceived
by graphic representations. The Guidelines identify several cases that provide for the
possible combinations between product taste and flavor:
- only characterizing ingredient or with natural flavoring;
- characterizing ingredient with artificial flavoring;
- only natural flavoring;
- only artificial flavoring.
One of the cases provides that when flavoring occurs only through a natural flavoring, it is
not possible to refer directly to the flavor of the product, but it must be clearly highlighted
that the taste only derives from the flavoring. By applying this case to a strawberry-flavored
ice cream, the product name must contain the words “product flavored with” / “product with
the natural flavoring of” / “taste of” / “flavor of”. In addition, when a graphic representation
of the flavoring appears on the package, an additional wording must be added near the
image or text: “natural flavoring of” / “flavored with” / “taste of” / “flavor of”.
For each combination, the wordings to be integrated change, but it is understood that each
case must be evaluated individually according to the different characteristics of the food
label. It is therefore always better to contact an expert in case of doubts.
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Source: Direction générale de la concurrence, de la consommation et de la répression des fraudes