Regulation For Food Labeling

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Informed consent is a requirement for the conclusion of every contract including the contract that a person enters into with the seller of the food product by purchasing the said product due to which food labels play an important role for the purchase and sale of any food product. Food labels provide information which helps the consumer to make an informed decision about their purchase. The information provided on the food label include the directions of use and storage to ensure the safe and healthy wellbeing of the consumer, the consumer is able to decide on his purchase according to his dietary requirements which further adds to the satisfaction of the consumer.

The United Arab Emirates through its Ministerial Decision no. 26 of 1984 of the implementing regulation to the federal law no. 4 of 1979 concerning quashing adulteration and fraud in commercial transactions (hereinafter referred to as 'the implementing law') has provided us with the regulations regarding the food labeling on the food packaging. The implementing law defines labels as any statement, clarification, mark or descriptive article whether pictorial, written, printed, affixed or engraved on the package of a product or connected to it. These labels are sometimes also referred to as 'Illustrative Information'. The term 'package' for the present regulation means any form or shape by which the food product is packaged to be sold as an independent unit whether containing whole or in parts. This definition of 'package' also includes wraps and envelopes. The term 'packaged' used here refers to anything packaged in advance to be sold by the retail in packages.

The regulations provided by the implementing law with regards to the information to be included and the manner in which it is to be included are enlisted below:

1. The first and the most important rule regarding the labeling is that it should display only the true information and should in no way mislead the consumers in thinking the product to be some other product or misinform them about the attribute and characteristics of the said product or even the origin and source of the product. Such practices of misleading are considered as a fraud and are penalized by law.

2. The information included on the label must be clear and conspicuous so that the consumer may easily avail it.

3. The information that is hidden through some painted, written or printed material is not considered to be provided.

4. The information should be written in a color so different from the color of the background on which it is printed that the consumer may read it with ease.

5. The print of the information should be with a material that cannot be easily removed.

6. The name of the food product must be written in alphabetical letters of a reasonable size comparing to other information specified on the label.

7. In case the package is covered by an external wrap, this wrap must bear all the necessary information, and it must not cover the label of the package or preclude from reading its information with ease.

8. In case the food products contain any animal derivatives such as gelatin, fat, meat, enzymes etc., a clear mention of the sane should be included on the label with details regarding the name and type of animals from which such substances are extracted .

9. The products containing alcohol are to have an indication in that regards.

10. If the food product is to be used for specific conditions, the same should be mentioned on the label. Eg: sugar produced for diabetic patients should have the same mentioned on the label.

11. Products containing nutrients such as vitamins and minerals must have detailed information regarding the kinds and quantities of the nutrients available per unit of the product and also if such products are to be used for special purposes then the suitability for the use is also to be provided.

12. Food products processed through ionizing radiation must have the same mentioned on the label.

13. A general name describing the product must be mentioned on the label. The name must be such that it tells the consumer what the products actually is and it should not mislead the consumers in believing the product to be something else.

14. It is required to write on the label a listing of ingredients of the food product arranged in descending order pursuant to the proportion of each except for the following instances:

a) If the food product is dried and provided to be prepared by adding water, it is allowed to arrange the ingredients in descending order according to its proportion in the food product prepared after adding water under the title of "ingredients after preparation".

b) If the composition of the food product is known, and that the non – advertising of its ingredients will not contribute to mislead the consumer provided that the information specified on the label of the package shall enable the consumer to understand the nature of the food product.

c) If any of the approved standard specifications has otherwise been specified.

15. Where components of the food product may consist of several different sub-components then such sub-components are to be mentioned. The exception to this rule lies where the component is a food product that its approved standard specification does not require listing of the whole components with its sub-components.

16. Water should also be added as one the components especially where such addition provides a better understanding of the composition of the product.

17. Preservatives, bleaching, coloring or any other authorized additive substances that are present in the food product must be mentioned.

18. Instructions pertaining to storage, transportation and directions of use must be included on the label.

19. Net contents of the ingredients or components must be listed with its quantities in metric units according to its form as follows:

a) In case of liquid food products the volume must be provided.

b) In case of solid food product the weight must be provided, except for products sold by number for which the number is to be mentioned.

c) In case of sticky and semi – solid food product, either the weight or volume maybe provided.

d) In instances where the food product is inserted in a liquid that is to be discarded before usage, information of the net contents must specify the net weight of the package, and the net weight of the strained product.

20. Net contents in metric unit for foods shall be provided according to the following:

a) In case of frozen food products, the net weight or volume must be decided at freezing point.

b) In case of refrigerated food products, the net weight or volume must be specified at degree of temperature 4ƒ.

c) In case of preserved food product, the net weight or volume shall be specified at degree of temperature 20ƒ.

21. Information regarding the source and origin of the product must be specifically and clearly provided.

22. The production, manufacture, packaging and Expiration date of the product is to be mentioned.

23. The labeling may be in several languages ​​but one of the languages ​​has to be Arabic and the information provided in other languages ​​has to conform to the information provided in Arabic.

Production and sale of products that do not conform to the above regulations of labeling may be penalized with a term of imprisonment or fine or both of the penalties. In case of import, products without such labeling or without the labeling in confirmation with the above guidelines are not allowed entry in the United Arab Emirates.

Both producers and consumers must keep the above in mind. Consumers have the right to take legal action against the producers if the above requirements are not met by food labels. It is advisable to consult a lawyer for filing the appropriate action before the Consumer Protection Department at the Ministry of Economy.


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