Best Before date
718 views
Skip to first unread message
Rose Grant
Nov 12, 2009, 4:00:10 PM11/12/09
to cider-w...@googlegroups.com
Some of you will remember that I have mentioned being pulled up by
Trading Standards for not having a Best Before date (BBD) on my
bottled ciders. The position is confusing because although it is
something that is done by large producers like Westons, the BBD is not
often found on bottles of craft cider.
A BBD is not required on a bottle of wine. Looking at the regulations,
it is stated that a BBD is unnecessary for wine and similar drinks
made from fruit. I took this up with our local Trading Standards
Office, pointing out that cider is similar to wine and is likewise
made from fruit.
During her visit today, the Trading Standards inspector told me that
as long as each bottle carried a batch code, to allow traceability, a
BBD was not required. Hooray!
As I was able to show a record of all batches bottled this year and
examples of bottles stamped with my 4 digit batch code, all was well
on this occasion.
I can't help thinking that the BBD victory will be short lived. The
trend seems to be for more and more obligatory warnings to be added
beverage labels.
Rose
Trading Standards for not having a Best Before date (BBD) on my
bottled ciders. The position is confusing because although it is
something that is done by large producers like Westons, the BBD is not
often found on bottles of craft cider.
A BBD is not required on a bottle of wine. Looking at the regulations,
it is stated that a BBD is unnecessary for wine and similar drinks
made from fruit. I took this up with our local Trading Standards
Office, pointing out that cider is similar to wine and is likewise
made from fruit.
During her visit today, the Trading Standards inspector told me that
as long as each bottle carried a batch code, to allow traceability, a
BBD was not required. Hooray!
As I was able to show a record of all batches bottled this year and
examples of bottles stamped with my 4 digit batch code, all was well
on this occasion.
I can't help thinking that the BBD victory will be short lived. The
trend seems to be for more and more obligatory warnings to be added
beverage labels.
Rose
Nick Bradstock
Nov 13, 2009, 9:18:41 AM11/13/09
to cider-w...@googlegroups.com
Dear All
The current position on this sort of thing, as understood by NACM, is below
(although I can't cite sources or legal references from memory and E&OE!)
For more legal input and some helpful general and specific guidance on these
matters, try
http://www.food.gov.uk/foodindustry/guidancenotes/labelregsguidance/
1. Ingredients list
All alcoholic beverages are exempt from carrying this. The EU regularly
seeks to update the Directive so as to require Member States to amend their
national regulations to require ingredients lists for ABs - and an attempt
is being made even now - but the wine (of fresh grapes) lobby has so far
successfully argued that it is not necessary for wine. The other AB sectors
(beer, spirits and cider/perry/fruit wine) are prepared to change but
believe that all should change at once - so a bit of a stalemate there in
spite of qualified majority voting in the EU COuncil. The UK could go its
own way but could not insist on imports carrying ingredients lists and so we
are waiting for direction in the form of a new Directive - but no one is
holding his or her breath.
Of course, you may do it voluntarily, as some already do, but then you must
follow the full existing requirements as enshrined in general food law.
2. QUID
Quantitative Ingredients Declarations are needed for all foods that claim
high levels of something or give emphasis to a particular inclusion - ABs
are not exempt from this even if they do not carry an ingredients list. So,
if you claim a specific variety or perhaps even show an apple on your label
you should say what % of this item has gone into your product. BUT, as far
as I'm aware, this provision is yet to be tested on a cider maker's
production and I presume that those labels that might have been examined
were deemed acceptable. This is a grey area.
3. Best Before Date
Cider and perry are not required to carry a BBD since they are accepted as
basically being best before for 2 years or more. This is a very old
provision in the Food Labelling Regs and might yet be challenged. Beer must
carry a BBD since the UK's brewers accepted that their products could not
remain best before for more than 1 year and certainly not 2 years.
4. Finally, Lot Number (or sometimes called Batch Code)
This is supplementary or even an alternative to BBD. All consumer goods
sold, and foods without exception and including ABs, must carry a code,
usually prefixed 'L' to determine a lot so that all that quantity can be
identified if recall becomes necessary - clear records must be kept
including destination on leaving the premises (this could be as simple as
eg: 'my farm shop sale'). The size of the lot (and so the likely cost of
any recall) may be determined more or less freely by the manufacturer. Some
try to keep it as small as possible - eg: a new lot every few minutes of the
output of a mega-bottling line (you may even see the BBD showing packaging
time in seconds) or the whole of one batch may be a 'lot' when batches are
separated by days or more. It's a balance between necessary control and the
cost of an economic recovery.
As I said, E&OE - this more of an awareness guide. Even local authority
TSOs may not be aware of the overall picture and will play safe by demanding
the full monty.
If you hear different, please do alert me and I will try to arrange a
definitive industry (NACM) statement from our technical committee.
Best wishes
Nick
--
You received this message because you are subscribed to the Cider Workshop
group.
To post to this group, send email to cider-w...@googlegroups.com
To unsub from this group, send email to
cider-worksho...@googlegroups.com
For more options, visit this group at
http://groups.google.com/group/cider-workshop?hl=en
The current position on this sort of thing, as understood by NACM, is below
(although I can't cite sources or legal references from memory and E&OE!)
For more legal input and some helpful general and specific guidance on these
matters, try
http://www.food.gov.uk/foodindustry/guidancenotes/labelregsguidance/
1. Ingredients list
All alcoholic beverages are exempt from carrying this. The EU regularly
seeks to update the Directive so as to require Member States to amend their
national regulations to require ingredients lists for ABs - and an attempt
is being made even now - but the wine (of fresh grapes) lobby has so far
successfully argued that it is not necessary for wine. The other AB sectors
(beer, spirits and cider/perry/fruit wine) are prepared to change but
believe that all should change at once - so a bit of a stalemate there in
spite of qualified majority voting in the EU COuncil. The UK could go its
own way but could not insist on imports carrying ingredients lists and so we
are waiting for direction in the form of a new Directive - but no one is
holding his or her breath.
Of course, you may do it voluntarily, as some already do, but then you must
follow the full existing requirements as enshrined in general food law.
2. QUID
Quantitative Ingredients Declarations are needed for all foods that claim
high levels of something or give emphasis to a particular inclusion - ABs
are not exempt from this even if they do not carry an ingredients list. So,
if you claim a specific variety or perhaps even show an apple on your label
you should say what % of this item has gone into your product. BUT, as far
as I'm aware, this provision is yet to be tested on a cider maker's
production and I presume that those labels that might have been examined
were deemed acceptable. This is a grey area.
3. Best Before Date
Cider and perry are not required to carry a BBD since they are accepted as
basically being best before for 2 years or more. This is a very old
provision in the Food Labelling Regs and might yet be challenged. Beer must
carry a BBD since the UK's brewers accepted that their products could not
remain best before for more than 1 year and certainly not 2 years.
4. Finally, Lot Number (or sometimes called Batch Code)
This is supplementary or even an alternative to BBD. All consumer goods
sold, and foods without exception and including ABs, must carry a code,
usually prefixed 'L' to determine a lot so that all that quantity can be
identified if recall becomes necessary - clear records must be kept
including destination on leaving the premises (this could be as simple as
eg: 'my farm shop sale'). The size of the lot (and so the likely cost of
any recall) may be determined more or less freely by the manufacturer. Some
try to keep it as small as possible - eg: a new lot every few minutes of the
output of a mega-bottling line (you may even see the BBD showing packaging
time in seconds) or the whole of one batch may be a 'lot' when batches are
separated by days or more. It's a balance between necessary control and the
cost of an economic recovery.
As I said, E&OE - this more of an awareness guide. Even local authority
TSOs may not be aware of the overall picture and will play safe by demanding
the full monty.
If you hear different, please do alert me and I will try to arrange a
definitive industry (NACM) statement from our technical committee.
Best wishes
Nick
You received this message because you are subscribed to the Cider Workshop
group.
To post to this group, send email to cider-w...@googlegroups.com
To unsub from this group, send email to
cider-worksho...@googlegroups.com
For more options, visit this group at
http://groups.google.com/group/cider-workshop?hl=en
Rose
Nov 13, 2009, 12:46:44 PM11/13/09
to Cider Workshop
Nick,
Thank you for your detailed and up to date clarification of this
confusing legislation.
It seems to me that the BBD problem I have been having, may have been
because the local trading standards were classing cider in the same
category as beer. Surely, here in Dorset they should have known that
cider is 'The wine of the West' !
Many of us at the craft level are keen to embrace ingredients
labelling, should it ever come to pass, as it will distinguish craft
cider from some of the less appley products on the market.
The existing QUID regulation is an interesting one. Presumably this
already applies if one is producing a single variety cider. I often
wonder what else is contained in bottles of single varieties such as
Dabinett, knowing that the individual juice is unsuitable to stand
alone. I usually get around the problem of acid imbalance by doing a
two variety blend and state this on the label, eg Dabinett and
Porter's Perfection. From what you have said, I should also state the
percentage of each juice in the blend.
I've taken note for next year, so as to be one step ahead of the TSO!
Rose.
On Nov 13, 2:18 pm, "Nick Bradstock" <nickbr...@btinternet.com> wrote:
> Dear All
> The current position on this sort of thing, as understood by NACM, is below
> (although I can't cite sources or legal references from memory and E&OE!)
> For more legal input and some helpful general and specific guidance on these
> matters, tryhttp://www.food.gov.uk/foodindustry/guidancenotes/labelregsguidance/
Thank you for your detailed and up to date clarification of this
confusing legislation.
It seems to me that the BBD problem I have been having, may have been
because the local trading standards were classing cider in the same
category as beer. Surely, here in Dorset they should have known that
cider is 'The wine of the West' !
Many of us at the craft level are keen to embrace ingredients
labelling, should it ever come to pass, as it will distinguish craft
cider from some of the less appley products on the market.
The existing QUID regulation is an interesting one. Presumably this
already applies if one is producing a single variety cider. I often
wonder what else is contained in bottles of single varieties such as
Dabinett, knowing that the individual juice is unsuitable to stand
alone. I usually get around the problem of acid imbalance by doing a
two variety blend and state this on the label, eg Dabinett and
Porter's Perfection. From what you have said, I should also state the
percentage of each juice in the blend.
I've taken note for next year, so as to be one step ahead of the TSO!
Rose.
On Nov 13, 2:18 pm, "Nick Bradstock" <nickbr...@btinternet.com> wrote:
> Dear All
> The current position on this sort of thing, as understood by NACM, is below
> (although I can't cite sources or legal references from memory and E&OE!)
> For more legal input and some helpful general and specific guidance on these
Reply all
Reply to author
Forward
0 new messages