Dear. Our company [name for the editors' information] produces canned and processed fish. We are preparing to comply with the provisions of EU Regulation 1163/2011, which requires us to place nutritional and energy values ​​on the packaging in a special way, for 100g and for a portion. We have already collected specifications from our suppliers and sent our own components for analysis in a laboratory and we already have the results. Now, however, we do not know what to do next. We want to avoid penalties for inconsistency of the information written on the packaging with the results of the inspection, because we have had unpleasant experiences in this regard and we know that in a confrontation between an entrepreneur and an office, the entrepreneur usually loses even if the guilt is not certain. This is a different topic, but to sum up, we have to be careful, so we are looking for confirmation.

The topic looks exactly like this: we buy fish from several large suppliers from different countries. We receive the specifications together with the delivery, and it results from them that for the same fish, of the same species and sort, some values ​​are different. The differences result from various reasons, e.g. they are related to the fishing season, they also depend on the fishing grounds or breeding. At the moment, our conclusion is, and I hope it is wrong, that in order to properly comply with the regulations, we should make several types of labels for the same product and pack it depending on the specifications sent by the supplier. But this is simply impossible, and certainly unmanageable in terms of organization and costs.

During the conversation, the lady from WIJHARS advised us to also submit the finished product for analysis in the laboratory and when we have the result, we should put it on the packaging. However, we did not explain the differences, because apparently the most important thing is to have documented results, then the differences are less important. However, no one has accepted the official position, because apparently they are only for inspection, not for advising and solving such problems. However, the problem will not be solved in this way, because if the fish we buy change the fat and protein content several times during the year, does it mean that we have to submit each product to the laboratory so many times, how many times do the composition changes? And how many times do we have to change the labels? After all, this is a straight path to bankruptcy! I don't want to think that this is what those who establish this law have in mind, but it must be somehow logically explained what to do in cases like ours? How can this problem be solved differently?

EXPERT ANSWER:

First of all, we want to reassure you. There is no need to print several types of labels. There is also no need to submit each raw material delivery for analysis to a laboratory. Fortunately, such situations as those described above have been foreseen by the Legislator. In this case, it is regulated by REGULATION (EU) NO. 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL [SECTION 3. Nutritional information. Article 31. Calculation. Point 4], which states:

The values ​​provided, as appropriate for a given case, are average values ​​based on:
a) the food analysis carried out by the manufacturer;
b) calculation based on known or actual average values ​​of the ingredients used; or
c) calculation based on generally available and accepted data.

As can be seen in the content of the Regulation, first of all, these values ​​are considered averages, so they do not need to be calculated after every slightest change in the raw material values. Secondly, three possibilities of obtaining an acceptable, and therefore correct result are indicated. One of these possibilities is to submit the products for analysis, which in the case of your company, when you have to pay for a large number of tests, is definitely pointless. Therefore, in such a situation, it is worth using one of the other two possibilities. I will discuss both of them briefly.

ad. b) Calculation based on known or actual average values ​​of the ingredients used.

Known nutritional values ​​are those provided in the specification by the supplier. Having them, you can use them in several ways:
- calculate the value of the product yourself by mathematically converting grams and % according to the formula for calculating the value, substituting the data of subsequent raw materials according to the recipe of the calculated product
- calculate yourself using the FOODCAL Nutritional Value Calculator, entering the values ​​from the specification into the Calculator (you can remember them for use in subsequent calculations)
- order a service of calculating the value for products, providing an external expert or company with your recipes along with the specifications of the raw materials

ad. c) Calculation based on generally available and accepted data.

In the case of raw materials for which there is no specification from the supplier, you can look for their value in generally available and accepted data. Such data, i.e. generally available, can be found in institutions, companies and laboratories related to the food industry. Our program FOODCAL Nutritional Value Calculator also has it. After your company's problems with previous inspections, the word "accepted" used by the Legislator will probably raise some doubts, but assuming that the data obtained from the most substantive and prestigious sources are definitely called accepted, you can be sure about the data developed by the Food Institutes associated with universities or local government. This is also the idea that guided us when creating the catalog of raw materials in our Calculator. Generally available data available in our FOODCAL Nutritional Value Calculator are obtained from such sources and directly from producers. Access to the catalog of raw materials is available immediately after logging in to the Calculator.

We hope that your doubts have been dispelled. We invite you to use our software, and in case of further questions, we will be happy to help.

Editorial Team
Nutrition Calculator FOODCAL
https://pl.nutrition-calculator.com

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