Food producers, regardless of whether it is packaged or not, are most often controlled by two institutions: SANEPID and IJHAR-S, or the Agricultural and Food Quality Inspection. The entry into force of new regulations and obligations imposed on the food industry by EU Regulation 1169/2011 will probably result in increased control of compliance with the new regulations. How to prepare for this?

How to prepare for a Sanpid and IJHARS inspection?

The subject of the inspection was bound to come up sooner or later. In fact, questions about documentation and ways to smoothly pass the Sanpid and IJHARS inspections have been appearing since the beginning of 2015. The news that significant changes are taking place in the labeling of food products has caused considerable dissatisfaction among producers, because they ultimately lead to the replacement of packaging and labels, and thus additional costs. In particular, there is concern about the new obligation to inform customers about nutritional and energy values. The most common questions from food producers are:

How to prove the correctness of the calculations of nutritional values?

What if there is a discrepancy between the values ​​given on the label and the results of the laboratory inspection?

We will now try to answer both questions, and also analyze hypothetical situations that may occur during the inspection. We will also devote some space to discussing the documentation regarding the nutritional value for the Sanpid and IJHARS inspections.

How to prove the correctness of the calculations of nutritional values?

This is the simplest thing. It has long been known that in all situations when something needs to be proven, the best evidence is hard evidence in the form of documents.

Unfortunately, an entrepreneur who calculates nutritional values ​​himself, without creating reliable documentation, is in a losing position. He simply exposes himself unnecessarily to further investigations by inspectors.

For example, bakers have a habit of calculating everything in a notebook. They have recipes written down there, they calculate the amounts of raw materials for baking there, and they also calculate nutritional values ​​there. Will they give their notebook to inspectors? Will the inspectors recognize the credibility of such handwritten calculations, from which various erroneous conclusions can be drawn at first glance? Probably not, and with a high degree of probability it can be said that it is tempting to take the product to the laboratory and compare the results with the notebook.

Let's imagine a different situation, however. The inspectors receive a package of documents from the entrepreneur (e.g. the baker described above) which includes: a professional REPORT in the form of a printout of a table of the product's nutritional value together with the composition of the recipe, which includes:
1. Product name
2. Raw materials and their share in the product, i.e. the composition of the recipe
3. Information on the loss or increase in mass as a result of the production process
4. Nutritional and energy values ​​presented in accordance with the Regulation
5. Results for 100g and for a portion
6. Other information depending on the needs
and to this is attached an additional Certificate with a guarantee of correct calculations and compliance with the regulations and a Quality Policy document. Can this be received better by the inspectors than a notebook with notes?

Such a Certificate and Report can be printed by users of the Nutrition Calculator FOODCAL program calculating nutritional values, which is the only program for the food industry providing comprehensive support for the needs of food producers in terms of fulfilling the requirements of EU Regulation 1169/2011.

It should be added that, of course, reports from analyses in external laboratories give an equally professional impression and similar certainty, but on condition that the laboratory is accredited, i.e. has been checked for its capabilities ensuring the reliability of analyses. However, analysis in the laboratory is the most expensive way to obtain the data required by law, and in addition, the waiting time for the result is several weeks. Fortunately, EU Regulation 1169/2011 allows 3 equivalent ways to obtain nutritional value results, of which calculating the values ​​with the FOODCAL Nutritional Value Calculator is included in as many as two permitted methods. For the sake of order, let us refer to the Regulation (Article 31, point 4), where it is formulated as follows:

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.

So we can see that the manufacturer has every right to use the nutritional value of raw materials to calculate them in the FOODCAL Calculator if he knows them, or if he does not know the value of raw materials, he can download their data from the Raw Materials Catalog available in the FOODCAL Calculator as generally available and accepted.

What if there is a discrepancy between the values ​​given on the label and the results of the laboratory control test?

This is a slightly more complex topic and perhaps in accordance with the strange Polish law, which theoretically has a consistent interpretation of the law, but there are different interpretations of the regulations by institutions, there will be situations when the decisions of inspectors from one province will be different from the decisions from another province, as is the case with decisions of the Tax Offices. However, being constantly on the subject and having contact with employees of both institutions, i.e. Sanpid and IJHAR-S, we already have certain conclusions that generally calm the atmosphere around the discrepancies, especially if the provisions of the Regulation are treated literally, i.e. exactly as they are written.

Firstly, the Legislator clearly speaks in the regulations about AVERAGE VALUES. So it is assumed from the outset that there are situations in food production when the seasonality of raw materials, the origin of raw materials, production processes and other factors may affect the nutritional value of the entire product, which is why it is permissible to state them as averages. For example, seasonal changes in the fat content of fish described in the article "Calculation of nutritional values ​​in fish processing taking into account changes in the fat content of fish" or similar problems with changing values ​​of vegetables in salads depending on the season described in the article "How to calculate the nutritional values ​​for seasonal vegetable salads?"

So if the raw materials themselves have fluctuations in their values ​​during the year, even several times, their average value should be used for calculations, and the result for the product itself can also be given as an average. For such recipes, a difference can clearly be found during a laboratory control, and practically every laboratory analysis performed on a different batch of the product can give different results. In such a case, the most important thing is that the label contains values ​​that will differ from the control result within the norm. These standards are also given in the Regulation and we will discuss them in a separate article. But the most important thing is that the entrepreneur - the producer, at the time of the control, can prove that he had grounds to provide nutritional values ​​in this way. So in this situation, factual documents come to the rescue again, and especially the Printed Report from the FOODCAL program.

Here are a few real-life examples we have heard about from customers who use the FOODCAL Nutrition Calculator. Brief examples of decisions made by producers as a result of situations resulting from the specifics of their production:

A. a producer who had laboratory analysis results for his products, also calculated them using the FOODCAL Calculator, obtained slightly different results, provides values ​​on the labels that are the result of averaging both of these results (laboratory + Calculator) because he considered that this is actually the case in accordance with the Regulation

B. a producer who has a lot of seasonal products, after performing one laboratory analysis and comparing the results from the Calculator for the same product, decided that the nutritional values ​​of all his products will be provided only and exclusively based on the results from the FOODCAL Calculator

C. a producer who wanted to check the correctness of the results from the Calculator, calculated them using the free trial version, then sent the same product to the laboratory from where the result came with a clear difference, after talks with the National Food and Nutrition Institute, Sanitary Inspectorate, IJHAR-S and us, decided to send the same product again to another laboratory, from where he received yet another result, decided to calculate the values Calculator, but not using the Raw Materials Catalog included with the Calculator in recipes, but obtaining specifications of all raw materials from your suppliers. I will add that the Calculator has a function for adding your raw material data yourself, which is certainly an indisputably good method for obtaining a result that can be easily defended in the event of an inspection.

There are many interesting cases that could be discussed, but the most important will be the common conclusions:
> to prepare well for an inspection, you need to have factual documentation

> the FOODCAL Calculator gives clear and correct results, which also provides documentation that facilitates passing the inspection

> nutritional values ​​published on labels should be expressed as averages, so the results of any laboratory analysis or calculations made using other methods may be different from those given on the label, as long as they are within the standard limits and the method used to define them is one of the three permitted by EU Regulation 1169/2011.

Note: If you want to see what the documentation generated by the FOODCAL Nutrition Calculator looks like, leave your email and we will send you a set of sample documents.

We hope that your doubts are cleared up. We invite you to use our software, and if you have any further questions, we will be happy to help.

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

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