how many of these label are illegal

[Tom Bick]

This is one of my labels this year and I rather like it.

 

[Erichalfbee]

there is a derogation alleged derogation and potential derogation

Had to look that up

 

[Swarm]

Tom,
Stunning

 

[Tom Bick]

Tom,
Stunning

Thanks definitely KISS

 

[pargyle]

This is one of my labels this year and I rather like it.

Stuff the legals ... that's just stunning - nice jars too !

 

[Erichalfbee]

I've just spotted they are made out of wood. Lovely!

 

[enrico]

This was my stall at the last Farmers Market
Taster jars, Jars for sale and I made up some gift bags with a jar of honey and a glass with bees in relief on them.
Seemed to go quite well.
Pleased with the branding, New this year, clean and easy to print in black and white.
Just for interest really!
e

 

[Swarm]

I say .... Very nice Enrico, like the upmarket gift bags.

 

[itma]

This was my stall at the last Farmers Market
Taster jars, Jars for sale and I made up some gift bags with a jar of honey and a glass with bees in relief on them.
Seemed to go quite well.
Pleased with the branding, New this year, clean and easy to print in black and white.
Just for interest really!
e

Yes that branding does look smart …



… but it looks as though your labels are missing the Country of production (which shouldn't be a problem for direct sales) and - more seriously - any "Lot Identification" or "Indication of Durability".

Prepacked foodstuffs must indicate a manufacturing or packaging lot reference, a system which is harmonised throughout the European Union (EU). The lot reference allows consumers to trace the product in the event of any dispute or health risk. The date of minimum durability or "use by" date can be used as the means of identifying the lot.

http://europa.eu/legislation_summaries/other/l21091_en.htm
Actually, the EU Directive was updated in 2011, but the relevant points are unchanged. http://www.fsai.ie/uploadedFiles/Dir2011_91.pdf
And that Directive itself says

Article 1
1. This Directive concerns the indication which allows identi- fication of the lot to which a foodstuff belongs.
2. For the purposes of this Directive, ‘lot’ means a batch of sales units of a foodstuff produced, manufactured or packaged under practically the same conditions.
Article 2
1. A foodstuff may not be marketed unless it is accompanied by an indication as referred to in Article 1(1).
2. Paragraph 1 shall not apply:
(a) to agricultural products which, on leaving the holding, are:
(i) sold or delivered to temporary storage, preparation or packaging stations;
(ii) transported to producers’ organisations; or
(iii) collected for immediate integration into an operational preparation or processing system;
(b) when, at the point of sale to the ultimate consumer, the foodstuffs are not prepackaged, are packaged at the request of the purchaser or are prepackaged for immediate sale;
(c) to packagings or containers the largest side of which has an area of less than 10 cm2;
(d) to individual portions of ice cream. The indication enabling the lot to be identified shall appear on the combined package.
Article 3
…
Article 5
When the date of minimum durability or ‘use by’ date appears on the label, the indication referred to in Article 1(1) need not appear on the foodstuff, provided that the date consists at least of the uncoded indication of the day and the month in that order.

There is no exemption there from Lot numbering for our honey. But Article 5 means that a 'best before' plainly specified to the day (regardless of the daftness of that for honey) can function as a Lot Number.

I know the BBKA advice is that - for direct sales - Lot ID and Durability Indication are not required.
However, I think they are wrong on this, because I've never found ANY legal support for their assertion.
If anyone can find ANY reference to an actual law that supports that waiver, I'd love to see it.

As I've stated before, there is a (likely) waiver for stating the Country of Production for direct sales, but that does not apply to Durability and Lot Identification.

 

[itma]

This was my stall at the last Farmers Market
Taster jars, Jars for sale and I made up some gift bags with a jar of honey and a glass with bees in relief on them.
Seemed to go quite well.
Pleased with the branding, New this year, clean and easy to print in black and white.
Just for interest really!
e

Yes that branding does look smart …



… but it looks as though your labels are missing the Country of production (which shouldn't be a problem for direct sales) and - more seriously - any "Lot Identification" or "Indication of Durability".

Prepacked foodstuffs must indicate a manufacturing or packaging lot reference, a system which is harmonised throughout the European Union (EU). The lot reference allows consumers to trace the product in the event of any dispute or health risk. The date of minimum durability or "use by" date can be used as the means of identifying the lot.

http://europa.eu/legislation_summaries/other/l21091_en.htm
Actually, the EU Directive was updated in 2011, but the relevant points are unchanged. http://www.fsai.ie/uploadedFiles/Dir2011_91.pdf
And the Directive itself says

Article 1
1. This Directive concerns the indication which allows identi- fication of the lot to which a foodstuff belongs.
2. For the purposes of this Directive, ‘lot’ means a batch of sales units of a foodstuff produced, manufactured or packaged under practically the same conditions.
Article 2
1. A foodstuff may not be marketed unless it is accompanied by an indication as referred to in Article 1(1).
2. Paragraph 1 shall not apply:
(a) to agricultural products which, on leaving the holding, are:
(i) sold or delivered to temporary storage, preparation or packaging stations;
(ii) transported to producers’ organisations; or
(iii) collected for immediate integration into an operational preparation or processing system;
(b) when, at the point of sale to the ultimate consumer, the foodstuffs are not prepackaged, are packaged at the request of the purchaser or are prepackaged for immediate sale;
(c) to packagings or containers the largest side of which has an area of less than 10 cm2;
(d) to individual portions of ice cream. The indication enabling the lot to be identified shall appear on the combined package.
Article 3
…
Article 5
When the date of minimum durability or ‘use by’ date appears on the label, the indication referred to in Article 1(1) need not appear on the foodstuff, provided that the date consists at least of the uncoded indication of the day and the month in that order.

There is no exemption there from Lot numbering for our honey. But Article 5 means that a 'best before' plainly specified to the day (regardless of the daftness of that for honey) can function as a Lot Number.

I know the BBKA advice is that - for direct sales - Lot ID and Durability Indication are not required.
However, I think they are wrong on this, because I've never found ANY legal support for their assertion.
If anyone can find ANY reference to an actual law that supports that waiver, I'd love to see it.

As I've stated before, there is a (likely) waiver for stating the Country of Production for direct sales, but that does not apply to Durability and Lot Identification.

 

[enrico]

Just to put your mind at rest itma....it is there, it says 'produce of uk' and best before date directly under the round offas coin mark which are all turned away from the camera and which I left off the gift bags as they or the jar of honey inside. I can see why you think it isn't there but trust me ....... It is!
But thanks for looking!
Actually just had another look and the one by the £4.50 price ticket is visible but is blurred so you can't see what it says.!!!
E

 

[Swarm]

This is for those who have nothing better to do, most if not all other EU countries would laugh and carry on as normal.
I prefer Tom's approach.

 

[mintmoth]

This is the DEFRA list. There are more than I thought, but I don't see honey in there anywhere.

Foods and categories of food which are exempt from the requirement to carry date marks under the Food Labelling Regulations (FLR); or require a specific date marking under other relevant legislation

Exempt from the requirement to carry date marks under the FLR
1. Loose food, including food sold in catering establishments;
2. Food that is pre-packed for direct sale as defined in the FLR;
3. Any food prepared otherwise than in the course of a business carried on by the person preparing it, such as one-off charity events;
4. Fancy confectionery products which are individually wrapped and which are intended to be sold as single items;
5. Food sold in indelibly marked glass bottles;
6. Seasonal selection packs, provided that individual food items are fully labelled;
7. Fresh fruit and vegetables, including potatoes, but not including sprouting seeds and similar products such as legume sprouts, which have not been peeled, cut or similarly treated;
8. Wine, liqueur wine, sparkling wine, aromatised wine and any similar drink obtained from fruit other than grapes and any other drink made
from grapes or grape musts coming within the Common Customs Tariff (see the Regulations);
9. Any drink with an alcoholic strength by volume of 10 per cent or more;
10. Any soft drink, fruit juice or fruit nectar or alcoholic drink, sold in a container containing more than 5 litres and intended for supply to catering establishments;
11. Any flour confectionery and bread which, given the nature of its content, is normally consumed within 24 hours of its preparation;
12. Vinegar;
13. Cooking and table salt;
14. Solid sugar and products consisting almost solely of flavoured or coloured sugars;
15. Chewing gums and similar products;
16. Edible ices in individual portions;
17. Any additive sold as such which is required to be labelled in accordance with regulation 4(3) of the Extraction Solvents in Food Regulations 1993, or the appropriate provisions of any of the additives regulations.

 

[mintmoth]

This is for those who have nothing better to do, most if not all other EU countries would laugh and carry on as normal.
I prefer Tom's approach.

That's so true

It's the EU that insists eggs carry a "best before" date, not a "use by" date, but beyond that date they may not be safe to eat raw. Doesn't have to say that on the egg though...

 

[itma]

This is for those who have nothing better to do, most if not all other EU countries would laugh and carry on as normal.
I prefer Tom's approach.

Yes it would be nice if we lived in that sort of a world.

However, as exemplified by some recent comments about sugar syrup, and the usual derision about the quality of "honey" coming from under-regulated countries, there is a need for legal protection of US, those who are actually selling GOOD honey.
To protect us, there are laws that make it an offence to falsely label honey.

To do it properly, complying with the law, isn't hard.
And my expectation would be that the enforcement authorities might well think that those individuals who weren't too bothered about complying the law for labels just might be equally unbothered about what went into their jars.

And remember, this is a thread specifically about labels complying (or not) with the legal requirements - rather than their artistic merit or marketing potential.

 

[enrico]

This is the same label but on a pound jar.......shows up better!
Let me know If there are any other faults......thanks. Weight is correct size of print by the way!

 

[itma]

This is the same label but on a pound jar.......shows up better!
Let me know If there are any other faults......thanks. Weight is correct size of print by the way!

Enrico, it does LOOK very nice indeed, but there are two details that a nit-picking jobsworth MIGHT get fussed over.

It looks as though the weight is stated as "454 gms" but I believe it should just say "454g" (gms isn't the proper designation of the unit) -- however I refuse to believe anyone is really going to fuss over how big your typeface makes the space between the number and the letter…

And particularly since the Best Before is doubling as the Lot ID, I understand that the date needs to be absolutely crystal clear and "02/08/17" could potentially mean different things to different folks, whereas "O2 Aug 2017" is unambiguous.

 

[jenkinsbrynmair]

Just checked th regs. and if you only sell direct to the public (i.e. not supply a retailer) lot number is not mandatory

 

[jd101k2000]

My understanding of the Lot number and best before date is that you have to keep a bottle of honey for six months after the best before date. Then, if there is a problem/claimed problem, you have a sample that can be tested.

For example, person claims that your honey poisoned them. Your sample can be tested for pesticides/exotic hallucinogenic nectar. So it protects you against false claims on the one hand and, if your honey is at fault, allows you to identify which honey to recall. (How you would perform a recall, I have absolutely no idea.)

 

[Gilberdyke John]

My understanding of the Lot number and best before date is that you have to keep a bottle of honey for six months after the best before date. Then, if there is a problem/claimed problem, you have a sample that can be tested.

For example, person claims that your honey poisoned them. Your sample can be tested for pesticides/exotic hallucinogenic nectar. So it protects you against false claims on the one hand and, if your honey is at fault, allows you to identify which honey to recall. (How you would perform a recall, I have absolutely no idea.)

Hallucinogenic nectar as a constituent could open up a whole new market
Off the radar of course