A food law adviser commented toFoodnavigator.comthat most foods and drinks currently sold in the EU were likely to need new labelling, with even food sold loose being subject to new allergen rules. New origin labelling rules mean that a company would have to state if a product is processed in one country, but the main ingredient comes from somewhere else. The introduction of mandatory nutrition labelling is seen as a major change, although a longer transition period up to December 2016 is to be allowed for small businesses.
In terms of origin labelling requirements, there have been calls from the European Cocoa Association (ECA) to exempt chocolate from compulsory labelling requirements. It is feared that the new regulations requirement that the origin of ingredients that constitute over 50% of a food should be individually specified would compel chocolate manufacturers to abandon the practice of bean blending. According toConfectionerynews.com, cocoa is regularly blended in chocolate products because it is a daily traded commodity that varies significantly in price, availability and quality, depending on weather and market conditions. The ECA argues that to comply with this regulation, [the] industry would have to trace specific origins, separate sourcing and [to] invest in additional processing lines, increase storage capacity, etc. Transport, warehouse management and other trade-related operations would also need to be adapted to these new requirements.
The ECA has highlighted the precedent set by the Swiss authorities, where an exemption for cocoa from origin labelling requirements has been granted.
However, it should be noted that voluntary labelling of origin already occurs for certain chocolate products.