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Guidance on Primary Origin Indication: what you need to know


EU Regulation 775/2018: After 1 April 2020, Food manufactures must label origin of the primary ingredient

The EU Regulation 775/2018 introduces the rules to indicate on the label the country of origin or the place of provenance of the primary ingredient of a food, such as wheat for pasta or milk for dairy products. The purpose of the new legislation is to give the consumer more accurate information on the provenance of the food that they are consuming.

The regulation was passed on June 1 2018 and comes into force April 1, 2020. Food placed on the market or labelled before April 1 2020 can be marketed until stocks are exhausted, but any food marketed or labelled after this date needs to comply.

The two key points to follow are:

  • The origin of the primary ingredient must be shown on pack when the place of origin of the food differs from that of its primary ingredient. 
  • This will only apply to product/packages where the origin of the product is indicated either voluntarily by the food producer or mandated under article 26(2)(a) of EU1169/2011.

This new regulation will have an effect on business at all stages of the supply chain. For example, a primary ingredient may be sourced or harvested in one region or country and then passed to another region for processing before it even reaches the inward goods warehouse of the food manufacturer for processing into the final commercial product. 

Producers will have the option to either declare the origin of the primary ingredient in the same field of view as the origin of the product or add a separate disclaiming statement to inform the consumer that the origin of the product and primary ingredient is not the same.

The purpose is to give the consumer more accurate information on the provenance of the food that they are consuming.

Food manufacturers have a responsibility to show full traceability over its raw materials, collate all information across the supply chain and provide accurate ingredient information to consumer by means of the final packaging and labelling. Faced with this large array of things to be tracked and checked, the key to effective control of food labelling is to have a single version of the truth

The simplest way to achieve this single version of the truth is to use an integrated, end-to-end solution like 4Pack. Designed to help all departments involved in managing changes to existing products and getting new food and beverage products smoothly to market, 4Pack’s workflows integrate activity and information across Marketing, NPD, Quality, Technical, Regulatory Packaging, Logistics, Finance, Graphics and other teams internally and externally.


4Pack exists to help Food & Beverage manufacturers and brands of all sizes to push innovative, safer products to market across channels quickly. If you want to turbo charge your product launch process, book a demo with one of our experts.



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