Managing Food Mislabelling: Essential Steps for Ensuring Accurate Product Labelling

Keywords: Food Mislabelling, Labelling Management, Investigations, Regulatory Compliance, Brand Protection

Food Mislabelling refers to the act of providing inaccurate or misleading information on food product labels, packaging, or accompanying documents. It involves the incorrect representation of essential details related to the food item, such as its ingredients, nutritional content, origin, certifications, or allergen information. Food mislabelling can occur due to various reasons, including human error, inadequate quality control, regulatory non-compliance, lack of clear guidelines or standards, technical malfunctions, changes in formulations and ingredients, lack of training and awareness or even intentional misrepresentation.

Mislabelling of food products can have significant consequences on business, both from the perspective of monetary losses and brand reputation loss. They include risks such as consumer health risks, regulatory non-compliance and penalties, legal liabilities, investigations costs, packaging material losses, product recall costs and damage to brand reputation.

Investigation Costs of Food Mislabelling

In case of food mislabelling, a company needs to undertake several investigations to identify the root cause, assess the extent of the issue, and implement corrective measures. These investigations typically involve internal audits, supply chain analysis, product testing, and coordination with regulatory authorities.

1. Internal Audits:

Internal audits involve a comprehensive review of the company's processes, procedures, and controls related to labelling and product information. This investigation helps identify any gaps or deficiencies in the internal systems that may have contributed to the mislabelling.

The company's standard operating procedures (SOPs) for labelling, including labelling design, creation, and verification processes must be assessed thoroughly whilst auditing labelling procedures and documentation. Assessing the procedures for managing changes to labelling, such as updates to ingredients, nutritional information, or allergen declarations. It is important to evaluate how changes are documented, approved, communicated, and implemented within the labelling process.

Training programs provided to employees involved in labelling activities must be evaluated to determine the competency of the team managing labelling. The effectiveness of quality control checks and procedures implemented throughout the labelling process must be evaluated. Inspection of the labelling equipment, printers, and software used within the company, and assessing their calibration, maintenance, and accuracy in generating and applying labels is critical.

2. Supply Chain Analysis:

Supply chain analysis focuses on tracing the product's journey from raw materials to manufacturing, packaging, and distribution. It involves examining the suppliers, subcontractors, and intermediaries involved in the production process to identify potential points of mislabelling or contamination.

Suppliers must be assessed for their adherence to labelling regulations, quality control measures, and accurate provision of product information. Reviewing and assessing the accuracy of the information provided by suppliers regarding the composition, origin, and allergen status of the ingredients.

Evaluation of the integrity of packaging and labelling materials throughout the supply chain, from the initial packaging stage to the final product distribution is necessary to determine if there are any vulnerabilities or opportunities for mislabelling to occur during transportation, storage, or handling.

Assessing the availability of systems or technologies that facilitate supply chain transparency and enable quick identification of mislabelling errors.

3. Product Testing:

Product testing plays a crucial role in investigating mislabelling incidents. It involves conducting laboratory tests on samples of the mislabelled products to determine their composition, quality, safety, and compliance with labelling regulations. Verifying the accuracy and completeness of the label information against the product's actual composition, ingredients, nutritional content, allergen declarations, and other labelling claims is essential.

Testing may include chemical analysis, allergen testing, nutrition analysis, microbial analysis, contaminant testing, certification verification and/or any other relevant tests.

4. Coordination with Regulatory Authorities:

Companies often collaborate with regulatory authorities during mislabelling investigations. This collaboration includes sharing information, cooperating in inspections, and adhering to regulatory guidelines. Regulatory agencies may conduct their own investigations and audits to assess the situation and take appropriate actions if necessary.

Food companies must understand the specific regulations and guidelines governing food labelling within the relevant jurisdiction. Companies must review the process for notifying the authorities, providing accurate information, and implementing necessary corrective actions.

Companies also engage additionally with external agencies or guidance and assistance regarding labelling compliance.

5. Document Reviews:

This investigation involves reviewing various documents such as production records, invoices, purchase orders, quality control documents, and labelling specifications. Analysing these documents helps identify any discrepancies, deviations, or non-compliance related to labelling and product information.

Processes need to be set in place for monitoring and assessing the company's awareness and response to updates, changes, or new regulations issued by government agencies pertaining to food labelling.

6. Consumer Complaint Analysis:

Companies may analyse consumer complaints and feedback related to mislabelling incidents. This investigation helps understand the impact on consumers, identify patterns or trends, and gather additional information that may aid in the investigation process.

7. Corrective Action Implementation:

Once the root cause of the mislabelling incident is identified, companies need to implement corrective actions to prevent future occurrences. This involves updating labelling processes, revising quality control measures, training employees, and strengthening compliance procedures.

By conducting these investigations, companies can gather essential information, determine the causes of mislabelling, and take appropriate actions to rectify the issue and ensure compliance with labelling regulations.

All of the above processes are essential while being cost-intensive. This can be an additional expense for food companies in case of mislabelling are better avoided through optimal food labelling processes set up right from the start.

About LabelBlind®

FoLSol-AI® is a proprietary digital food labelling tool designed by LabelBlind® (registered MSME estd. in 2018). We are engaged in the space of Food Labelling and Food Regulation Compliance for Packed and Fresh Food, Global Food Labelling for Food Exports and Imports, Food Assessment and Rating. The company creates AI-led Digital Food Labelling and SaaS Solutions for Food Businesses to strengthen regulation compliance.

We have trained FoLSol-AI® using neural networks, to assess regulatory compliance of food labels. FoLSol-AI® interacts with label images and can generate a compliance report instantly for any food label, across any food category. Effort of days and hours, is reduced to minutes with FoLSol-AI®.

FoLSol-AI® application uses Object Detection Model to quickly and accurately validate the presence and positioning of required logos on the label, contributing to the overall compliance assessment. FoLSol-AI® leverages neural networks and AI technologies to perform Optical Character Recognition (OCR) and extract data from the nutrition labels. By utilizing AI-based OCR, the application achieves higher accuracy and efficiency in extracting information from the labels compared to traditional OCR techniques. FoLSol® application integrates the ChatGPT API to extract data from the detected text in a structured format. By combining the OCR output with ChatGPT's capabilities, the application can effectively parse and organize the extracted information, making it easier to assess the compliance of the nutrition label.

Author

Rashida Vapiwala

Founder at LabelBlind® | Ph.D | Digitising Food Labelling and Nutrition Quality | Food Label Specialist

Recognised by NITI-Aayog - 75 Women Entrepreneurs on the 75th year of independence

References

• The numbers on mislabeling. How does your organization compare? https://www.loftware.com/resources/blog-posts/2021/the-numbers-on-mislabeling-how-does-your-company-compare

• The Top 3 Reasons for Label & Packaging Errors in Food Manufacturing. https://scm.ncsu.edu/scm-articles/article/the-top-3-reasons-for-label-packaging-errors-in-food-manufacturing

• Quality Matters: Mislabeled Products and Supply Chain Audit. https://www.etq.com/blog/quality-matters-mislabeled-products-supply-chain-audit/

• What is Food Fraud Costing Your Business? https://www.highspeedtraining.co.uk/hub/what-is-food-fraud-costing-your-business/

• 5 Simple Causes of Incorrect Food Labelling. https://haccpmentor.com/incorrect-food-labelling/