Rice, how to reuse non-compliant labels?

Dear Dongo lawyer,

Our company has a large amount of packaging for parboiled rice in stock which, however, does not have the mandatory wording 'long grain B' on the label.

Is it possible to add the missing wording in the white box where the batch and the minimum durability date are printed, using laser printing, in order to save the already printed packaging?

Many thanks

Anna

The lawyer Dario Dongo, Ph.D. in international food law, answers

Dear Anna,

It is essential to do everything possible to save the packaging materials already printed, in compliance with the rules of information to the consumer. Not only for economic needs, but also to minimize the environmental impact of the production cycle. Let's therefore evaluate together the rules to be applied to the specific case, the proposed solution and the possible measures.

Rice, classification

Common Market Organisation Regulation (EU) 1308/13 indicates in Annex II, Part I, the marketing standards relating to 'round grain rice,medium grain rice' and 'long grain rice'. This last category is divided into:

• 'category A, i.e. rice with a length greater than 6,0 millimetres and with a length/width ratio greater than 2 and less than 3';
• 'B category, i.e. rice with a length exceeding 6,0 millimetres and with a length/width ratio equal to or greater than 3'.

The regulation itself also defines the criteria for measuring grains, on milled rice, as well as the definitions for whole, trimmed and broken grains. (1)

Rice, designation on the label

The Italy – with the legislative decree 131/2017, which states 'provisions concerning the domestic rice market' – has adopted specific rules which integrate the CMO Regulation in various aspects, including the labelling of commercial products on the national territory. (2)

La legal name of rice consists of the name of one of the following groups:

'a) round grain rice or round rice or Originario rice;

b) medium grain rice or medium rice;

c) long grain rice A or long rice A;

d) long grain rice B or long rice B';

This denomination must be integrated, as appropriate, with:

'a) the indications "semi-finished" or "whole" or "semi-raw";

b) the particular treatment undergone;

c) the colour of the pericarp, if different from the normal whitish colour and if due to the hereditary characteristics of the varieties of raw rice from which the rice is obtained'.

The name itself can be accompanied dai names of all varieties of raw rice.'I names of rice varieties raw materials cannot be used on the packaging unless they also appear in the name of the food'(Legislative Decree 131/2017, article 3).

Positioning of mandatory information on the label

Food Information Regulation (EU) No 1169/11 – laying down uniform provisions on commercial information relating to foodstuffs – indicates in Article 9 the Required Information to be reported on the label. (3)

Among these, the food name and the yours amount – in addition to the actual alcoholic strength by volume, for beverages containing more than 1,2% alcohol by volume – they must be positioned in the same field of vision (EU Reg. 1169/11, article 13.5).

The «field of view» is in turn defined as 'all surfaces of a package that can be read by a unique viewing angle' (EU Reg. 1169/11, article 2.2.k).

Font size

'Le mandatory information referred to in Article 9, paragraph 1, which appear on the packaging or on the label attached to it are printed in such a way as to ensure clear legibility, in characters whose middle part (x-height), as defined in Annex IV, is equal to or greater than 1,2 mm.

In the case of packaging or containers whose larger surface area measure less than 80 cm2, the x-height of the character size referred to in paragraph 2 is equal to or greater than 0,9 mm' (EU Reg. 1169/11, article 13, paragraphs 2,3).

Article 9 however 'applies without prejudice to more specific Union provisions on metrology'(EU Reg. 1169/11, article 11).

Dimensions of quantity indications according to EU metrological standards

La Directive 2007 / 45 / EC establishes metrological requirements for prepackaged packaging, including specific provisions for the size of characters used to indicate the nominal quantity of the product.

The minimum height of the characters for indicate the nominal quantity it must be:

• 2 mm for nominal quantities up to 50 g or 50 ml;
• 3 mm for nominal quantities greater than 50 g/ml up to 200 g/ml;
• 4 mm for nominal quantities greater than 200 g/ml up to 1 kg/1 l;
• 6 mm for nominal quantities exceeding 1 kg/1 l (Directive 2007/45/EC, Annex III). (4)

These European provisions have been received in Italian legislation through DPR 391/80, thus ensuring the harmonization of metrological requirements throughout the European Union. Compliance with these standards is essential for the free circulation of pre-packaged products in the European internal market. (5)

Conclusions

It is possible to reuse packaging for the packaging of rice with a non-compliant label with regards to the incompleteness of the food name, under the following conditions:

• insert the complete name of the food by laser printing on the individual films already printed, respecting the minimum dimensions established (height of the median letter 'x' greater than 1,2 mm);
• ensure that the full name is in the same field of vision (i.e. on the same side of the packaging);
• If the pre-printed films show the quantity on a different side of the packaging, reprint the full name and the quantity of the product on the same side, respecting the relevant minimum dimensions (4 mm for packages from 201 to 1000 g).

Stamping the legal sales name and quantity on the white space on the side, in compliance with the aforementioned character height requirements, can therefore allow the reuse of available packaging.

Cordially

Dario

Note

(1) Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 establishing a common organization of the markets in agricultural products. Latest consolidated version: 08/11/24. https://tinyurl.com/hbe87nht

(2) Legislative Decree 4 August 2017, n. 131. Provisions concerning the internal rice market, pursuant to Article 31 of Law No. 28 of 2016 July 154. Regulations. https://tinyurl.com/52rzmdzu

(3) Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council. Current consolidated version: 01/04/2025 https://tinyurl.com/mryep48y

(4) Directive 2007/45/EC of the European Parliament and of the Council of 5 September 2007 laying down rules on nominal quantities for prepacked products. https://tinyurl.com/3sn3tc75

(5) Presidential Decree 391/1980. Metrological discipline of the pre-packaging in volume or mass of pre-packaging of a type other than the EEC one. Text updated on 8.2.18. Normattiva. https://bit.ly/3iulynL

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