Packaging size and legibility criteria, the lawyer Dario Dongo answers

Dear Mr. Dongo,

I would like to ask you for advice on a problem that I have found myself facing. I have to export some jars of preserves to Holland, Belgium, Germany and France. The reg. UE 1169/11 in article 16 indicates that some mandatory indications may be omitted if the largest surface of the container measures less than 10 cm2. I therefore ask you if, since my container is a cylinder, by greater surface I must mean the area of ​​that cylinder.

thank you

Chiara

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

Dear Chiara good morning,

the European Commission at the time he rejected the request of the industrial part, to be able to consider only the visible surface in the frontal area. Equal to one third of its largest area, in most cases of cylindrical, spherical and conical packages.

Consequently, the surface of the packaging to be considered for the purpose of applying exceptions on the height of the characters (2) - and on the mandatory information to be reported on the label (see next paragraph) - remains the broadest. In the case of jars, usually the side. (1)

'' In the case of packaging or containers whose largest surface measures less than 10 cm 2, only the indications listed in Article 9, paragraph 1, letters a), c), e) and f) are mandatory on the packaging or on the label . ' (3) 'The information referred to in Article 9, paragraph 1, letter b), (4) is provided by other means or is made available to the consumer at his request'

(EU reg. 1169/11, article 16.2)

It is worth remembering in this regard that the measurement must be performed on the closed vessel and it is the entire area of ​​its largest surface to be considered. Not instead that of the label affostavi, generally smaller.

Dario Dongo

Footnotes
(1) Without prejudice to the hypothesis of jars of minimum height, such as those used for caviar and its substitutes. In this case, the area of ​​the metal cover may be larger than that of the glass side
(2) See the requirements for legibility and height of the characters referred to in reg. EU 1169/11, article 13 and Annex IV
(3) Food name, allergens, quantity, minimum shelf life or expiry date (EU regulation 1169/11, article 9.1, letters a, c, e, f)
(4) List of ingredients, ed