Country of Origin Labelling Guidance

The country of origin is deemed to be the place of last substantial change. This is consistent with section 36 of the Trade Descriptions Act 1968 where the approach is that for the purposes of the Act:

• “goods shall be deemed to have been manufactured or produced in the country in which they last underwent a treatment or process resulting in a substantial change”.

Concerning what processes result in a substantial change, we suggest that for example, the transformation of pork into bacon, ham, sausages or pies should be regarded as a treatment or process resulting in a substantial change, while the simple slicing, cutting, mincing and/or packing of meat does not amount to such a change.

For some products the name of a country or place is used to describe their origin as part of the name of the food, for example “British Steak Pie” or “French Beef Bourguignon”, thereby, forming an origin declaration. If the place that is declared as the of origin of the food (according to the principle of last substantial change) is not the same as the place of origin of its primary ingredients, in order not to be misleading it may be necessary to provide information on the origin of those ingredients. It is recommended that for example:

• Pork sausages made in UK using pork from countries outside the UK are not described as “British pork sausages”. Instead they could bear the name “Pork Sausages” and if helpful, a further declaration could be made as described –

“Made in UK from pork imported from Denmark or Belgium (i.e. more than one country)”; or
“Made in UK from Dutch pork”

• Salmon smoked in Scotland but made from Norwegian salmon is not described as “Scottish smoked salmon” but is described as – “Norwegian salmon smoked in Scotland”, or
“imported salmon smoked in Scotland”.

Other terms that could similarly be used are “Baked in …”, “Pressed in …”, “Packed in …”, “Sliced and packed in …” or “Processed in …”.

In the case of a product (particularly a recipe dish) that reflects a culinary dish of a particular country, an origin declaration may be necessary to clarify where the product was made. This may apply in the cases of product ranges such as “British Classics”, “Indian”, “Thai” or “Chinese”, or when the name of the food is in a foreign language. For example:

• For a lasagne that is produced in Germany and marketed in an “Italian” range, or with indications of origin such as Italian flag colours, a declaration such as “Produced in Germany” should be provided. If the product contains pasta from Italy, then this could also be declared.

• For onion bhajis that are described as “Indian snacks made with spiced fresh onions”, if they are produced in the UK then a declaration of UK origin should be made.

To declare the place of origin of a food from Northern Ireland the declaration “Northern Irish” or “UK” could be used.

Country of Origin Labelling Guidance
Consumer Guide to Country of Origin Information on Food Labels

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