Private label pork: what to specify

A private-label pork brief defines the product (cut, trim, weight range, temperature regime, pack format) and the label (legal content, languages, batch marking, carton identification) in parallel. The second stalls projects: under Regulation (EU) No 1169/2011 the operator named on the pack — not necessarily the packer — is legally responsible for what it says.

Who owns the label

Article 8(1) of Regulation (EU) No 1169/2011 makes the operator "under whose name or business name the food is marketed" responsible for the food information; if it is not established in the Union, the importer takes the role. Article 8(2) requires it to ensure the information is present and accurate; Article 9(1)(h) puts its name or business name and address on the pack.

Article 8(7) lets those particulars travel on commercial documents accompanying the food where prepacked food is marketed before sale to the final consumer or supplied to a mass caterer; even then Article 9(1)(a), (f), (g) and (h) must appear on the external packaging. Article 8(8) makes the supplier give its customer enough information to meet its own obligations. Specify the data set that travels with the consignment, not only what is printed.

The mandatory particulars

Article 9(1) lists the particulars for prepacked food; several carry meat-specific detail.

Origin

Commission Implementing Regulation (EU) No 1337/2013 has applied since 1 April 2015 to fresh, chilled and frozen swine meat under the Combined Nomenclature codes in Annex XI to Regulation 1169/2011 (heading 0203). Article 5(1) requires "Reared in:", "Slaughtered in:" and a batch code; for swine it turns on age and live weight.

Article 7 gives minced meat and trimmings a closed list: "Origin: EU"; "Reared and slaughtered in: EU"; "Reared and slaughtered in: non-EU"; "Reared in: non-EU" with "Slaughtered in: EU"; "Reared and slaughtered in: EU and non-EU". These are prescribed strings, not examples, with an official wording per language.

Composition statements that change the name

Annex VI, Part A requires added water above 5 % of finished weight to be declared in the name of meat products and preparations resembling a cut, joint, slice, portion or carcase (point 6); added proteins of a different animal origin must be named (point 5). Annex VII, Part B, entry 17 caps what may be declared "meat" — for porcines 30 % fat and a 25 % collagen/meat protein ratio — above which the declared meat content drops and fat or connective tissue is listed separately.

Legibility, language and net quantity

Mandatory information must be easily visible, clearly legible and, where appropriate, indelible (Article 13(1)). Article 13(2) sets a minimum x-height of 1.2 mm, Article 13(3) lowering it to 0.9 mm where the largest surface is under 80 cm²; below 10 cm², Article 16(2) cuts the set to name, allergens, net quantity and date.

Article 15(1) requires a language easily understood by consumers in the Member State of marketing, and Article 15(2) lets that State stipulate one or more official Union languages. This drives the artwork version count.

Net quantity follows the average-quantity system of Council Directive 76/211/EEC, whose Annex I scales the quantity figures with pack size (point 3.1) and makes the "℮", a lower-case "e" at least 3 mm high, the packer's or importer's guarantee (point 3.3).

Batch marking and carton identification

Under Article 3 of Directive 2011/91/EU the lot is set by the producer, manufacturer or packager, or the first EU seller, and preceded by "L" unless clearly distinguishable. Article 4(2) of Regulation 1337/2013 caps a batch at one day's production in a single establishment.

Cartons carry the identification mark of Regulation (EC) No 853/2004, Annex II, Section I, applied before the product leaves the establishment: country name in full or as a two-letter ISO code, the approval number and, inside the Union, the EU abbreviation in an official language — EC, EU, EL, UE, EE, AE, ES or EÚ. In Spanish that abbreviation is "UE"; "CE" is no longer listed. For cut meat or offal it must be destroyed when the packaging is opened.

Article 18 of Regulation (EC) No 178/2002 sets the one-step-back, one-step-forward duty; Article 3 of Regulation (EU) No 931/2011 fixes what must accompany food of animal origin: description, quantity, dispatching and receiving operators, a lot reference and dispatch date. Carton labels encode this with GS1 Application Identifiers: (00) SSCC, (01) GTIN, (10) batch/lot, (17) use by or expiry, (310n) net weight in kilograms.

Quick-frozen goods need −18 °C or lower at all points and a "do not refreeze after defrosting" message on consumer packs (Council Directive 89/108/EEC, Articles 5(1) and 8(1)(d)).

Minimum runs

Minimum run is commercial, not legal. It follows printing method — each rotogravure cylinder or flexo plate set is originated per version and per colour — plus reel width, label tooling, the number of language versions and whether variable data is pre-printed or applied inline. Fewer versions improve run economics.

What this means for your order

• Name the responsible operator and destination market before artwork starts.
• Fix the languages early: they set the version count.
• Check origin wording against actual sourcing; copy the prescribed strings exactly.
• State the date type: use-by, plus "Frozen on …" for frozen product.
• Define batch granularity and code placement against the one-day rule.
• Agree the carton data set and symbology with the artwork.