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[DC: RA-T-9-002(NT): 10/15 (3) : R/HRW]

Regulatory Affairs Department

Campden BRI (Chipping Campden) Limited Station Road Chipping Campden Gloucestershire GL55 6LD UK

Campden BRI (Nutfield) Coopers Hill Road Nutfield Surrey RH1 4HY UK

Report for:

Department for Environment, Food & Rural Affairs

Nobel House,

17 Smith Square,

London,

SW1P 3JR

Report on:

Scoping of the extent of voluntary country of origin labelling for packaged goods Work performed by Campden BRI (Chipping Campden) Limited and Campden BRI (Nutfield) Report number: Information & Legislation/REP/132625 Issue date: 2015

Contact details: David Leeks Regulatory Affairs Department Campden BRI (Nutfield)

david.leeks@campdenbri.co.uk Tel: +44(0)1386 842156 Fax: +44(0)1386 842100

We value your opinion: http://www.campdenbri.co.uk/campdenbri/fdbck.php

Report issued and authorised by:

Campden BRI (Nutfield)

Stephen Spice Head of Department – Regulatory Affairs

Campden BRI Group

This research was commissioned and funded by Defra. The views expressed reflect the research

findings and the authors’ interpretation; they do not necessarily reflect Defra policy or opinions.

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Contents 1. Executive Summary 1.1 Aims and Objectives 1.2 Background 1.3 Approach 1.4 Results 2. Method 2.1 Outline 2.2. Sampling Plan 2.2 Shopping 2.3 Assessment 2.4 Imaging 2.5 Data analysis 2.6 Error rate determination 2.7 Statistical analysis 3. Results 3.1 PRIMARY INGREDIENT STATUS OF SAMPLES PURCHASED 3.2 PRODUCTS WITH PRIMARY INGREDIENTS 3.2.1 All Products with Primary Ingredients 3.2.2 Beverages with Primary Ingredients 3.2.3 Cereals and Cereal Products with Primary Ingredients 3.2.4 Confectionery with Primary Ingredients 3.2.5 Dairy Products with Primary Ingredients 3.2.6 Oils with Primary Ingredients 3.2.7 Processed Fruit with Primary Ingredients 3.2.8 Processed Vegetables with Primary Ingredients 3.2.9 Miscellaneous Foods with Primary Ingredients 3.3 PRODUCTS WITH ONLY A SINGLE INGREDIENT 4.3.1 All Products with only a Single Ingredient 4.3.2 Beverages with only a Single Ingredient 4.3.3 Cereals and Cereal Products with only a Single Ingredient 4.3.4 Confectionery with only a Single Ingredient 4.3.5 Dairy Products with only a Single Ingredient 4.3.6 Oils with only a Single Ingredient 4.3.7 Processed Fruit with only a Single Ingredient 4.3.8 Processed Vegetables with only a Single Ingredient 4.3.9 Miscellaneous Foods with only a Single Ingredient

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3.4 PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT 4.4.1 All Products with a Clear Above-50% Ingredient 4.4.2 Beverages with a Clear Above-50% Ingredient 4.4.3 Cereals and Cereal Products with a Clear Above-50% Ingredient 4.4.4 Confectionery with a Clear Above-50% Ingredient 4.4.5 Dairy Products with a Clear Above-50% Ingredient 4.4.6 Oils with a Clear Above-50% Ingredient 4.4.7 Processed Fruit with a Clear Above-50% Ingredient 4.4.8 Processed Vegetables with a Clear Above-50% Ingredient 4.4.9 Miscellaneous Foods with a Clear Above-50% Ingredient 3.5 IMPLICATIONS OF ORIGIN 4. Discussion and Conclusions 4.1 PRODUCTS WITH PRIMARY INGREDIENTS 4.2 PRODUCTS WITH ONLY A SINGLE INGREDIENT 4.3 PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT 4.4 CONCLUDING REMARKS 5. References 6. Acknowledgements Annex 1 Summary Tables

Annex 2 Categorisation of samples with numbers assessed in each sub-category

Annex 3 Assessment form

Annex 4 Guidance for Assessors

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1. Executive Summary 1.1 Aims and Objectives Defra’s objectives include supporting a world leading food and farming industry and a cleaner, healthier environment. Promoting competitiveness, creating a level playing field in the market and ensuring consumers are not misled are important in meeting these objectives. A key aspect of this is ensuring that consumers receive accurate food information on the provenance of food they buy. Under the terms of Article 26(3) of Regulation (EU) No 1169/2011 on the Provision of Food Information to Consumers (FIC)(1), the giving of origin information for the primary ingredient(s) (as defined) of a food will become mandatory where the origin of the whole food is volunteered and this is a different country or place from that of the origin of the primary ingredient(s). The application of this provision is dependent on the laying down of further rules in a yet-to-be-published Commission Implementing Act; this will delay the provision’s introduction significantly beyond the FIC general application date of 13 December 2014. Under the terms of Article 26(5) of Regulation (EU) No 1169/2011 on the Provision of Food Information to Consumers, the European Commission is also examining the case for the possible extension of mandatory origin labelling to single ingredient products and ingredients that represent more than 50% of a food. The FIC calls upon the Commission to present the results of its examination in a report to the European Parliament and the Council by 13 December 2014. Campden BRI has previously undertaken Defra-funded studies to assess the level of provision of voluntary country of origin information for meat, processed meat products, milk, fresh cream, butter and cheese(3-5). These are products for which best practice guidance on the provision of country of origin information has existed in the UK for some years prior to the publication of the FIC, and against which the products were assessed. The aim of the current project is to conduct a scoping study to assess the extent of voluntary origin labelling of a broad range of packaged food in the UK for which such data has not previously been collected. It focuses on those areas to be covered, or potentially to be covered, by origin labelling requirements under the Food Information to Consumers Regulation (FIC), i.e. products with primary ingredients, products with only a single ingredient and products with a clear above-50% ingredient. This baseline information will inform Defra on the extent to which current origin labelling practices in the UK may already satisfy future and potential future requirements under the FIC. This will inform Defra’s negotiating position in any negotiations with the European Commission on possible or definite extensions to origin labelling in the future. As a scoping study, the data also provides a baseline for future comparison, whether or not some of the possible extensions to origin labelling under the FIC are implemented in the foreseeable future. At the same time, as this survey looked largely at products for which data has not previously been collected, the conclusions are limited to those arising from comparisons with potential legal requirements rather than from any movements in the extent of voluntary provision of origin information which may have occurred over a particular period. The survey was neither complete (covering every distinct label in the market) nor random, so the results should not be taken as representative of the market in any quantitatively measurable way. Nevertheless, all practical means were used to ensure that the survey reflected the variety in the market, and the relative market share of different groups, i.e. product types and brand types (‘branded’ or ‘own label’). This means that conclusions on the overall market and those groups are more broadly applicable, albeit with unquantifiable precision. Further discussion on the statistical analysis of the results is given under ‘2.1 Outline’ below. 1.2 Background

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Information on the origin of a food product is voluntary for some foods and compulsory under the law for othersa. Additional information on the origin of individual ingredients may be provided voluntarily on foods. The Food Information to Consumers Regulation (FIC)(1) extends the range of foods for which the giving of origin information is mandatory to fresh, chilled or frozen meat from swine, poultry, sheep and goat. Detailed rules have been published for the form this origin information should take(2). Such information is already required for beef and veal.

Under the FIC, origin indications for a food should comprise either the ‘country of origin’ or the ‘place of provenance’. The country of origin is considered to be the country from which the food product was wholly obtained or, if production involved more than one country, the country where the product last underwent substantial, economically-justified processing. The place of provenance means any place where a food is indicated to come from and that is not the country of origin determined according to the above rules. The FIC also requires that when the origin of a whole product is volunteered and the origin of its primary ingredient is different, information must also be given about the origin of that primary ingredient. The application of this requirement is also subject to the publication of detailed rules, which, at the time of writing, had not yet been published and are still subject to discussion between Member States. The application date for this is therefore currently uncertain.

By 13 December 2014, the Commission is due to report to the European Parliament and Council on the possibility of imposing an obligation for the mandatory origin labelling of further types of finished foods or their ingredients, including single ingredient foods and ingredients which represent more than 50% of a food. This Commission report will assess consumer needs for the information, the feasibility of its provision, and an analysis of the costs and benefits including the impact on the internal market and international trade. It may be accompanied with proposals to modify the relevant Union provisions. 1.3 Approach During October and November 2013, 496 foods from 8 food categories (beverages, cereals and cereal products, confectionery, dairy, miscellaneous foods, oils, processed fruit and processed vegetables) were purchased on-line and in-store from fourteen different major supermarkets, convenience stores and discounters, selected on the basis of retailer market share data. These food categories had not, generally speaking, been the focus of previous Campden BRI origin labelling surveys. Previous surveys(3-5) had indicated that this number of samples would enable meaningful coverage of this restricted market. As with the 2012(3) survey, about 60% of the products were marketed under a retailer's own name or brand, the remainder being branded items. To provide a visual archive of the products, the samples were photographed, often from several angles, in order to include all aspects of the labels. By recording the origin-related indications on each product label, experienced food law advisers provided the raw data for the assessment of the extent of primary ingredient origin labelling, and origin labelling of single ingredient foods and ingredients representing more than 50% of a food.

a For some foods such as unprocessed beef and veal, poultrymeat from outside the EU, honey, fresh fruit and fresh

vegetables, origin labelling is required by law. For other foods general food labelling rules currently require that details of

the place of origin or provenance of a food are only required to be given if their omission might mislead the purchaser to a

material degree as to the food’s true origin.

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1.4 Results 96% of products in the survey were assessed as possessing a primary ingredient (above-50% ingredients and the single ingredient of single ingredient products were always classified as primary ingredients). 74% of products with a primary ingredient offered whole product origin information (e.g. ‘made in the UK’ or ‘product of California, USA’) with or without accompanying primary ingredient origin information (e.g. ‘made with British potatoes’ for crisps and ‘Kentish hops’ for beer). These were divided into 22% which gave a whole product origin statement and a primary ingredient origin statement, and the remainder (determined as 53% rather than 52% due to rounding) offering a whole product origin statement but no primary ingredient origin statement. Less than 2% of products with primary ingredients offered primary ingredient origin information without accompanying whole product origin information. Within the 53% of products with primary ingredients which gave a whole product origin statement but no primary ingredient origin statement may be some products which will, once the primary ingredient origin provisions of Article 26(3) of the FIC apply, need to be relabelled. With regard to the individual food categories, in all cases a very high proportion of products were assessed as possessing a primary ingredient. This proportion was lowest, at 86%, for miscellaneous foods which tended to be relatively heavily processed mixtures of ingredients, none of which predominated in determining the nature of the food, e.g. pickles and sauces. The giving of whole product origin was much more common in each food category than the giving of primary ingredient origin. Whole product origin was given without accompanying primary ingredient origin on the labels of between 40% and 59% of products in all food categories. Where the primary ingredient of these products originates from a different place from that stated as the whole product origin, label changes may be required to comply with Article 26(3) of the FIC. 26% of products in the survey were single ingredient products. Where a product has only a single ingredient, full origin information may nevertheless comprise that of the product and the ingredient where that ingredient was subject to significant processing which could have taken place at a location distant from that of the sourcing of the ingredient. The potential future requirement here is that a statement of product origin may be required: in this survey this was found to be given already for 80% of single ingredient products. Proportions were similarly high in food categories individually except for processed vegetables and miscellaneous foods where, with very few samples being single ingredient products, they were lower. None of the confectionery items in the survey were single ingredient products. For 53% of the products in the survey there was a clear ingredient in a proportion above 50%. Such ingredients are a possible candidate for mandatory origin labelling under the FIC. In this survey, 31% of the products with a clear above-50% ingredient offered origin information for that ingredient. Whole product origin statements were more prevalent, being given in 77% of cases. This was also the general pattern for origin statements within the individual food categories. There were two exceptions to this: confectionary products and miscellaneous foods, in each case on a very small number of qualifying products. No confectionery products with a clear above-50% ingredient offered origin information for that ingredient, while 29% offered whole product origin information. 6% of miscellaneous foods with a clear above-50% ingredient offered origin information for that ingredient, while 53% offered whole product origin information. 19% of products were assessed as carrying implications of origin, such as depictions of well-known landmarks, flags or arrangements of colours reminiscent of flags, and national symbols (e.g. the Welsh dragon). These were more often implications of product origin (87%) than of primary ingredient origin (38%), with some implications judged to be of both product and primary ingredient origin. In the former case (product origin) the implications were accompanied by clear product origin statements in 93% of cases, but in the latter case (primary ingredient origin), accompanying clear primary ingredient origin

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statements were provided in only 58% of cases. Implications of origin were more prevalent on dairy products than on other product types and the use of the Union Jack flag, often in conjunction with the ‘Red Tractor’ logo, was particularly common. No firm conclusions can be drawn as this survey is not fully representative. However, it provides some useful indicators on current uptake of labelling information on primary ingredient origin information and processing in the market place and a baseline for future comparisons.

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2. Method 2.1 Outline The approach, further described below, employs a well-tested, multi-disciplinary method, developed by Campden BRI, to facilitate the assessment of large numbers of food and drink labels according to criteria specified by the client, together with routines to report and analyse the data. The technique has proved very adaptable and successful in providing valuable information for both public and private sector clients, including the Food Standards Agency (Country of Origin)(4,5) and the Department of Health (Alcoholic Drinks)(6,7). The bespoke process involves in-house information, legislation, computing and statistics specialists in market analysis and product procurement, assessment form design, sample logging and assessment, and data analysis to allow the rapid reporting of results in a flexible format. This study aimed to draw conclusions about the complete market (the 'population') on the basis of a relatively small number of labels (the 'sample'). In such circumstances there is always a possibility that the sample will not be adequately representative of the population, leading to incorrect conclusions. Statistical analysis allows assessment of the likelihood of such errors. Confidence intervals on estimates (e.g. of proportions with primary ingredients), loosely speaking, indicate the range of population values that might reasonably be associated with observed sample values. Confidence interval calculations assume (inter alia) that the sample was chosen randomly from the population. In this study the sampling was not completely random: substantial effort was made to ensure that the survey samples reflected all major variations in the market, so that coverage of the population was better than would be suggested by the relatively small sample size. Accordingly, the sample can be expected to be substantially more representative of the population than would have been achieved by random sampling, so that the confidence associated with confidence intervals is larger than suggested by the random sampling based calculations. Overall, confidence intervals presented in this report should be treated with caution; the assumptions underlying the calculations are generally inappropriate to these circumstances, but they can be used as approximate indications of the reliance that can be based on conclusions. However, it is our considered opinion that the survey results are closer representations of the market than would be indicated by such confidence intervals. 2.2 Sampling Plan A sampling plan was developed for the products based on market information from Key Note Publications Ltd(8-14). The sampling plan ensured that the products purchased:

were broadly representative of the various types of products available to consumers at retail outlets

reflected the market share of own label and branded products

excluded products that were made from organic ingredients and/or whose names were registered under the EU Protected Food Names Scheme.

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Kantar Worldpanel Marketshare(15) was used to ensure that numbers of products purchased from a particular retailer reflected that retailer’s market share, as detailed below.

Supermarket Kantar Worldpanel Marketshare 12 weeks to 9/6/13 (%)

Tesco 30.5

Asda 16.9

Sainsburys 16.7

Morrisons 11.6

Co-operative 6.3

Waitrose 4.9

Aldi 3.6

Lidl 3.0

Iceland 2.0

Farmfoods 0.6

Products were additionally sourced from Budgens, Premier (Happy Shopper) and Booths, for which individual market share data is not available, and from Marks & Spencer, for which data comparable to the above is not available. 2.2 Shopping Products lists were used to inform online shopping for those retailers that offered this service and in-store shopping for those who did not or where the required products could not be found online. Branded products were purchased via online shopping wherever available or in store where not. Between 28 October and 29 November 2013, twenty two shopping trips were completed, of which six were transacted on-line, across the fourteen different stores identified above. Inadvertent purchases of products outside the scope were discarded. Where duplicates were acquired they were separately assessed and used for error rate determination (see 3.6 below). The 496 unique samples were split between the product categories and sub-categories set out in Annex 1. 2.3 Assessment The sample assessment form (Annex 2) included a detailed and extensive series of questions, designed to generate the data necessary to meet the objectives of the project. The thirty-three questions were organised into two separate sections; the first section collected general information on the product, the second was specific to the origin of the product. The assessment forms were designed as protected Word forms. Bookmarks held the assessors' responses. These comprised drop-down boxes where response choice was limited to a predefined list (e.g. either ‘yes’ or ‘no’), and free text areas suitable for capturing text, such as exact origin statements given on labels. Each fieldname or bookmark was coded to include a question reference to facilitate data analysis at the next stage (e.g. ‘Q16Primary-ingred’ was the code for the question ‘Are there one or more obvious primary ingredients?’). Each assessment form was saved with the last five numbers of the barcode as the sample identifier. Assessments were conducted by seven Food Law Advisers experienced in food labelling and skilled in the systematic recording of information. Before undertaking assessments the assessors were instructed on the content of the assessment form and its completion.

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To enhance consistency a Consultant Assessor was available for discussion whilst the assessments were underway. Detailed Guidance Notes were also provided to ensure uniform interpretation (see Annex 3). Completed assessment forms were submitted by email to an in-house autoprocessor. This bespoke system recognises Word attachments according to data coded into the Word document. It is then able to cycle through all the fields (or bookmarks) in the Word document and add the data as an additional record to the corresponding Excel spreadsheet. In this way, assessment form data was consolidated into a single Excel spreadsheet. 2.4 Imaging As samples were assessed they were photographed using a Nikon D80 camera. Images were checked for clarity and coverage and additional photographs were taken where required. Several views were necessary to provide a suitable record. Images were saved as jpeg files, using the last four numbers of the sample barcode as an identifier, plus a sequential suffix (a, b, c etc) according to the number of shots taken. 2.5 Data analysis The auto processor output was subject to a sixteen step process, with reference back to assessment forms and photographs as appropriate, to check that each sample was correctly categorised by product category and type and to ensure that its assessment was complete, internally consistent and logical. After validation the data was analysed primarily in Excel, using database summary functions and data filtering. 2.6 Error rate determination As indicated above, the design of the assessment form, the development of guidance for its completion, and the designation of a Consultant Assessor to resolve uncertainties and divergences were all intended to reduce the likelihood that the analysed data would contain errors. In addition, extensive testing of the consistency of the data in the spreadsheet was undertaken by the Consultant Assessor for validation purposes. To calculate the likely residual error rate of data included in the final report, the number of fields in the assessment form requiring responses which could be viewed as matters of fact, rather than opinion, was identified as the basis for the calculation. There were 15 such fields. Eight samples had been assessed twice, either inadvertently or during testing of the assessment form, giving a total of 240 fields which were assumed to provide a reasonable representation of the total products sampled. Divergences between pairs of assessments were counted to provide an estimated error rate. Estimated error rate (14 errors from 240 fields) = 5.8% (95% CI 3.2%:9.6%) 2.7 Statistical analysis In the results and discussions set out in this report, where importance is often placed on proportions (such as 75% of beverage labels include product origin information) confidence intervals have been estimated on the proportion. For example “75% (95% CI 67%:82%)” indicates that the proportion observed in the survey was 75%, and that we are 95% certain that the corresponding proportion in the underlying population is between 67% and 82%. Interval estimations for single proportions are calculated by the method of Clopper and Pearson (16) (an "exact" method based on a relationship between the F distribution and the binomial distribution).

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3. Results 3.1 PRIMARY INGREDIENT STATUS OF SAMPLES PURCHASED Chart 1

Chart 1 shows a series of vertical bars, the first representing in total, 100% of all products sampled and each of the subsequent bars in total, 100% of each of eight individual product types. The bars are sub-divided on the basis of the primary ingredient status of the products represented by the bar. The top, clear segment of each bar, where this exists, represents the proportion of products of each type possessing no primary ingredient. The remainder of each bar then comprises, in total, the proportion possessing a primary ingredient, and is divided into an orange segment, representing those products where there is a primary ingredient but with no firm indication that it comprises more than 50% of the product, a lilac segment where the primary ingredient clearly makes up more than 50% of the product but not the whole product, and a green segment where the primary ingredient is the only ingredient (i.e. the product has only a single ingredient). The actual numbers of products in each segment are given. The sum of the numbers for each segment colour across the eight individual product types equals the numbers shown for the segments in the ‘All products’ bar. The results below are given separately for ‘products with primary ingredients’ (i.e. those products falling within the orange, lilac and green segments combined), ‘products with only a single ingredient’ (i.e. those products falling within the green segment) and ‘products with a clear above-50% ingredient’ (i.e. those falling within the lilac and green segments combined).

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3.2 PRODUCTS WITH PRIMARY INGREDIENTS The Food Information to Consumers Regulation (FIC) states, in Article 26(3): 3. Where the country of origin or the place of provenance of a food is given and where it is not the same as that of its primary ingredient: (a) the country of origin or place of provenance of the primary ingredient in question shall also be given; or (b) the country of origin or place of provenance of the primary ingredient shall be indicated as being different to that of the food. Key to this is the definition of a ‘primary ingredient’, which is given in Article 2(2)(q) of the Regulation: ‘primary ingredient’ means an ingredient or ingredients of a food that represent more than 50 % of that food or which are usually associated with the name of the food by the consumer and for which in most cases a quantitative indication is required Article 22 of the Regulation explains that quantitative indications are required for ingredients

mentioned in, or associated with, the name of the food, or

emphasised on the labelling in words, pictures or graphics, or

which are essential to characterise the food and to distinguish it from products with which it might be confused because of its name or appearance.

The two main determinants of a primary ingredient are therefore likely to be its proportion in the food and the extent to which it characterises the product. The introduction of this origin labelling requirement is subject to the adoption of an implementing act which is yet to be published. In the meantime, the future requirement will theoretically apply to all primary ingredients in all food products. The results in this section explore, for products judged by the assessors to possess one or more primary ingredients, the extent of origin labelling both of those primary ingredients and of the products as a whole. Critical to the forthcoming FIC requirement is whether the origin of the primary ingredient(s) is the same as that of the whole product. In this survey we have assessed information provided on labels alone. Where whole product origin is given unaccompanied by primary ingredient origin we can draw no conclusions as to whether the label will need to be changed to bring it into compliance with Article 26(3) of the FIC, as brought into application by the future implementing act. The results are summarised in the chart 2.

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Chart 2

The numbers at the top of each bar are the total numbers of all products (first bar) and of each product type (subsequent bars) which possess a primary ingredient. The segmentation of each bar gives the proportions of these products which give:

no origin information (blue segment)

origin information about only the primary ingredient (PI) (red segment)

origin information about both the primary ingredient and whole product (WP) (yellow segment)

origin information about only the whole product (green segment) 3.2.1 All Products with Primary Ingredients (see Chart 2 and Annex 1, Table 1.1) Of the 496 products assessed, 96% or 476 (represented by the full height of the ‘All products’ bar in Chart 2 above) were judged to possess at least one primary ingredient by the assessors. The single ingredient in single ingredient products and the predominant ingredient in products with one ingredient making up more than 50% of the food were always judged to be primary ingredients, so such products are all included in the 96%. 74% of the 476 products gave a whole product origin statement (e.g. ‘produced in the UK’), as represented by the combined green and yellow segments of the ‘All products’ bar in Chart 2 above. Only 23% of the 476 gave a primary ingredient origin statement (e.g. made with North American cranberries), as represented by the combined red and yellow segments of the ‘All products’ bar in Chart 2 above. Nearly all products with a primary ingredient origin statement gave a whole product origin statement as well (sometimes in one combined statement such as ‘Produced in the UK using Belgian milk chocolate’); only 8 products (less than 2% of the 476 products with primary ingredients) had labels giving primary ingredient origin statements but no whole product origin information (represented by the red segment of the ‘All products’ bar in Chart 2 above). Where products with primary ingredients gave both primary ingredient origin and whole product origin (the yellow segment of the Chart 2 bar), these origins were identical in 28% of cases (e.g. ‘produced in Italy’ and ‘made with Italian tomatoes’), while in 21% of cases the primary ingredient was indicated to have come from an area within that identified as the origin of the whole product (such as ‘produced in the UK’ and ‘Kentish hops’). In 24% of cases the origin of the primary ingredient was indicated to be a completely different place from that of the whole product (e.g. Brazil vs the EU) or to be a larger but

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defined area from within which the whole product was stated to originate (e.g. a product made in Cornwall with ‘West Country’ milk). It is these products to which the requirement of Article 26(3) of the Regulation clearly applies and which, by being marked with information on the different origin of the primary ingredient(s), meet the requirement. In the remaining samples giving both primary ingredient origin and whole product origin statements, the primary ingredient origin statements were non-specific, such as ‘produce of more than one country’. Of the 476 products in the survey judged to possess at least one primary ingredient, 251 (53% (95% CI 48%:57%)) gave a whole product origin statement unaccompanied by a primary ingredient origin statement (the green segment of the Chart 2 bar), and it is not possible to ascertain from this label survey how many of these products will need to undergo label changes to bring them into line with Article 26(3) of the Regulation. In 5% (95% CI 3%:7%) of cases, primary ingredient origin statements were very non-specific, e.g. ‘various countries’, ‘more than one country’.

3.2.2 Beverages with Primary Ingredients (see Chart 2 and Annex 1, Table 1.2)

Only one of the 133 beverage products sampled was judged not to possess a primary ingredient. This was a mixed fruit juice cordial, with no particular single fruit mentioned in the product’s name or given more prominence than any other on the label. A similar product was assessed as having water and fruit juices from concentrate as primary ingredients, and all similar products with names mentioning specific fruits were assessed as having fruit(s) as primary ingredients along with water. This perhaps demonstrates the inability of the Regulation’s definition of ‘primary ingredient’ always to enable a definitive decision on an ingredient’s status to be reached. It might also be asked whether the intention for products such as this is that water should be classified as a primary ingredient. These are points which the forthcoming implementing act may usefully address. For beverages, the proportions of products with primary ingredients bearing statements of whole product, primary ingredient or whole product and primary ingredient origin statements was very similar to those for all products. Where beverages gave both whole product and primary ingredient origin statements (represented by the yellow segment in the beverages bar of Chart 2), the proportions for which the origins were exactly the same or for which the primary ingredient came from within the larger area of origin of the whole product, were smaller than for all products. This perhaps reflects the necessarily distant origin of fruit such as citrus fruit, tea, coffee and cocoa for climatic reasons. 37% (95% CI 20%:56%) of beverage primary ingredient origin statements were very non-specific, e.g. ‘fruit from various countries’. 73 of the 132 beverage products with primary ingredients (55% (95% CI 46%:64%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (represented by the green segment of the beverages bar of Chart 2), a very similar proportion as with all products. The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act.

3.2.3 Cereals and Cereal Products with Primary Ingredients (see Chart 2 and Annex 1, Table 1.3) Again, almost all of these products were judged to possess one or more primary ingredients, but with a somewhat lower proportion than for all products giving primary ingredient origin information. The primary ingredient was in very many cases assessed as being the cereal component, which is perhaps an ingredient type the origin of which is not perceived as being an important influence on consumer purchasing decisions: it was reported in 2009 that only 5% of respondents in a survey looked for origin information on baked products such as bread and cakes, compared with 69% looking for such information on fruit and vegetables, and 57% on fresh meat (NatCen(17)).

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In fewer cases than for all products was the origin of the primary ingredient(s) different from that of the product as a whole, perhaps reflecting to some extent the ability to grow the common cereals other than rice in the UK. 55 of the 102 cereals and cereal products with primary ingredients (54% (95% CI 44%:64%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (represented by the green segment of the cereal products bar of Chart 2), a very similar proportion as with all products. The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act.

3.2.4 Confectionery with Primary Ingredients (see Chart 2 and Annex 1, Table 1.4)

As for other product categories, the proportion of confectionery products assessed as having one or more primary ingredients was very high. However, the occurrence of primary ingredient origin statements was very low and only one confectionery product gave both a whole product origin statement and a primary ingredient origin statement. This was a truffle product with a Belgian chocolate coating. In many cases the primary ingredient in this category was a sugar material which may be perceived to be a commodity for which origin is not particularly important to consumers (respondents to a survey in 2009 said that they most commonly used origin labelling for fruit and vegetables (69%), fresh meat (57%) and meat products (30%) (NatCen(17))). 24 of the 41 confectionery products with primary ingredients (59% (95% CI 42%:74%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (represented by the green segment of the confectionery bar of Chart 2), a not dissimilar proportion from other product categories. The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act.

3.2.5 Dairy Products with Primary Ingredients (see Chart 2 and Annex 1, Table 1.5) Only 2 of the 81 dairy products were assessed as not possessing a primary ingredient. These were a crème brûlée and a trifle, both in the desserts sub-category. Nearly all the rest of the dairy products were assessed as having milk or, in a few cases, yogurt, as the primary ingredient. With dairy products, whole product and primary ingredient origin statements were given to a greater extent than with other product categories (note the small size of the blue segment of the Dairy bar in Chart 2, relative to its size for most other food categories). This is perhaps not surprising: there is a perception that consumers are interested in the origin of dairy ingredients(18) and this is reflected in the existing UK industry-developed non-statutory guidance in this area, the Principles on Country of Origin Information (19). The Principles advise that liquid milk and fresh cream should be labelled with the country of origin of the milk, and cheese and butter with the country of origin of the milk or the place of manufacture. In Campden BRI’s 2012 Comparative Study to the National Country of Origin Labelling Evaluation 2011(3) it was reported that at the time of the study (early 2012), 93% of milk sold in the UK was marked with either an origin for the milk, a place of manufacture (i.e. whole product origin) or both. The equivalent percentages for fresh cream, cheese and butter were respectively: 67%, 76% and 100%. The corresponding percentages found in this survey (albeit with much lower sample numbers for milk and cheese) were, 78% (milk), 100% (cream), 96% (cheese) and 100% (butter). Desserts was the only dairy sub-category not covered by the Principles, and here, albeit on a very small sample size of 18 assessed as possessing a primary ingredient, only 33% (95% CI 13%:59%) gave a primary ingredient origin statement and only 67% (95% CI 41%:87%) a whole product origin statement, percentages somewhat lower than for the sub-category as a whole.

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Of those 30 dairy products giving both primary ingredient and whole product origin statements (the yellow segment of the Dairy bar in Chart 2), only four gave an origin for the primary ingredient which was outside, or potentially outside, the origin area of the whole product. In three of these cases, the whole product origin was specified very narrowly, at county or regional level with the milk being sourced from a wider area. In the other case, the origin of the milk was given as UK or Ireland with the product being produced in the UK. 36 of the 79 dairy products with primary ingredients (46% (95% CI 34%:57%)) gave a whole product origin statement without an accompanying primary ingredient (i.e. dairy ingredient) origin statement (as represented by the green segment of the Dairy bar in Chart 2). This is a slightly lower proportion not providing this accompanying information than generally, possibly because of perceived consumer interest in the origin of milk when used as an ingredient, as mentioned above. The labelling of some of these products may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act.

3.2.6 Oils with Primary Ingredients (see Chart 2 and Annex 1, Table 1.6)

Only 10 oils, all individual seed oils, were assessed for this survey. Virgin and extra virgin olive oils were excluded, as there is a legal requirement for these to be marked with an origin statement. In 9 of the 10 cases the oils were single ingredient foods, with the tenth containing added vitamin E. Clearly, in all 10 cases, the oil constituted a primary ingredient. In 4 cases an origin for the oil was stated and all these products also volunteered whole product origin (the yellow segment of the Oils bar in Chart 2). In 4 other cases whole product origin alone was volunteered (the green segment of the Oils bar in Chart 2). The labelling of one or more of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act. 3.2.7 Processed Fruit with Primary Ingredients (see Chart 2 and Annex 1, Table 1.7) This category included canned fruit, frozen fruit and dried fruit and nuts. In all cases, the fruit or nuts were assessed as being a primary ingredient. A very high proportion (90%) of this small sample gave a whole product origin statement (the green and yellow segments of the Processed Fruit bar in Chart 2), while 40% gave primary ingredient origin information (the yellow segment of the Processed Fruit bar in Chart 2). No samples from this category gave primary ingredient origin information but no whole product origin information (i.e. there is no red segment in the Processed Fruit bar in Chart 2). Three products gave very non-specific primary ingredient origin statements, e.g. ‘produce of various countries’. 10 of the 20 processed fruit products (50% (95% CI 27%:73%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (as represented by the green segment of the Processed Fruit bar in Chart 2). The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act. 3.2.8 Processed Vegetables with Primary Ingredients (see Chart 2 and Annex 1, Table 1.8) All but one of the 44 processed vegetable products assessed was judged to possess at least one primary ingredient, this being the vegetable(s). The product assessed as having no primary ingredient was a mixed vegetable product with no quantitative ingredient information. The proportion with primary ingredient origin statements was relatively high compared with some other categories (the yellow and red segments combined of the Processed Veg bar in Chart 2), and all but one of these also gave whole product origin (the lone product giving only a primary ingredient origin is represented by the red segment; those giving both primary ingredient and whole product origins, by the yellow segment). 20 of the 43 processed vegetable products with primary ingredients (47% (95% CI 31%:62%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (as

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represented by the green segment of the Processed Veg bar in Chart 2). The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act. 3.2.9 Miscellaneous Foods with Primary Ingredients (see Chart 2 and Annex 1, Table 1.9) Miscellaneous foods assessed comprised pickles and similar products, salad dressings and mayonnaise, vinegar, and sweet and savoury sauces and spreads. Of the 57 products assessed, 86% were judged to possess at least one primary ingredient. This is a low proportion compared with other product categories, perhaps reflecting the fact that these are generally quite heavily processed products with several ingredients none of which particularly, on their own, predominates or characterises. The proportion of products with primary ingredient(s) giving origin information, particularly for the primary ingredient(s), was on the low side compared with most other product categories (note the relatively large size of the blue segment and the relatively small size of the combined yellow and red segments of the Miscellaneous bar in Chart 2), again perhaps reflecting the perception that information on individual ingredients within such highly-processed multi-ingredient products is not a high priority for consumers. Only 8% of miscellaneous foods with primary ingredients gave both whole product and primary ingredient origins (the yellow segment of the Miscellaneous bar in Chart 2). 29 of the 49 miscellaneous foods with primary ingredients (59% (95% CI 44%:73%)) gave a whole product origin statement without an accompanying primary ingredient origin statement (as represented by the green segment of the Miscellaneous bar in Chart 2). The labelling of some of these may need to change to bring them into line with Article 26(3) of the Regulation, when brought into application by the implementing act. 3.3 PRODUCTS WITH ONLY A SINGLE INGREDIENT The Food Information to Consumers Regulation (FIC) states, in Article 26(5): 5. By 13 December 2014, the Commission shall submit reports to the European Parliament and the Council regarding the mandatory indication of the country of origin or place of provenance for the following foods: (a) types of meat other than beef and those referred to in point (b) of paragraph 2; (b) milk; (c) milk used as an ingredient in dairy products; (d) unprocessed foods; (e) single ingredient products; (f) ingredients that represent more than 50 % of a food. Article 26(7) further states that these reports may be accompanied by proposals to modify the relevant Union provisions. At the time of writing, the Commission had commissioned an external study(20) concerning origin labelling of unprocessed foods, single ingredient products and ingredients that constitute over 50% of a food, to inform the development of its reports in these areas. The Commission has published the terms of reference(21) for this study. The extension of mandatory origin labelling to single ingredient products is therefore a possibility in the medium term. This section of the Results looks at the current extent of origin labelling on those products, within the various categories assessed in this survey, which are single ingredient foods.

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Potentially, even a single ingredient food can have separate whole product and ingredient origins. Flour with no added nutrients, for instance, can be milled in one location from cereal grown in a different location. Similarly, pasta may be manufactured from distantly grown durum wheat. These may be regarded as single ingredient foods which have undergone at least a degree of processing and which could potentially be marked with two origin statements, one for the ingredient and one for its place of processing. In the list of foods for which mandatory origin labelling is to be considered by the Commission (Article 26(5) of the FIC), ‘unprocessed foods’ are classified separately from ‘single ingredient products’, suggesting that for the single ingredient products, the focus should be on processed products. Indeed, the terms of reference for the external study referred to above state: Single ingredient should only cover processed food. A strict interpretation of the term "single ingredient" could lead to a situation where a tomato puree might need to be analysed whilst a tomato puree containing salt or herbs not. A case by case analysis would need to be done. This category would include indicatively peeled tomatoes, sugar, seed oils, flaked grains, pop corns and snack nuts, potato crisps, spices, coffee, cacao powder, tea. and In the case of single ingredient foods (processed) and ingredients that represent more than 50% of a food, the country of origin of the food is to be determined in accordance with the Union Customs Code (see Article 2.2 of Regulation (EU) 1169/2011). This means that it would mainly correspond to the country of the last substantial transformation. However, the study will also examine the option of more extensive origin information. It would appear therefore that it is envisaged that a whole product origin statement (being that of the place of production or at least of last substantial change) would fulfil the possible future mandatory requirement under the FIC for origin labelling of single ingredient products. Where the only processing which a single ingredient product has undergone is a non-invasive physical change to extend shelf life, e.g. drying or freezing, then there may be nothing more than a place of packing to identify the origin of the product. While packing may not be regarded as a substantial change, for the purposes of this survey, place of packing statements were recorded as whole product origin statements. A strict view was taken on when a product was a single ingredient product. For instance, salted butter was not classified as a single ingredient product, nor were canned products in which the liquid medium contained ingredients other than water, e.g. pears in pear juice, sweetcorn in water with added salt. Chart 3 give data, for the single ingredient products in the survey, on the occurrence of whole product origin statements, as well as on statements referring to the origin of the single ingredient. The data is basically a subset of that shown in Chart 2 for products with primary ingredients, since the single ingredient in a single ingredient product was always classified as a primary ingredient.

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Chart 3

The numbers at the top of each bar are the total numbers of all products (first bar) and of each product type (subsequent bars) which possess only a single ingredient. The segmentation of each bar gives the proportions of these products which give:

no origin information (blue segment)

origin information about only the single ingredient (SI) (red segment)

origin information about both the single ingredient and whole product (WP) (yellow segment)

origin information about only the whole product (green segment) 3.3.1 All Products with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.1) Of the 496 products assessed, 26% were single ingredient products. 80% of these gave a whole product origin statement (the green and yellow segments combined of the All products bar of Chart 3) and 38% gave an origin for the single ingredient (the yellow and red segments combined of the All products bar of Chart 3). Of the 37% of single ingredient products giving origins for both the whole product and the single ingredient (the yellow segment of the All products bar of Chart 3), 33% identify the same place in both statements. In another 31% of cases, the single ingredient origin statement was very non-specific, e.g. ‘produce of more than one country’. 26 of the 131 single ingredient products in the survey (20% (95% CI 13%:28%)) did not give a whole product origin statement (see the red and blue segments combined of the All products bar of Chart 3). If mandatory origin labelling is introduced for single ingredient products this information will need to be added to the labels of these products. 3.3.2 Beverages with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.2) 32% of beverages in the survey were single ingredient products. These were products such as tea, coffee, cocoa, single fruit juices and water. 74% of these were marked with a whole product origin statement (the green and yellow segments combined of the Beverages bar of Chart 3).

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All products which gave an origin for the ingredient also gave an origin for the product as a whole (see the yellow segment of the Beverages bar of Chart 3 and note the absence of a red segment). A high proportion of ingredient origin statements (67% (95% CI 38%:88%)) were very non-specific (e.g. ‘produce of more than one country’). 11 of the 42 single ingredient beverage products in the survey (26% (95% CI 14%:42%)) did not give a whole product origin statement (see the blue segment of the Beverages bar of Chart 3). If mandatory origin labelling is introduced for single ingredient products this information will need to be added to the labels of these products. 3.3.3 Cereals and Cereal Products with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.3) Only 16% of cereals and cereal products in the survey were single ingredient products. These included pasta, rice, flour and a breakfast cereal. 82% of these gave a whole product origin statement (see the green and yellow segments combined of the Cereal Products bar of Chart 3). The continuing mandatory addition of nutrients to flour in the UK raises the issue of whether such flour would be regarded, for the purposes of origin labelling, as a single ingredient product. Even if not, such a multi-ingredient food may come within the scope of the Article 26(5) provision as an ‘unprocessed food’, or as a food with an above-50% ingredient. In the latter case (a food with an above-50% ingredient), it would be specifically the flour component whose origin would potentially need to be given. 3 of the 17 single ingredient cereals and cereal products in the survey (18% (95% CI 4%:43%)) did not give a whole product origin statement (see the blue segment of the Beverages bar of Chart 3). If mandatory origin labelling is introduced for single ingredient products this information will need to be added to the labels of these products (two flours and the breakfast cereal). 3.3.4 Confectionery with only a Single Ingredient None of these products (chocolates, gums, jellies, mints and sugar-based) were single ingredient products. Even the simplest boiled sweet has flavourings and colour-sources added to the sugar base. 3.3.5 Dairy Products with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.5) 59% of dairy products assessed in this survey were single ingredient products with the single ingredient identified as milk. Plain cream, butter, cheese and yogurt, with no added ingredients, were classified as single ingredient products. Salted butter was classified as a multi-ingredient product and therefore excluded from this part of the analysis. 88% of the single ingredient dairy products were labelled with a whole product origin statement (see the green and yellow segments combined of the Dairy bar of Chart 3). All but one of the products labelled with milk origin also gave whole product origin (the lone product is represented by the red segment of the Dairy bar of Chart 3). In just under half of the cases where milk and whole product origin were given, these origins were identical. 6 of the 48 single ingredient dairy products in the survey (13% (95% CI 5%:25%)) did not give a whole product origin statement (see the red and blue segments combined of the Beverages bar of Chart 3). If mandatory origin labelling is introduced for single ingredient products this information will need to be added to the labels of these products. 3.3.6 Oils with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.6) On a small sample of ten oils, nine possessed only a single ingredient. The tenth oil contained added vitamin E. All but one of the nine gave a whole product origin statement (see combined green and

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yellow segments of the Oils bar of Chart 3) and four gave an oil origin as well (see the yellow segment of the Oils bar of Chart 3). The one single ingredient oil without a whole product origin statement (represented by the blue segment of the Oils bar of Chart 3) would need to introduce such a statement if mandatory origin labelling was introduced, as potentially envisaged, for single ingredient products. 3.3.7 Processed Fruit with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.7) 35% of processed fruit samples in the survey were single ingredient products, these being dried or frozen fruits or, in one case, a nut product. All of these were marked with a whole product origin statement (the combined green and yellow segments make up the whole of the Processed Fruit bar in Chart 3). Four also gave an origin for the fruit or nut (see the yellow segment of the Processed Fruit bar in Chart 3). If origin labelling was made mandatory for single ingredient foods, all the single ingredient processed fruit products assessed in this survey may already be compliant, depending on how extensive were the exact rules for implementation. 3.3.8 Processed Vegetables with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.8) Only 11% of processed vegetable samples in the survey were single ingredient products, these being five examples of frozen or dried vegetables. Two of these five gave origin information, this comprising both whole product and ingredient origin statements (as represented by the yellow segment of the Processed Veg bar of Chart 3). In both cases the whole product statement was a ‘packed in...’ statement, identifying a different place from that of the origin of the ingredient. The 3 out of the 5 single ingredient processed vegetable products in the survey which did not offer a whole product origin statement (represented by the blue segment of the Processed Veg bar of Chart 3) will need to do so if mandatory origin labelling is introduced for single ingredient products. 3.3.9 Miscellaneous Foods with only a Single Ingredient (see Chart 3 and Annex 1, Table 2.9) Only 7% of the 57 miscellaneous foods in this survey were single ingredient foods, these being four plain vinegar products. Two of these were marked with a ‘produced in...’ statement (see the green segment of the Miscellaneous bar of Chart 3) and another, a wine vinegar, gave an origin statement for the grapes (see the red segment of the Miscellaneous bar of Chart 3). If mandatory origin labelling is introduced for single ingredient products, then assuming vinegar is not exempted from the requirement, it will need to be marked with whole product origin information. Two of the four vinegars in the survey were currently not so marked, as represented by the combined red and blue segments of the Miscellaneous bar of Chart 3. 3.4 PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT ‘Ingredients that represent more than 50% of a food’ are identified in Article 26(5) of the FIC as being subject to an assessment by the Commission, by 13 December 2014, as a candidate for the imposition of mandatory origin labelling. In furtherance of this, the Commission has commissioned an external study to cover this and two other candidate areas for mandatory origin labelling, namely unprocessed foods and single ingredient products (regarding single ingredient products, the current level of origin labelling provided in the UK is also subject to analysis in this report (see Section 4.2 above)). With regard to ‘ingredients that represent more than 50% of a food’, the terms of reference(21) of the external study describe the scope of this area as follows:

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the legislator seems to identify the ingredient as basic products, thus excluding processed ingredients such as industrial preparations. This section would include indicatively flour in bread. A list of other examples should be proposed by the consultant and agreed with the Commission's services. Moreover, the contractor should examine particular cases where it is already clear for the consumer that the raw material used is not cultivated in the EU (like cocoa beans for a Belgian chocolate) and in which cases the absence of the indication of its origin would not create doubts or confusion for the consumers. Also stated in the terms of reference is: In the case of single ingredient foods (processed) and ingredients that represent more than 50% of a food, the country of origin of the food is to be determined in accordance with the Union Customs Code (see Article 2.2 of Regulation (EU) 1169/2011). This means that it would mainly correspond to the country of the last substantial transformation. However, the study will also examine the option of more extensive origin information. Any eventual requirement in this area may therefore be limited to ingredients which are of a relatively unprocessed nature, and the origin information related to place of last substantial change. The commissioned study may therefore need to address what type of origin information would be appropriate for ingredients which were not subjected to any substantial changes between, for instance, harvesting and use on the final product. For the assessors, a definite answer to the question as to whether a product contained an ingredient present at over 50% was not always possible, and indeed, ‘don’t know’ was one of the choices for selection in answer to this question on the assessment form. The uncertainty arises where an above 50% ingredient is not identified by being given a quantitative ingredient declaration (‘QUID’) and where the quantity of the ingredient is not otherwise obviously above 50% (e.g. it is obvious, without a QUID percentage being given, that the oil in sunflower oil with vitamin E, is present in the final product at above 50%). Altogether, uncertainty as to whether a product possessed an above-50% ingredient was registered for 189 products, including for various bakery products, sauces, sugar confectionery and chocolate, jams and other spreads, chewing gum, yeast extract and breakfast cereals. Chart 4 gives data, for the products with a clear above-50% ingredient in the survey, on the occurrence of origin statements for that ingredient, as well as on statements referring to the origin of the product as a whole. The data is basically a subset of that shown in Chart 2 for products with primary ingredients, since an above-50% ingredient was always classified as a primary ingredient. This data also, of course, includes all the single ingredient product data.

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Chart 4

The numbers at the top of each bar are the total numbers of all products (first bar) and of each product type (subsequent bars) which possess a clear above-50% primary ingredient. The segmentation of each bar gives the proportions of these products which give:

no origin information (blue segment)

origin information about only the clear above-50% primary ingredient (PI) (red segment)

origin information about both the clear above-50% primary ingredient and whole product (WP) (yellow segment)

origin information about only the whole product (green segment) 3.4.1 All Products with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.1) Of the 496 products assessed, 265 or 53% were judged to have a clear, above-50% ingredient. The proportions offering the various combinations of origin information were not dissimilar to those for all products with primary ingredients and all products with only a single ingredient. A slight trend may be discernible, from products with primary ingredients to products with an above-50% ingredient to products with a single ingredient, for an increased level of ingredient origin information. This could reflect the increasing predominance of one ingredient through these categories, and the resulting perceived increasing importance of giving consumers information about that ingredient. Far more products offered whole product origin information than ingredient origin information. 183 of the 265 products with a clear above-50% ingredient in the survey (69% (95% CI 63%:75%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the All products bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. 3.4.2 Beverages with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.2) 62% of beverages were assessed as having a clear above-50% ingredient (e.g. coffee, tea, a fruit juice, water, carbonated water). Again, looking across the three ingredient-based classifications of the products, there was a tendency for ingredient origin information to become more prevalent in the order: beverages with primary ingredients, beverages with a clear above-50% ingredient, beverages with only a single ingredient.

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59 of the 82 beverages with a clear above-50% ingredient in the survey (72% (95% CI 61%:81%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Beverages bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Far more of these products gave whole product origin information (the green and yellow segments combined of the Beverages bar of Chart 4) than gave ingredient origin information (the yellow and red segments combined of the Beverages bar of Chart 4). 3.4.3 Cereals and Cereal Products with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.3) 32% of cereals and cereal products were assessed as having a clear above-50% ingredient (e.g. flour, rice, semolina). Again, looking across the three ingredient-based classifications of the products, there was a tendency for ingredient origin information to become more prevalent in the order: cereals and cereal products with primary ingredients, cereals and cereal products with a clear above-50% ingredient, cereals and cereal products with only a single ingredient. 26 of the 34 cereals and cereal products with a clear above-50% ingredient in the survey (76% (95% CI 59%:89%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Cereal Products bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Far more of these products gave whole product origin information (the green and yellow segments combined of the Cereal Products bar of Chart 4) than gave ingredient origin information (the yellow and red segments combined of the Cereal Products bar of Chart 4). 3.4.4 Confectionery with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.4) 16% of confectionery products were assessed as having a clear above-50% ingredient (e.g. a polyol, cocoa, chocolate). This amounted to only 7 products, the labelling of none of which included origin information for that ingredient. This will have to be provided if mandatory origin labelling is introduced for such ingredients. 3.4.5 Dairy Products with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.5) 88% of dairy products were assessed as having a clear above-50% ingredient (milk or, in a few cases, yogurt). Compared with foods with above-50% ingredients in other categories, the level of ingredient origin offered was relatively high at 40% (represented by the yellow and red segments combined of the Dairy bar of Chart 4), reflecting national non-statutory guidance covering these products, as mentioned earlier (see section 4.2.5). There was very little variation in the degree of ingredient origin information offered for dairy products, whether they were classified as with primary ingredients, with an above-50% ingredient or with a single ingredient. 43 of the 71 dairy products with a clear above-50% ingredient in the survey (61% (95% CI 48%:72%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Dairy bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Far more of these products gave whole product origin information (the green and yellow segments combined of the Dairy bar of Chart 4) than gave ingredient origin information (the yellow and red segments combined of the Dairy bar of Chart 4).

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3.4.6 Oils with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.6) All the oils were assessed as having a clear above-50% ingredient, this being the oil. This is exactly the same set of data as for the oils with primary ingredients (see section 4.1.6): it is all the oils in the survey. 6 of the 10 oils with a clear above-50% ingredient in the survey (60% (95% CI 26%:88%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Oils bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Far more of these products gave whole product origin information (the green and yellow segments combined of the Oils bar of Chart 4) than gave ingredient origin information (the yellow segment of the Oils bar of Chart 4). 3.4.7 Processed Fruit with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.7) 65% of processed fruit products were assessed as having a clear above-50% ingredient, this being the type of fruit (or in one case, nut). 8 of the 13 processed fruit products with a clear above-50% ingredient in the survey (62% (95% CI 32%:86%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Processed Fruit bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Based on this small sample, more of these products give whole product origin information (the green and yellow segments combined of the Processed Fruit bar of Chart 4) than give ingredient origin information (the yellow segment of the Processed Fruit bar of Chart 4). 3.4.8 Processed Vegetables with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.8) 71% of processed vegetable products were assessed as having a clear above-50% ingredient, this being the type of vegetable. 18 of the 31 processed vegetable products with a clear above-50% ingredient in the survey (58% (95% CI 39%:75%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Processed Veg bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products. Far more of these products gave whole product origin information (the green and yellow segments combined of the Processed Veg bar of Chart 4) than gave ingredient origin information (the yellow and red segments of the Processed Veg bar of Chart 4). 3.4.9 Miscellaneous Foods with a Clear Above-50% Ingredient (see Chart 4 and Annex 1, Table 3.9) 30% of miscellaneous foods were assessed as having a clear above-50% ingredient. 16 of the 17 miscellaneous foods with a clear above-50% ingredient in the survey (94% (95% CI 71%:100%)) did not give an origin statement for that ingredient (as represented by the green and blue segments combined of the Miscellaneous bar of Chart 4). If mandatory origin labelling is introduced for such ingredients, this information will need to be added to the labels of these products.

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Based on this small sample, more of these products give whole product origin information (the green segment of the Miscellaneous bar of Chart 4) than give ingredient origin information (the red segment of the Miscellaneous bar of Chart 4). 3.5 IMPLICATIONS OF ORIGIN (see Annex 1, Tables 4.1-4.9) Implications of origin are an important consideration legally, since under the FIC(1), if there are implications of origin in the material supplied with a food which could cause the consumer to reach an inaccurate conclusion as to the food’s origin, then a correcting origin statement is required. This is a continuing provision from the 2000 Directive(22). Implications typically take the form of depictions of national flags (or of the colours and/or patterns of such flags), or of famous buildings or natural landmarks, such as the Eiffel Tower, Houses of Parliament or Giant’s Causeway. As part of the assessments, data was collected on possible implications of origin given on the labels of the products. A view was taken, during assessments, as to whether an implication was of whole product origin or primary ingredient origin. In either case, it was also documented whether the implication was accompanied on the label by a corresponding true origin statement. An inspection of product labels which do not bear explicit origin information cannot, of course, reveal whether, in fact, any origin implied is the true origin, which can stand on its own, or is a misleading origin which should be accompanied by an explicit origin statement. Tables 4.1-4.9 summarise data on the proportions of products bearing implications of origin and the extent to which these implications are accompanied by specific origin statements. 19% of the products assessed in this survey (i.e. 95 of 496 products) were judged to be bearing implications of origin. Of these 95 products, 87% bore implications of whole product origin, and again of these 95 products, 25% bore implications of both whole product and primary ingredient origin. 38% of the 95 products bore implications of primary ingredient origin. Whole product origin implications were in nearly all cases accompanied on labels by whole product origin statements, but primary ingredient origin implications were accompanied by primary ingredient origin statements less frequently. For instance, in 11 cases depictions of the Union Jack flag in connection with primary ingredients were not accompanied by statements of the UK origin of those ingredients. Implications of origin were far more prevalent on dairy products than on other product types and the use of the Union Jack flag, often in conjunction with the ‘Red Tractor’ logo, was particularly common. 4. Discussion and Conclusions 4.1 PRODUCTS WITH PRIMARY INGREDIENTS The primary ingredient origin labelling requirement is a firm requirement under Article 26(3) of the Regulation, but its application is subject to the interpretation of the definition of a ‘primary ingredient’ and to further implementing rules, yet to be published. The definition makes reference to ingredient(s) which represent over 50% of the food or are associated with the food by the consumer, and in most cases are required to be given a quantitative indication (QUID). QUID rules under the FIC are the same as those in the outgoing legislation and include, for instance, an exemption from QUIDing for ingredients which although mentioned in the food’s name, play a minor role in consumer choice because the variation in their quantity is not a decisive factor for the nature of the product (e.g. the potato in a beef and potato pie). It remains to be seen whether such non-nature-determining ingredients may, on this basis, fall outside the scope of the primary ingredient origin labelling requirement. The future implementing rules may give further general interpretation of the ‘primary ingredient’ definition, addressing issues such as the above, as well as elucidation of the requirements

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on a product category specific basis. In the meantime, for a few products there can be an element of subjectivity as to whether they possess a primary ingredient according to the definition laid down in the FIC. The primary ingredient origin labelling requirement is only triggered when whole product origin is volunteered and the primary ingredient comes from a different place. The data given below is for products where whole product origin, but not primary ingredient origin, was given. These are the potentially non-compliant products; as a study only of information given on labels it is not possible to determine, for those labels which are silent on primary ingredient origin, whether changes will be required once the Article 26(3) provision is enacted. The primary ingredients in some of these products will undoubtedly have originated from the place identified as the origin of the product and these products are then outside the scope of the requirement and are not non-compliant. Others may be exempted from the requirement by the forthcoming implementing rules. The proportions given below, of products with primary ingredients which are potentially non-compliant, range from 40% to 59% across the product categories, but are very much maximum proportions which are likely to be reduced significantly because of the above two considerations. Where remedial action for these products becomes necessary under the future implementing rules, this could comprise providing origin information for the primary ingredient (even if this is only to indicate that it originates from a different place from the product’s place of manufacture) or removing the information on the product’s place of manufacture if other legal constraints and commercial considerations allow this.

PRODUCTS WITH PRIMARY INGREDIENTS

Product Category Numbers and percentages giving whole product, but not primary ingredient origin

All products 251 of 476 (53%) (95% CI 48%:57%)

Beverages 73 of 132 (55%) (95% CI 46%:64%)

Cereals and cereal products 55 of 102 (54%) (95% CI 44%:64%)

Confectionery 24 of 41 (59%) (95% CI 42%:74%)

Dairy products 36 of 79 (46%) (95% CI 34%:57%)

Oils 4 of 10 (40%) (95% CI 12%:74%)

Processed Fruit 10 of 20 (50%) (95% CI 27%:73%)

Processed Vegetables 20 of 43 (47%) (95% CI 31%:62%)

Miscellaneous Foods 29 of 49 (59%) (95% CI 44%:73%)

4.2 PRODUCTS WITH ONLY A SINGLE INGREDIENT While in some cases it may be open to conjecture whether a particular product possesses one or more primary ingredients and this may be clarified for particular product types in the forthcoming implementing rules, it is generally clearer when a product has only a single ingredient. Single ingredient products are a candidate class of foods for a future requirement for origin information provision under the FIC. Indications currently are that the Commission’s thinking in considering the possibility of imposing this requirement is that it should comprise place of processing information. In this survey, 20% of prepacked single ingredient foods did not provide place of processing information. For some individual product categories, however, it should be noted that numbers of single ingredient foods in the survey were very low with, for instance, the 60% of single ingredient processed vegetable products which gave no place of processing information representing only three products, and the 50% of miscellaneous foods which were similarly uninformative representing only two products. As the terms of reference of the Study on the mandatory indication of origin or place of provenance of unprocessed foods, single ingredient products and ingredients that represent more than 50% of a food(21), commissioned by the EU Commission points out, the main types of foods which could be affected by the introduction of a requirement for mandatory origin information on processed single ingredient foods could include sugar, seed oils, flaked grains, popcorn, spices, coffee, cocoa powder and tea. Also, as the terms of reference point out, if mandatory origin information was introduced for

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single ingredient foods, some consideration will be necessary of the position of products which are single ingredients apart from the addition of small quantities of herbs, spices, salt or perhaps, additives etc.

PRODUCTS WITH ONLY A SINGLE INGREDIENT

Product Category Numbers and percentages not giving place of processing information

All products 26 of 131 (20%) (95% CI 48%:57%)

Beverages 11 of 42 (26%) (95% CI 14%:42%)

Cereals and cereal products 3 of 17 (18%) (95% CI 4%:43%)

Confectionery No single ingredient products

Dairy products 6 of 48 (13%) (95% CI 5%:25%)

Oils 1 of 9 (11%) (95% CI 0%:48%)

Processed Fruit 0 of 7 (0%) (95% CI 0%:41%)

Processed Vegetables 3 of 5 (60%) (95% CI 15%:95%)

Miscellaneous Foods 2 of 4 (50%) (95% CI 7%:93%)

While numbers of single ingredient products are low, the interpretation of the data in terms of the proportion of labels requiring change should a mandatory origin labelling provision be introduced, is not subject to the same uncertainty which surrounds the primary ingredient data. It is generally very clear when a product has only a single ingredient and the absence of an indication of place of processing leaves no uncertainty that a change would be required. 4.3 PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT There was more uncertainty in determining numbers of products falling into this category than with products with primary ingredients and products with only a single ingredient. As discussed in Section 3.4, for 189 products there was uncertainty as to whether they possessed an above-50% ingredient, and these products were not included within this category. However, once placed in this category, it is clear whether origin information is being given or not for the above-50% ingredient. In the survey overall, about twice as many products were assessed as possessing a clear above-50% ingredient as were assessed as being single ingredient products. The former category (products with an above-50% ingredient) obviously includes all of the latter (single ingredient products), as well as additional products where it was clear that one ingredient made up more than half of the product, but not all of it. The potential requirement with products possessing a clear above-50% ingredient is for the origin of that ingredient to be indicated. Across all product categories, relatively high proportions of products with a clear above-50% ingredient did not give this information. Numbers of products in the survey with a clear above-50% ingredient were however quite low for some product categories, e.g. confectionery, where none of seven qualifying products gave origin indications for the above-50% ingredient. For all product categories, whole product origin statements were much more common than origin information for the above-50% ingredient. In considering numbers of products with a clear above-50% ingredient which would be non-compliant if giving origin information for that ingredient became mandatory, it should be noted that the terms of reference of the EU-commissioned study(21) put forward the view that any requirement would be likely to apply only to relatively unprocessed ingredients (such as for instance flour, but perhaps not sugar). In addition, where it is clear that an ingredient has not been cultivated in the EU (e.g. cocoa beans), there may be no requirement.

PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT

Product Category Numbers and percentages not giving origin of the above-50% ingredient

All products 183 of 265 (69%) (95% CI 63%:75%)

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Beverages 59 of 82 (72%) (95% CI 61%:81%)

Cereals and cereal products 26 of 34 (76%) (95% CI 59%:89%)

Confectionery 7 of 7 (100%) (95% CI 59%:100%)

Dairy products 43 of 71 (61%) (95% CI 48%:72%)

Oils 6 of 10 (60%) (95% CI 26%:88%)

Processed Fruit 8 of 13 (62%) (95% CI 32%:86%)

Processed Vegetables 18 of 31 (58%) (95% CI 39%:75%)

Miscellaneous Foods 16 of 17 (94%) (95% CI 71%:100%)

4.4 CONCLUDING REMARKS The FIC specifically introduces origin labelling for primary ingredients originating from a different source from that volunteered for the whole product. However, this provision will not apply until an implementing act, informed by an impact assessment, is in place. To the extent that this survey reflects origin labelling practices in the whole market (see Section 2.1), it suggests that potentially, up to about half of the labels of products with primary ingredients in the marketplace may need to add primary ingredient origin statements once the requirement is in place. This is very much a maximum figure, as for an unknown proportion of products the unstated origin of the primary ingredient will be the same as the stated origin of the whole product, resulting in no requirement for additional labelling. Should a requirement for place of processing information be introduced for the single ingredient in single ingredient foods, then this survey suggests that 20% of the labels of such foods currently lack this information and would need to be amended accordingly. A much higher proportion of products, about 70%, with a clear above-50% ingredient do not offer origin information for that ingredient and would need to be amended should the requirement for this information become mandatory. Finally, it is worth considering the overlap between these requirements or potential requirements. An ingredient which is a primary ingredient may also make up more than 50% of a food. Subject to future implementing rules and legal requirements, this ingredient may be subject to mandatory origin labelling under its status as an above-50% ingredient, irrespective of whether, as a primary ingredient, it originates from a different location from the volunteered origin of the product as a whole. Equally, the single ingredient of single ingredient products will also be an above 50% ingredient, and if origin labelling requirements for single ingredient products and above-50% ingredients are introduced, a single ingredient product could potentially be required to be marked with both a place of processing and a place of sourcing of the ingredient.

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5. References

1. 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, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004. Official Journal of the European Union, 22.11.2011, L 304, 18-63.

2. Commission Implementing Regulation (EU) No 1337/2013 of 13 December 2013 laying down

rules for the application of Regulation (EU) No 1169/2011 of the European Parliament and of the Council as regards the indication of the country of origin or place of provenance for fresh, chilled and frozen meat of swine, sheep, goats and poultry. Official Journal of the European Union, 14.12.2014, L 335, 19-22.

3. Campden Technology Ltd (2012). 2012 Comparative study to the National Country of Origin

Labelling Evaluation 2011. Campden Technology Ltd, Chipping Campden

4. CCFRA Technology Ltd (2005). An assessment of the uptake of Food Standards Agency guidance on Country of Origin Labelling. CCFRA Technology Ltd, Chipping Campden

5. Campden Technology Ltd (2010). An assessment of the uptake of Food Standards Agency guidance on Country of Origin Labelling. Campden Technology Ltd, Chipping Campden.

6. Campden & Chorleywood Food Research Association (2008). Monitoring implementation of alcohol labelling regime (including advice to women on alcohol and pregnancy). Campden & Chorleywood Food Research Association, Chipping Campden.

7. Campden BRI (2009). Monitoring implementation of alcohol labelling regime stage 2 (including advice to women on alcohol and pregnancy). Campden BRI, Chipping Campden.

8. Hucker, R. (editor) (2013) Market report 2013: Cooking sauces and food seasonings. 6th edition. Key Note Publications

9. Hucker, R. (editor) (2013) Market report 2013: Breakfast cereals. 17th edition. Key Note

Publications.

10. Hughes, K. (editor) (2013) Market report plus 2013: Confectionery. 31st edition. Key Note Publications

11. Tutt, L. (editor) (2011) Market assessment 2011: Hot beverages. 6th edition. Key Note

Publications

12. Tutt, L. (editor) (2012) Market report 2012: Milk and dairy products. 26th edition. Key Note Publications

13. Tutt, L. (editor) (2013) Market report plus 2013: Biscuits and cakes. 20th edition. Key Note

Publications

14. Tutt, L. (editor) (2013) Market report 2013: Bread and bakery products. 28th edition. Key Note Publications

15. Kantar Worldpanel (2013) Market share total till roll. http://www.kamcity.com/(accessed 9 October 2013)

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16. Clopper, C.J. and Pearson, E.S. (1934). The use of confidence or fiducial limits illustrated in the case of the binomial. Biometrika, 26(4), pp. 404-413.

17. National Centre for Social Research (2009). Country of Origin Labelling: Omnibus Research Report. Prepared for the Food Standards Agency.

18. Food Standards Agency. Food Labelling: Country of Origin Guidance, October 2008.

19. Principles of Country of Origin Labelling. November 2010

20. EU Commission Notification of Commissioned External Study to Inform its Report to the European Parliament and Council regarding the mandatory indication of the country of origin or place of provenance for unprocessed foods, single ingredient products and ingredients that constitute over 50% of a food (accessed 9 June 2014)

21. EU Commission Terms of Reference for External Study: ‘Study on the mandatory indication of origin or place of provenance of unprocessed foods, single ingredient products and ingredients that represent more than 50% of a food’ (accessed 9 June 2014)

22. Directive 2000/13/EC of the European Parliament and of the Council of 20 March 2000 on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs

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6. Acknowledgements The authors would like to express their gratitude to the many individuals who contributed time, expertise and support to this survey. Particular thanks are due to Zoe Donkin and Oliver Hamilton of Defra for their patience and helpful advice.

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Annex 1 Summary Tables These Tables give data on the origin indications found on products categorised as with primary ingredients, with only a single ingredient and with a clear above-50% ingredient. Data is given within these categories for each product type studied in the survey (e.g. beverages, dairy products). ‘Occurrence’ refers to the number of samples of each product type with a primary, single or above-50% ingredient, out of the total number of samples of that product type in the survey. For instance, out of 133 beverage samples in the survey, 132 possessed a primary ingredient. Further figures are then given for those products with a primary, single or above-50% ingredient to indicate whether their labelling offered:

whole product origin information

primary, single or above-50% ingredient origin information as appropriate and

both the above types of origin information Where both types of origin information are given, the geographical relationship between the two originating areas identified in the information is further explored unless the imprecision of the information prevents this (e.g. ‘fruit juice from various countries’). It is because of this limitation that the percentage figures given in this comparison of the two origin statements, where they exist, do not total to 100%. 1. PRODUCTS WITH PRIMARY INGREDIENTS Table 1.1: All Products with Primary Ingredients

count % (95% CI)

Occurrence 476/496 96 (93 - 98) Of which give primary ingredient origin 111/476 23 (20 - 27) Of which give whole product origin 354/476 74 (70 - 78) Of which give primary ingredient origin and whole product origin 103/476 22 (18 - 26) Of which primary ingredient origin is different from whole product origin*

25/103 24 (16 - 34)

Of which primary ingredient origin is within a larger whole product origin area**

22/103 21 (14 - 31)

Of which primary ingredient and whole product origins are identical

29/103 28 (20 - 38)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

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Table 1.2: Beverages with Primary Ingredients

count % (95% CI)

Occurrence 132/133 99 (95 - 100) Of which give primary ingredient origin 30/132 23 (16 - 31) Of which give whole product origin 100/132 76 (68 - 83) Of which give primary ingredient origin and whole product origin 27/132 20 (14 - 28) Of which primary ingredient origin is different from whole product origin*

10/27 37 (19 - 58)

Of which primary ingredient origin is within a larger whole product origin area**

3/27 11 (2 - 29)

Of which primary ingredient and whole product origins are identical

3/27 11 (2 - 29)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 1.3: Cereals and Cereal Products with Primary Ingredients

count % (95% CI)

Occurrence 102/108 94 (88 - 98) Of which give primary ingredient origin 16/102 16 (9 - 24) Of which give whole product origin 70/102 69 (59 - 77) Of which give primary ingredient origin and whole product origin 15/102 15 (8 - 23) Of which primary ingredient origin is different from whole product origin*

2/15 13 (2 - 40)

Of which primary ingredient origin is within a larger whole product origin area**

3/15 20 (4 - 48)

Of which primary ingredient and whole product origins are identical

5/15 33 (12 - 62)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 1.4: Confectionery with Primary Ingredients

count % (95% CI)

Occurrence 41/43 95 (84 - 100) Of which give primary ingredient origin 2/41 5 (1 - 17) Of which give whole product origin 25/41 61 (45 - 76) Of which give primary ingredient origin and whole product origin 1/41 2 (0 - 13) Of which primary ingredient origin is different from whole product origin*

1/1 100 (3 - 100)

Of which primary ingredient origin is within a larger whole product origin area**

0/1 0 (0 - 98)

Of which primary ingredient and whole product origins are identical

0/1 0 (0 - 98)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

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Table 1.5: Dairy Products with Primary Ingredients

count % (95% CI)

Occurrence 79/81 98 (91 - 100) Of which give primary ingredient origin 31/79 39 (28 - 51) Of which give whole product origin 66/79 84 (74 - 91) Of which give primary ingredient origin and whole product origin 30/79 38 (27 - 50) Of which primary ingredient origin is different from whole product origin*

4/30 13 (4 - 31)

Of which primary ingredient origin is within a larger whole product origin area**

9/30 30 (15 - 49)

Of which primary ingredient and whole product origins are identical

15/30 50 (31 - 69)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 1.6: Oils with Primary Ingredients

count % (95% CI)

Occurrence 10/10 100 (69 - 100) Of which give primary ingredient origin 4/10 40 (12 - 74) Of which give whole product origin 8/10 80 (44 - 98) Of which give primary ingredient origin and whole product origin 4/10 40 (12 - 74) Of which primary ingredient origin is different from whole product origin*

2/4 50 (68 - 93)

Of which primary ingredient origin is within a larger whole product origin area**

1/4 25 (1 - 81)

Of which primary ingredient and whole product origins are identical

1/4 25 (1 - 81)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 1.7: Processed Fruit with Primary Ingredients

count % (95% CI)

Occurrence 20/20 100 (83 - 100) Of which give primary ingredient origin 8/20 40 (19 - 64) Of which give whole product origin 18/20 90 (68 - 99) Of which give primary ingredient origin and whole product origin 8/20 40 (19 - 64) Of which primary ingredient origin is different from whole product origin*

3/8 38 (9 - 76)

Of which primary ingredient origin is within a larger whole product origin area**

0/8 0 (0 - 37)

Of which primary ingredient and whole product origins are identical

2/8 25 (32 - 65)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

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Table 1.8: Processed Vegetables with Primary Ingredients

count % (95% CI)

Occurrence 43/44 98 (87 - 100) Of which give primary ingredient origin 15/43 35 (21 - 51) Of which give whole product origin 34/43 79 (64 - 90) Of which give primary ingredient origin and whole product origin 14/43 33 (19 - 49) Of which primary ingredient origin is different from whole product origin*

4/14 29 (8 - 58)

Of which primary ingredient origin is within a larger whole product origin area**

6/14 43 (18 - 71)

Of which primary ingredient and whole product origins are identical 2/14 14 (2 - 43) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 1.9: Miscellaneous Foods with Primary Ingredients

count % (95% CI)

Occurrence 49/57 86 (74 - 94) Of which give primary ingredient origin 5/49 10 (3 - 22) Of which give whole product origin 33/49 67 (52 - 80) Of which give primary ingredient origin and whole product origin 4/49 8 (2 - 20) Of which primary ingredient origin is different from whole product origin*

3/4 75 (19 - 99)

Of which primary ingredient origin is within a larger whole product origin area**

0/4 0 (0 - 60)

Of which primary ingredient and whole product origins are identical

1/4 25 (1 - 81)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

2. PRODUCTS WITH ONLY A SINGLE INGREDIENT Table 2.1: All Products with only a Single Ingredient

count % (95% CI)

Occurrence 131/496 26 (23 - 31) Of which give single ingredient origin 50/131 38 (30 - 47) Of which give whole product origin 105/131 80 (72 - 87) Of which give single ingredient origin and whole product origin 48/131 37 (28 - 46) Of which single ingredient origin is different from whole product origin*

9/48 19 (9 - 33)

Of which single ingredient origin is within a larger whole product origin area**

8/48 17 (7 - 30)

Of which single ingredient and whole product origins are identical

16/48 33 (20 - 48)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

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Table 2.2: Beverages with only a Single Ingredient

count % (95% CI)

Occurrence 42/133 32 (23 - 41) Of which give single ingredient origin 15/42 36 (22 - 52) Of which give whole product origin 31/42 74 (58- 86) Of which give single ingredient origin and whole product origin 15/42 36 (22 - 52)

Of which single ingredient origin is different from whole product origin*

2/15 13 (2 - 40)

Of which single ingredient origin is within a larger whole product origin area**

1/15 7 (0 - 32)

Of which single ingredient and whole product origins are identical

2/15 13 (2 - 40)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 2.3: Cereals and Cereal Products with only a Single Ingredient

count % (95% CI)

Occurrence 17/108 16 (9 - 25) Of which give single ingredient origin 6/17 35 (14 - 62) Of which give whole product origin 14/17 82 (57 - 96) Of which give single ingredient origin and whole product origin 6/17 35 (14 - 62)

Of which single ingredient origin is different from whole product origin*

0/6 0 (0 - 46)

Of which single ingredient origin is within a larger whole product origin area**

0/6 0 (0 - 46)

Of which single ingredient and whole product origins are identical

3/6 50 (12 - 88)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

N.B. None of the confectionery products sampled possessed only a single ingredient and hence there is no analysis of such products. To maintain consistency in notation, there is no Table 2.4. Table 2.5: Dairy Products with only a Single Ingredient

count % (95% CI)

Occurrence 48/81 59 (48 - 70) Of which give single ingredient origin 18/48 38 (24 - 53) Of which give whole product origin 42/48 88 (75 - 95) Of which give single ingredient origin and whole product origin 17/48 35 (22 - 51)

Of which single ingredient origin is different from whole product origin*

1/17 6 (0 - 29)

Of which single ingredient origin is within a larger whole product origin area**

6/17 35 (14 - 62)

Of which single ingredient and whole product origins are identical

8/17 47 (23 - 72)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

38

Table 2.6: Oils with only a Single Ingredient

count % (95% CI)

Occurrence 9/10 90 (55 - 100) Of which give single ingredient origin 4/9 44 (14 - 79) Of which give whole product origin 8/9 89 (52 - 100) Of which give single ingredient origin and whole product origin 4/9 44 (14 - 79)

Of which single ingredient origin is different from whole product origin*

2/4 50 (7 – 93)

Of which single ingredient origin is within a larger whole product origin area**

1/4 25 (1 - 81)

Of which single ingredient and whole product origins are identical

1/4 25 (1 - 81)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 2.7: Processed Fruit with only a Single Ingredient

count % (95% CI)

Occurrence 7/20 35 (15 - 60) Of which give single ingredient origin 4/7 57 (18 - 90) Of which give whole product origin 7/7 100 (59 - 100) Of which give single ingredient origin and whole product origin 4/7 57 (18 - 90)

Of which single ingredient origin is different from whole product origin*

2/4 50 (7 - 93)

Of which single ingredient origin is within a larger whole product origin area**

0/4 0 (0 - 60)

Of which single ingredient and whole product origins are identical

2/4 50 (7 - 93)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 2.8: Processed Vegetables with only a Single Ingredient

count % (95% CI)

Occurrence 5/44 11 (4 - 25) Of which give single ingredient origin 2/5 40 (5 - 85) Of which give whole product origin 2/5 40 (5 - 85) Of which give single ingredient origin and whole product origin 2/5 40 (5 - 85)

Of which single ingredient origin is different from whole product origin*

2/2 100 (16 - 100)

Of which single ingredient origin is within a larger whole product origin area**

0/2 0 (0 - 84)

Of which single ingredient and whole product origins are identical

0/2 0 (0 - 84)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

39

Table 2.9: Miscellaneous Foods with only a Single Ingredient

count % (95% CI)

Occurrence 4/57 7 (1 - 18) Of which give single ingredient origin 1/4 25 (1 - 81) Of which give whole product origin 2/4 50 (7 - 93) Of which give single ingredient origin and whole product origin 0/4 0 (0 - 60)

Of which single ingredient origin is different from whole product origin*

0/0 ** (0 - 100)

Of which single ingredient origin is within a larger whole product origin area***

0/0 ** (0 - 100)

Of which single ingredient and whole product origins are identical

0/0 ** (0 - 100)

*This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **Division by zero ***This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

3. PRODUCTS WITH A CLEAR ABOVE-50% INGREDIENT Table 3.1: All Products with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

265/496 53 (48 - 58) Of which give above-50% ingredient origin

82/265 31 (24 - 37)

Of which give whole product origin

203/265 77 (71 - 82) Of which give above-50% ingredient origin and whole product

origin

78/265 29 (24 - 35) Of which above-50% ingredient origin is different from

whole product origin*

17/78 22 (13 - 33) Of which above-50% ingredient origin is within a larger

whole product origin area**

17/78 22 (13 - 33) Of which above-50% ingredient and whole product origins are

identical 22/78 28 (19 - 40) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 3.2: Beverages with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

82/133 62 (52 - 70) Of which give above-50% ingredient origin

23/82 28 (19 - 39)

Of which give whole product origin

61/82 74 (64 - 83) Of which give above-50% ingredient origin and whole product origin

22/82 27 (18 - 38)

Of which above-50% ingredient origin is different from whole product origin*

5/22 23 (8 - 45)

Of which above-50% ingredient origin is within a larger whole product origin area**

2/22 9 (1 - 29)

Of which above-50% ingredient and whole product origins are identical 2/22 9 (1 - 29) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

40

Table 3.3: Cereals and Cereal Products with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

34/108 32 (22 - 42) Of which give above-50% ingredient origin

8/34 24 (11 - 41)

Of which give whole product origin

25/34 74 (56 - 87) Of which give above-50% ingredient origin and whole product origin

8/34 24 (11 - 41)

Of which above-50% ingredient origin is different from whole product origin*

1/8 13 (0 - 53)

Of which above-50% ingredient origin is within a larger whole product origin area**

0/8 0 (0 - 37)

Of which above-50% ingredient and whole product origins are identical 3/8 38 (9 - 76) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 3.4: Confectionery with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

7/43 16 (6 - 31) Of which give above-50% ingredient origin

0/7 0 (0 - 41)

Of which give whole product origin

2/7 29 (4 - 71) Of which give above-50% ingredient origin and whole product origin

0/7 0 (0 - 41)

Of which above-50% ingredient origin is different from whole product origin*

0/0 ** (0 - 100)

Of which above-50% ingredient origin is within a larger whole product origin area***

0/0 ** (0 - 100)

Of which above-50% ingredient and whole product origins are identical 0/0 ** (0 - 100) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **Division by zero ***This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 3.5: Dairy Products with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

71/81 88 (78 - 94) Of which give above-50% ingredient origin

28/71 40 (28 - 52)

Of which give whole product origin

61/71 86 (76 - 93) Of which give above-50% ingredient origin and whole product origin

27/71 38 (27 - 50)

Of which above-50% ingredient origin is different from whole product origin*

4/27 15 (4 - 38)

Of which above-50% ingredient origin is within a larger whole product origin area**

9/27 33 (17 - 54)

Of which above-50% ingredient and whole product origins are identical 12/27 44 (25 - 65) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

41

Table 3.6: Oils with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

10/10 100 (69 - 100) Of which give above-50% ingredient origin

4/10 40 (12 - 74)

Of which give whole product origin

8/10 80 (44 - 98) Of which give above-50% ingredient origin and whole product origin

4/10 40 (12 - 74)

Of which above-50% ingredient origin is different from whole product origin*

2/4 50 (68 - 93)

Of which above-50% ingredient origin is within a larger whole product origin area**

1/4 25 (1 - 81)

Of which above-50% ingredient and whole product origins are identical 1/4 25 (1 - 81) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 3.7: Processed Fruit with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

13/20 65 (40 - 85) Of which give above-50% ingredient origin

5/13 38 (14 - 68)

Of which give whole product origin

11/13 85 (55 - 98) Of which give above-50% ingredient origin and whole product origin

5/13 38 (14 - 68)

Of which above-50% ingredient origin is different from whole product origin*

3/5 60 (15 - 95)

Of which above-50% ingredient origin is within a larger whole product origin area**

0/5 0 (0 - 52)

Of which above-50% ingredient and whole product origins are identical 2/5 40 (5 - 85) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

Table 3.8: Processed Vegetables with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

31/44 71 (54 - 84) Of which give above-50% ingredient origin

13/31 42 (25 - 61)

Of which give whole product origin

26/31 84 (66 - 95) Of which give above-50% ingredient origin and whole product origin

12/31 39 (22 - 58)

Of which above-50% ingredient origin is different from whole product origin*

3/12 25 (5 - 57)

Of which above-50% ingredient origin is within a larger whole product origin area**

5/12 42 (15 - 72)

Of which above-50% ingredient and whole product origins are identical 2/12 17 (2 - 48) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

42

Table 3.9: Miscellaneous Foods with a Clear Above-50% Ingredient

count % (95% CI)

Occurrence

17/57 30 (18 - 44) Of which give above-50% ingredient origin

1/17 6 (0 - 29)

Of which give whole product origin

9/17 53 (28 - 77) Of which give above-50% ingredient origin and whole product origin

0/17 0 (0 - 20)

Of which above-50% ingredient origin is different from whole product origin*

0/0 ** (0 - 100)

Of which above-50% ingredient origin is within a larger whole product origin area***

0/0 ** (0 - 100)

Of which above-50% ingredient and whole product origins are identical 0/0 ** (0 - 100) *This is where the origins of the product and primary ingredient are completely different non-overlapping areas, or the area of origin of the primary ingredient is a larger area encompassing a smaller product origin area. **Division by zero ***This is where the primary ingredient is stated to originate from an area entirely within the area stated to be the origin of the product as a whole, e.g. potatoes from Lincolnshire, product made in the UK.

4. IMPLICATIONS OF ORIGIN Table 4.1: All Products with Implications of Origin

count % (95% CI)

Occurrence 95/496 19 (15 - 23)

Of which implications are of whole product origin

83/95 87 (79 - 93)

Of which also carry a clear whole product origin statement

77/83 93 (84 - 98)

Of which implications are of primary ingredient origin

36/95 38 (28 - 48)

Of which also carry a clear primary ingredient origin statement

21/36 58 (40 - 75)

Table 4.2: Beverages with Implications of Origin

count % (95% CI)

Occurrence

13/133 10 (5 - 17) Of which implications are of whole product

origin

11/13 85 (55 - 98)

Of which also carry a clear whole product origin statement

11/11 100 (71 - 100)

Of which implications are of primary ingredient origin

5/13 38 (14 - 68)

Of which also carry a clear primary ingredient origin statement

5/5 100 (47 - 100)

43

Table 4.3: Cereals and Cereal Products with Implications of Origin

count % (95% CI)

Occurrence

21/108 19 (12 - 29) Of which implications are of whole product

origin

20/21 95 (76 - 100)

Of which also carry a clear whole product origin statement

18/20 90 (68 - 99)

Of which implications are of primary ingredient origin

3/21 14 (3 - 36)

Of which also carry a clear primary ingredient origin statement

2/3 67 (9 - 100)

Table 4.4: Confectionery with Implications of Origin

count % (95% CI)

Occurrence

2/43 5 (0 - 16) Of which implications are of whole product

origin

2/2 100 (16 - 100)

Of which also carry a clear whole product origin statement

2/2 100 (16 - 100)

Of which implications are of primary ingredient origin

0/2 0 (0 - 84)

Of which also carry a clear primary ingredient origin statement

0/0 † (0 - 100)

† division by zero

Table 4.5: Dairy Products with Implications of Origin

count % (95% CI)

Occurrence

41/81 51 (39 - 62) Of which implications are of whole product

origin

37/41 90 (77 - 97)

Of which also carry a clear whole product origin statement

35/37 95 (81 - 100)

Of which implications are of primary ingredient origin

16/41 39 (24 - 55)

Of which also carry a clear primary ingredient origin statement

6/16 38 (15 - 65)

Table 4.6: Oils with Implications of Origin

count % (95% CI)

Occurrence

1/10 10 (0 - 45) Of which implications are of whole

product origin

1/1 100 (3 - 100)

Of which also carry a clear whole product origin statement

1/1 100 (3 - 100)

Of which implications are of primary ingredient origin

1/1 100 (3 - 100)

Of which also carry a clear primary ingredient origin statement

1/1 100 (3 - 100)

44

Table 4.8: Processed Vegetable Products with Implications of Origin

count % (95% CI)

Occurrence

11/44 25 (13 - 41) Of which implications are of whole product

origin

7/11 64 (31 - 89)

Of which also carry a clear whole product origin statement

6/7 86 (42 - 100)

Of which implications are of primary ingredient origin

9/11 82 (48 - 98)

Of which also carry a clear primary ingredient origin statement

7/9 78 (39 - 98)

Table 4.9: Miscellaneous Products with Implications of Origin

count % (95% CI)

Occurrence

6/57 11 (3 - 22) Of which implications are of whole product

origin

5/6 83 (36 - 100)

Of which also carry a clear whole product origin statement

4/5 80 (28 - 100)

Of which implications are of primary ingredient origin

2/6 33 (4 - 78)

Of which also carry a clear primary ingredient origin statement

0/2 0 (0 - 85)

45

Annex 2 Categorisation of samples with numbers assessed in each sub-category

Main category Sub-category

Beverages (133) Bedtime drinks (8)

Beer (19)

Cocoa (5)

Coffee (15)

Juices (fruit & vegetable) (22)

Soft drinks (carbonated) (42)

Soft drinks (non-carbonated) (8)

Tea (6)

Water (bottled, flavoured) (8)

Cereals & cereal products (108) Biscuits (25)

Bread (23)

Other bakery products (25)

Breakfast cereals (14)

Flour (7)

Pasta (7)

Rice (7)

Confectionery (43) Chocolate (22)

Gums & jellies (7)

Mints (7)

Sugar based (7)

Dairy (81) Butter (12)

Cheese (24)

Cream (7)

Desserts (20)

Milk (18)

Miscellaneous foods (57) Pickles, chutneys & relish (7)

Salad dressings & mayonnaise (7)

Sauces (savoury) (7)

Sauces (sweet) (7)

Sauces (table) (7)

Spreads (savoury) (7)

Spreads (sweet) (8)

Vinegar (7)

Oils (10) Individual seed oils (10)

Processed fruit (20) Canned (7)

Dried fruit and nuts (7)

Frozen (6)

Processed vegetables (44) Bottled (7)

Canned (7)

Crisps (14)

Dried (7)

Frozen & chilled (9)

TOTAL SAMPLES ASSESSED: 496

46

Annex 3 Assessment form

Q1 Assessor Code (Empty)

SECTION 1: GENERAL PRODUCT INFORMATION

Q2 Brand/marketing name (incl. brandowner’s name) Type here

Q3 Branded/Own-label (if a retailer named, it’s own-label) (Empty)

Q4 Legal Name of food Type here

Q5 Barcode (no spaces) Type here

Q6.1 Main Product Category - Beverages (Empty)

Q6.2 Main Product Category - Cereals & Cereal products (Empty)

Q6.3 Main Product Category - Confectionery (Empty)

Q6.4 Main Product Category - Dairy (Empty)

Q6.5 Main Product Category - Oils (Empty)

Q6.6 Main Product Category - Processed Fruit (Empty)

Q6.7 Main Product Category – Processed Vegetables (Empty)

Q6.8 Main Product Category – Miscellaneous Foods (Empty)

Q7 What is the price given on the receipt (£)? Type here

Q8 Weight or Volume Type here

Q9 Temperature state (Empty)

Q10 Date statement Type here

Q11 Lot mark (if found; might begin ‘L1234’ – do not include spaces, if no Lot mark, type ‘None’)

Type here

Q12 Name given in address details Type Here

Q13 Postcode (with the space in the middle) Type here

SECTION 2: ORIGIN INFORMATION

Q14 Is the product a single ingredient or a multi-ingredient product? (e.g. frozen peas are a single ingredient product, biscuits are a multi-ingredient product)

(Empty)

Q15 Is there one ingredient which makes up more than 50% of the food?

(Empty)

Q16 Are there one or more obvious primary ingredients? (Primary Ingredient’ means an ingredient or ingredients of a food that represent more than 50 % of that food or which are usually associated with the name of the food by the consumer and for which in most cases a quantitative indication is required)

(Empty)

Q17 If yes, state the primary ingredient(s) Type here

Q18 Are there any clear statements and/or any implications of origin of any sort, however vague? (incl. ‘made in UK’, ‘British’, ‘Packed in’, overt or suggested flags, iconic buildings, landmarks, logos or over prominent business address or hygiene marks etc.). Include the ingredient declaration, when checking the details. If ‘No’, your assessment is complete.

(Empty)

Q19 Is an origin statement in words given which refers to the product as a whole? (e.g. ‘produced in’, but also includes ‘packed in’, ‘sliced in’ etc)

(Empty)

47

Q20 If ‘Yes’ give the exact statement Type here

Q21 Is there any statement in words referring to the origin of the primary ingredient(s)? (This may include statements such as ‘X from various countries’)

(Empty)

Q22 If ‘Yes’ give the exact statement If ‘No’ go to question Q28

Type here

Q23 Are all primary ingredient origin statements completely non-specific? (e.g., ‘various countries’, ‘elsewhere’, ‘globally sourced’) If ‘Yes’, go to question Q28. Also, if you answered No to Q19, go to Q28

(Empty)

Q24 Are the origins of the primary ingredient(s) and the whole product exactly the same? (i.e., count ‘British’, ‘Britain’, Great Britain’ as the same, whereas UK is not the same as Britain, England is not the same as Devon) If ‘Yes’, go to Q28.

(Empty)

Q25 Is the primary ingredient(s) from a larger geographical region which contains a smaller region where the whole product comes from? (e.g. made with ingredients from EU, produced in UK)

(Empty)

Q26 Is the primary ingredient(s) from a smaller geographical area within a larger area where the whole product comes from? (e.g. made with ingredients from Norfolk, produced in the UK)

(Empty)

Q27 Is the origin of the primary ingredient(s) from a completely separate geographical area from the area where the whole product comes from? (e.g. made with pork from the Netherlands produced in the UK, made with chicken from Thailand, produced in EU)

(Empty)

Q28 Are there any implications of origin of any sort? (incl. clear or subtly suggested flags, iconic buildings, landmarks, logos etc. or over prominent business address or hygiene marks etc.) If no, your assessment is complete.

(Empty)

Q29 Describe the implications (e.g. colours of French flag)

Type here

Q30 What place does this imply to you (e.g., Houses of Parliament may imply the UK to you)

Type here

Q31 Is the implication that of the product origin as a whole or of an ingredient used within the product, or both? If of product origin, your assessment is complete.

(Empty)

Q32 What is the ingredient? Type here

Q33 Is this the primary ingredient? (Empty) vCoOLOct2013

48

Annex 4 Guidance for Assessors

Defra Country of Origin Labelling (vCoOL) Survey 2013 Guidance Notes for Assessors Tips For Navigating in a Form When a form is locked, you can only fill in those areas which are form fields (normally shaded grey). You can use the mouse to select fields, or else use the tab or arrow keys. Form fields: There are two types of form fields:- (1) Drop down boxes. When you select this field, a drop down arrow appears. Mouse: If you click into it, the selection list appears. Left-click to select the appropriate choice (usually, ‘yes’, ‘no’). Keyboard: ALT+down arrow to make the selection list appear. Navigate the list using arrow keys. Press Enter to accept. Alternatively, once you have the selection list, you can press the starting letter of the choice (e.g. ‘y’ for ‘yes’). If two choices start with the same letter, press the ‘y’ again for the second option starting with ‘y’, for example. (2) Text boxes. Type normally into the text boxes. If you press Enter, you will start a new line in the box. NB: spell checking does not work in forms, so please check your typing! Navigating in a Form: You can make use of the GoTo command to navigate a form. In Office 2007, click the “Page:” button on the Status bar at the bottom of the screen. The keyboard shortcut F5 works in all versions of Word (and Excel). Choose a page number to jump to, or else select ‘Bookmark’ and choose a question reference in the ‘bookmark name’ dropdown list. CTRL + HOME takes you to the start of the form, CTRL + END takes you to the end. Completing the Assessment Form Open the single, generic blank form at L:\2013\Contracts\Current\Defra vCoOL 131384 Objective 4 – logging, assessing, photography\ASSESSMENT FORMS\Blank form As soon as you have opened the form, please do ‘Save as’ and save as L:\2013\Contracts\Current\Defra vCoOL 131384 Objective 4 – logging, assessing, photography\ASSESSMENT FORMS\In progress\xxxxx, where xxxxx is the last 5 numbers of the barcode of the product, e.g. 97584. This is so that the blank form becomes available asap for others to open and to avoid the blank form being changed inadvertently into a partially completed or completed assessment. Q1 Assessor Code – select your initials from the drop down box SECTION 1: GENERAL PRODUCT INFORMATION Q2 Brand/marketing name This is often given on the front of packs, e.g. ‘Marks & Spencer 2 Crème Brulees’

49

‘Nestle Pure Life still spring water’ ‘Kellogg’s Special K’ Please always include the name of the brand, e.g. ‘Tesco Finest’, ‘Princes’, ‘Kellogg’s’, ‘Yeo Valley’. Q3 Branded or Own label State if the product is an own brand, such as ‘Tesco’ or ‘Waitrose’, or a branded product such as ‘Princes’. Take care with Lidl and Aldi own-label products as it not always obvious that these are own-label. If the word ‘Lidl’ or ‘Aldi’ appears anywhere in the small print, it is an own-label product. Q4 Legal name of food This may be given on the back of packs and fulfils the legal requirement to give a detailed name for a food. If there is more than one product name on the pack, the legal name is likely to be the most detailed version of the name. Examples are: ‘Crème Brulee with a Sachet of Demerara Sugar for you to Brulee for a Light Caramelised Topping’; ‘3 dark chocolate & macadamia bars baked with dark chocolate & raisins Clue: The legal name may be found near, or on the same face as, the weight/volume indication. N.B. the wording of the brand/marketing name my also be functioning as the legal name, so you may not be able to find a legal name which is different from the brand/marketing name. Q5 Bar Code Type the full number without spaces. Use the last five digits of the bar code as the code for saving the survey document. Q6.1 to 6.8 Only complete the question relevant to your product, then go straight to Q7 Q6.1 Main Product Category - Beverages Select the relevant sub category product type from the drop-down list. Q6.2 Main Product Category – Cereals & Cereal products Select the relevant sub category product type from the drop-down list. Q6.3 Main Product Category – Confectionery Select the relevant sub category product type from the drop-down list. Q6.4 Main Product Category – Dairy Select the relevant sub category product type from the drop-down list. Q6.5 Main Product Category – Oils Select the relevant sub category product type from the drop-down list. Q6.6 Main Product Category – Processed Fruit Select the relevant sub category product type from the drop-down list. Q6.7 Main Product Category – Processed Vegetables Select the relevant sub category product type from the drop-down list. Q6.8 Main Product Category – Miscellaneous Foods Select the relevant sub category product type from the drop-down list.

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Q7 What is the price given on the receipt? In units of £, but just give the figures, e.g. ‘0.78’, ‘2.34’ Q8 Weight/volume State the weight or volume, e.g. ‘160g’, ‘1.5L’. If the indication is in the form ‘[number] x Yg’, please record this followed by the word ‘multipack’, e.g. ‘4x250g multipack’. A few products will have only a number and no weight: in these cases just record the number as a digit plus any other associated text given with it on the labelling, e.g. ’14 pieces’, ‘8 tabs’. If there is no associated text, just follow the digit by a full stop, e.g. ‘6.’ If a product has no weight, volume or number, please state ‘no indication’. Q9 Temperature state State the temperature that the product would normally be sold in, e.g., Ambient, Frozen, Chilled. Q10 Date statement E.g. ‘Use by 03 Jun’ or ‘Best Before End Aug12’. It is not important to adhere to the case of the letters Q11 Lot Mark Possibly will not be present, but typically this will be ink-jetted numbers and/or letters near the date statement, perhaps beginning with a capital ‘L’. It may include or comprise numbers which appear to be identifying a time. Do not include spaces. Q 12 Name given in address details Usually, the name given at the beginning of the address details (typically a retailer for own-label products, a manufacturer for branded products). For the retailers, the common form of the name can be given without apostrophes, e.g. Iceland, Morrisons, Aldi, Lidl, Londis, Tescos, Sainsburys, Co-op, Asda. For manufacturers, give the full name as it appears, e.g. Premier Grocery Products Ltd. Always give the retailer’s name if the product was categorised as ‘own label’ in Q3. Q 13 Postcode State the postcode with spaces in the middle. SECTION 2: ORIGIN INFORMATION It may be difficult to decide whether a feature on the label constitutes an implication of origin. IN ALL CASES WHERE YOU ARE UNSURE PLEASE SEEK ADVICE FROM DAVID LEEKS (2156). Q 14 Is the product a single ingredient or a multi-ingredient product? (e.g. frozen peas are a single ingredient product, biscuits are a multi-ingredient product) Single ingredient products refer to products such as Frozen Peas, Honey, Milk, Rice. Record plain cream, butter, cheese, yogurt, fromage frais, dried plain pasta as single ingredient products. Multi-ingredient products refer to products with more than one ingredient, such as Chocolate, Crisps, Sauces. Although it may not have an ingredients list, beer is a multi-ingredient product. Q15 Is there one ingredient which makes up more than 50% of the food? If this is obvious, then answer yes or no. However, it may not be possible to make a decision as to the % of the ingredient within the product (unless of course there is a QUID indication). If this is the case, then state ‘Don’t know’. Answer ‘Yes’ for single ingredient products. Q16 Are there one or more obvious primary ingredients? (Primary Ingredient’ means an ingredient or ingredients of a food that represent more than 50% of that food or which are usually associated with the name of the food by the consumer and for which in most cases a quantitative indication is required) Answer ‘Yes’ for a single ingredient product – the single ingredient is the primary ingredient. An ‘unQUIDed’ ingredient can be a primary ingredient, e.g. the potato in potato crisps.

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Q17 If yes, state the primary ingredient(s) If you think there is more than one primary ingredient, list them all, separated by full stops. Q18 Are there any clear statements and/or any implications of origin of any sort, however vague? (incl. ‘made in UK’, ‘British’, ‘Packed in’, overt or suggested flags, iconic buildings, landmarks, logos or over prominent business address or hygiene marks etc.). Include the ingredient declaration, when checking the details. If ‘No’, your assessment is complete. Answer ‘Yes’ if there are any clear statements and/or any implications of origin, whether in the form of words, symbols, pictures or photographs. The business name and address details are not a statement or implication of origin unless they appear to have been emphasised so as potentially to indicate origin Q20 If ‘Yes’ give the exact statement If there is more than one statement, give them all, separated by full stops. Q21 Is there any statement in words referring to the origin of the primary ingredient(s)? (This may include statements such as ‘X from various countries’) This is relevant even for a single ingredient product, which may, for instance, be marked ‘milk from UK, packed in UK’ Q22 If ‘Yes’ give the exact statement If ‘No’ go to question Q28 If there is more than one statement, give them all, separated by full stops. Q24 Are the origins of the primary ingredient(s) and the whole product exactly the same? (i.e., count ‘British’, ‘Britain’, Great Britain’ as the same, whereas UK is not the same as Britain, England is not the same as Devon) If ‘Yes’, go to Q28. Britain, Great Britain and British can all be classed as one, whereas the UK is not the same as Britain because only the UK includes Northern Ireland. To answer ‘Yes’, the two origins must identify exactly the same total area. Q31 Is the implication that of the product origin as a whole or of an ingredient used within the product, or both? If of product origin, your assessment is complete. This is relevant even for a single ingredient product, which may, for instance, be dry pasta showing an ear of wheat with the Union Jack colours, implying wheat from the UK. STORAGE OF COMPLETED FORM The form you have just completed should be in the ‘In progress’ folder and should have been named using the last five digits of the number associated with the barcode of the product if present or, if not, the last five digits of another unique number on the packaging. Please do a final ‘Save’ and CUT AND PASTE (not copy) the completed form into the ‘Completed’ folder: L:\2013\Contracts\Current\Defra vCoOL 131384\Objective 4 – logging, assessing, photography\ASSESSMENT FORMS\Completed PHOTOGRAPHY You are not required to take photographs of the products.