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Criteria For The Use of The Terms Fresh, Pure, Natural Etc in Food Labelling

This document provides criteria for using terms like "fresh", "natural", and "pure" in food labeling to avoid misleading consumers. It recommends that "fresh" only be used if it has a clear meaning, such as for fruit salads made from fruit or dairy products held under chilled conditions with a limited shelf life. Terms like "ocean fresh" should be avoided. Pictorials must not mislead consumers about a product's type, quality or origin. Any claims made about a food must be technically substantiated.

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0% found this document useful (0 votes)
141 views

Criteria For The Use of The Terms Fresh, Pure, Natural Etc in Food Labelling

This document provides criteria for using terms like "fresh", "natural", and "pure" in food labeling to avoid misleading consumers. It recommends that "fresh" only be used if it has a clear meaning, such as for fruit salads made from fruit or dairy products held under chilled conditions with a limited shelf life. Terms like "ocean fresh" should be avoided. Pictorials must not mislead consumers about a product's type, quality or origin. Any claims made about a food must be technically substantiated.

Uploaded by

Joan Petit Gros
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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CRITERIA FOR THE USE OF THE TERMS FRESH,

PURE, NATURAL ETC IN FOOD LABELLING


CRITERIA FOR THE USE OF THE TERMS FRESH, PURE, NATURAL ETC
IN FOOD LABELLING

CONTENTS:

INTRODUCTION Page 3

BACKGROUND Page 3

RELEVANT LEGISLATION Page 4

GENERAL ADVICE Page 4

RECOMMENDED CRITERIA –

“fresh” Page 6

“natural” Page 10

“pure” Page 13

“traditional” Page 15

“original” Page 16

“authentic” Page 17

“home made” Page 18

“farmhouse” Page 19

CONTACT DETAILS Page 20

Revised December 2002 2


INTRODUCTION

1. The Food Standards Agency is committed to promoting informed choice.


Improving food labelling is one of our priority objectives.

2. Consumers are concerned about the way some descriptions on labels


have lost their true meaning. This conclusion has emerged from
consumer research, public consultations and correspondence.

3. Our aims in producing this advice on use of these terms are to help:

• manufacturers, producers, retailers and caterers to decide when these


descriptions could be used and when they should not
• enforcement authorities to challenge inappropriate uses
• consumers, by encouraging the adoption of consistent, transparent
labelling practices.

4. This advice should not be taken as an authoritative statement or


interpretation of the law, as only the courts have this power. Ultimately,
only the courts can decide whether, in particular circumstances, an offence
has been committed.

BACKGROUND:

5. The Agency invited the Food Advisory Committee (FAC) to investigate the
use of a number of terms and advise how misuse might be avoided.
These terms were:

• Fresh • Original
• Natural • Authentic
• Pure • Home-made
• Traditional • Farmhouse

6. The FAC concluded1 that the basic requirements of the Food Safety Act
1990, the Trade Descriptions Act 1968 and the Food Labelling Regulations
1996 were sufficient in principle to ensure that consumers are not misled
in this area of claims.

7. However, the FAC also found that these terms were being misused in
some cases, and that there was clear room for improvement. It felt that
use had in some cases become far-removed from generally accepted
meanings and had the potential to mislead consumers, even after making
due allowance for changes to the accepted meaning and use of words
over time. The Committee made a number of recommendations, which
have been taken as the basis for this advice.

1
“FAC Review of the use of the terms Fresh, Pure, Natural etc in Food Labelling 2001” –
FSA/0334/0701.

Revised December 2002 3


RELEVANT LEGISLATION

8. This advice relates to, and should be read in conjunction with, the
provisions of

q Article 16 of Regulation (EC) No 178/2002 (on the general principles


and requirements of food law)

this requires that the labelling, advertising and presentation of food,


and the information made available about it through whatever medium,
should not mislead consumers

q Article 2 of Directive 2000/13/EC (on food labelling)

this requires that the labelling, advertising and presentation of a food


must not be such as could mislead a purchaser to a material degree,
particularly
- as to the characteristics of the food and, in particular, as to its
nature, identity, properties, composition, quantity, durability, origin
or provenance, method of manufacture or production;
- by attributing to the food effects or properties that it does not
possess;
- by suggesting the food possesses special characteristics when in
fact all similar foods possess such characteristics

q the Food Safety Act 1990

this prohibits the sale of any food that is not of the nature, substance or
quality demanded by the purchaser; and makes it an offence to
describe, present or advertise food in a way that is false or likely to
mislead the consumer

q the Trade Descriptions Act 1968

this makes it an offence to apply a false trade description to any goods,


including specific information on quantity, size and composition, how
they were made and by whom

q the general provisions of the Food Labelling Regulations 1996

GENERAL ADVICE

9. This advice applies equally to all food, regardless of whether it is


prepacked or not, and regardless of the type of outlet from which it is sold.

10. General labelling principles are applicable to the use of all the terms
covered by this advice. As with all other aspects of claims

Revised December 2002 4


• foods should be sold without deceit and should be so labelled and
advertised as to enable a prospective purchaser to make a fair and
informed choice, based on clear and informative labelling;
• a food must be able to fulfil the claim being made for it and adequate
information must be available to show that the claim is justified;
• where a claim is potentially ambiguous or imprecise, the likely
understanding of an average consumer should prevail;
• controls should protect both consumers and honest traders;
• controls should allow fair comparison and competition between
products, sectors and traders;
• if consumer and trader interests conflict, the interests of consumers
must take precedence.

11. Pictures on labels and in advertisements have a powerful effect on


prospective purchasers and, in some product sectors, may have a greater
significance than names and other descriptive material. Pictorial
representations should be subject to the same scrutiny and control as the
words used to portray similar images and concepts. Care should be taken
to ensure that background illustrations and pictorial material do not
mislead the consumer as to the type, quality or origin of the product. For
example

• country scenes may lead a consumer to believe that animal products


have been obtained from extensively reared, free-range animals;
• kitchen scenes may lead a consumer to believe a product is hand-made
or at least produced in a small-scale operation.

12. The labelling and presentation of the food as a whole should be used in
assessing whether a particular label or description is likely to be
considered misleading. Where a consumer might be misled by pictorial
representations, any potential ambiguity must be clarified by equally clear
and prominent labelling.

13. Any use of the terms covered by this advice must be capable of technical
substantiation. Where there is any doubt over the likely interpretation of
the phrase or description being used, the most likely interpretation of a
typical consumer should prevail.

14. Notwithstanding the various potential meanings of these terms in the


different contexts in which they are used, it should always be clear in each
case what characteristic of a product is being described.

15. It is not helpful to use “style” or “type” to qualify the terms covered by this
advice (eg “traditional style”).

Revised December 2002 5


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“FRESH”

16. The description “fresh” can be helpful to consumers where it differentiates


produce that is sold within a short time after production or harvesting.
However, modern distribution and storage methods can significantly retard
the effects of this lapse of time, and it has become increasingly difficult to
decide when the term is being used legitimately

17. The term can also be helpful when used to identify products that have not
been processed. In these cases it is important to be clear what is meant
by processing: excluding the use of chill temperatures and other controlled
atmospheres for the delayed ripening and/or extended storage of fruit and
vegetables or washing and trimming would seem unnecessarily restrictive.

18. “Fresh” is often used in a number of phrases that may have an emotive
appeal but no real meaning (eg “oven fresh”, “garden fresh”, “ocean fresh”,
“kitchen fresh”, etc).

General:

19. The use of the term “fresh” in some specific circumstances is sanctioned in
law (eg “Traditional Farmfresh Turkey” 2 , “extra fresh” eggs 3 and “fresh”
poultry4).

20. Otherwise, the term “fresh” should only be used where it has a clear
meaning. The description can help consumers differentiate between
similar products, for example:

• fresh fruit salad that is made only from fresh fruit


• fresh dairy products (such as cream) held under chilled conditions at
point of sale, with limited shelf life, even where these have been
subjected to a minimal, mild heat treatment such as conventional
pasteurisation for safety purposes

21. The meaning of the terms “fresh” or “freshly” must be clear whenever they
are used, whether alone or qualified by other terms. The use of emotive
but basically meaningless terms like “ocean fresh”, “kitchen fresh”, “garden
fresh” etc should be avoided.

22. Expressions like “freshly cooked”, “freshly prepared”, “freshly baked”,


“freshly picked” can have no other connotation than the immediacy of the
action being described. Where such expressions are used, it is
recommended they be accompanied by an indication (eg of the date or
2
Council Regulation (EEC) No 2082/92 and Commission Regulation (EEC) No 1482/2000 on the
Certificates of Special Character for Agricultural Products and Foodstuffs
3
Council Regulation (EEC) No 2771/75 on the common organisation of the market in eggs, as
amended
4
Commission Regulation (EEC) No 1538/91 on certain marketing standards for poultry, as amended

Revised December 2002 6


time or period – “freshly prepared this morning”) of when the action being
described took place.

23. Packaging, storage and other supply chain processes that control
“freshness” should not be described in terms that may imply that only a
short period after harvesting or preparation has elapsed before sale if this
is not the case. For example, a food that has been vacuum packed to
retain its freshness should not be described as “freshly packed”.

Fruit and vegetables:

24. The term “fresh” is now used generically to indicate that fruit and
vegetables have not been processed, rather than that they have been
recently harvested, and is acceptable provided it is not used in such a way
as to imply the product has been recently harvested (eg “fresh from the
farm”; “freshly picked”) if this is not the case (see paragraph 22 above).

25. The term “fresh” may be used to describe fruit and vegetables that have
been washed and/or trimmed, provided the fact they have been washed
and/or trimmed is also indicated.

Meat and fish:

26. Virtually all carcase meat is chilled to near or just below 0°C following
slaughter, principally as a hygiene measure. The term “fresh” is
traditionally used to differentiate raw meat from that which has been
(chemically) preserved. It would serve no purpose to disqualify chilled
meat from use of the term “fresh”. Use of the term “fresh” in these
circumstances is acceptable.

27. Use of the term “fresh” to describe fish that has been kept chilled on ice,
but not deep frozen, is acceptable.

28. Meat or fish that has been previously frozen but which is sold thawed
would not be considered by the average consumer to be “fresh”. The term
“fresh” should not be used in these circumstances.

Fruit juice:

29. The term “fresh” should not be used, directly or by implication, on juices
prepared by dilution of concentrates.

30. The term “freshly squeezed” should only be used to describe juice
obtained direct from the fruit (ie not prepared from concentrates) where
there has been a short time between extraction and packaging and the
“use by” date given on the product is within 2 weeks of juice extraction.

31. Where fruit juice described as “freshly squeezed” has been pasteurised,
the indication of treatment should form part of the claim, eg “freshly
squeezed pasteurised orange juice” etc.

Revised December 2002 7


Fresh pasta:

32. Fresh pasta is traditionally considered as a short shelf life product and it is
unlikely that the term “fresh” for long shelf life products would equate with
the average consumers’ perception of the term 5.

Fresh bread:

33. Terms such as “freshly baked”, “baked in store” and “oven fresh” may
mislead consumers into believing that they are being offered products that
have been freshly produced on site from basic raw materials. Some
stores sell bread made from part-baked products that have been packed in
an inert atmosphere or frozen off-site then “baked off” at in-store bakeries.
Use of terms like “freshly baked”, “baked in store” and “oven fresh” on
these products could potentially infringe the general provisions described
in paragraph 8 above 6.

Frozen foods/ingredients:

34. The term “fresh” should only be used in relation to frozen foods if its use is
clear from the context. For example

• “frozen from fresh”


should only be used to indicate a food was fresh (ie recently made or
harvested) when it underwent freezing;

• “made with fresh ingredients”


should be used only where the intended meaning is that no processed
ingredients (ie ingredients that have been dried, freeze-dried, frozen,
concentrated, powdered, smoked, tinned, etc) were used;

• “made with fresh X”


should only be used where X is the name of an ingredient that has not
been processed and the food does not also contain processed
equivalents of the same ingredient. For example, a food described as
“made with fresh tomatoes” should not also contain tinned tomatoes.

Fresh taste:

35. The expression “fresh taste” should not be used where it could mislead the
consumer, for example by implying “freshly squeezed”, unless it is clear
from the context that the reference is to the “tanginess” of the taste or if
the appropriate criteria for “freshness” are met. The use of alternative
terms like “clean taste” and “refreshing taste” should be considered.

5
LACORS circular LAC 14 96 7: “Fresh pasta”
6
see also LACORS circular LAC 9 98 9: “Labelling and description of bread”

Revised December 2002 8


36. Terms like “with the taste of fresh X” (eg “with the taste of fresh lemons”)
should only be used if the product contains “fresh X” and the flavour being
described comes wholly or mainly from that “fresh X”.

Chilled foods:

37. The increased sales of chilled convenience foods has led to the use of the
term “fresh” to indicate a moderate life under refrigerated conditions and to
highlight the difference from conventional long-life products. Examples
include chilled soups and sauces with the taste and texture characteristics
of less heavily processed, canned or bottled items; and fruit juice produced
directly from the fruit, perhaps pasteurised. In these cases, the products
have a short shelf life, even under chilled storage, and it is claimed that the
term is applied to indicate this fact to the consumer

38. There are more precise ways to indicate the necessary storage conditions.
The term “fresh” should not be used in this manner unless the product
complies with the appropriate criteria for its use, as set out in this advice.

Revised December 2002 9


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“NATURAL”

39. “Natural” means essentially that the product is comprised of natural


ingredients, e.g. ingredients produced by nature, not the work of man or
interfered with by man. It is misleading to use the term to describe foods
or ingredients that employ chemicals to change their composition or
comprise the products of new technologies, including additives and
flavourings that are the product of the chemical industry or extracted by
chemical processes.

Dairy products:

40. The term “natural” has been used on certain dairy products for many
years, to signify that the products are manufactured only from milk, using
only the necessary, associated fermentation cultures and are free from
other ingredients or additives, such as preservatives , flavourings, colours,
ie, they are “plain”, unflavoured products, (eg “natural” yogurt, “natural”
fromage frais, and “natural” cottage cheese). This usage is well
understood, and is therefore acceptable, providing it is clear that the term
is indicating that the flavour of the product is that derived solely from the
ingredients essential to the manufacture of the product, and that the
flavour has not been adjusted by any other means. The ingredients must
comply with the requirements in 44 and 45.

Bottled water:

41. The term “natural” may be used to describe mineral water in accordance
with the Natural Mineral Water, Spring Water and Bottled Drinking Water
Regulations 1999 7. Other product names for bottled water are “spring
water” and “bottled drinking water”.

General:

42. The term “natural” without qualification should be used only in the following
cases:

a) To describe single foods, of a traditional nature, to which nothing has


been added and which have been subjected only to such processing
as to render them suitable for human consumption:

• smoking (without chemicals), traditional cooking processes such as


baking, roasting or blanching and traditional methods of dehydration
are examples of processes that are acceptable, as are physical
sieving and washing with water.

7
implementing Directives 80/777/EEC, as amended, and 80/778/EEC

Revised December 2002 10


• fermentation is itself a natural process but subsequent processes
may disqualify the final product from the description “natural” unless
appropriately qualified.

• processes such as freezing, concentration, pasteurisation, and


sterilisation, whilst clearly playing a significant role in both making
food safe and preserving it do not accord with current consumer
expectations of “natural” foods. However, the process to which a
“natural” product has been subjected can be described using these
terms (e.g. “pasteurised natural lemon juice”, “frozen natural orange
juice”).

• for single ingredient foods such as cheese, yoghurt and butter,


acceptable processing is that which is strictly necessary to produce
the final product (as described in paragraph 40 above, and 44 and
45 below.

Bleaching, oxidation, smoking (with chemicals), tenderising (with


chemicals), hydrogenation and similar processes fall outside the scope.

The restriction to “foods of a traditional nature” excludes from the


concept of “naturalness” foods derived from novel processes.

b) To describe food ingredients obtained from recognised food sources


and which meet the criteria in a).

c) To describe permitted food additives obtained from recognised food


sources by appropriate physical processing (including distillation and
solvent extraction) or traditional food preparation processes.

d) To describe flavourings when in conformity with the UK Flavourings in


Food Regulations 1992, as amended, and EC Directives 91/71/EEC
and 2000/13/EC (Annex III8).

e) To describe preserved tuna and bonito when in conformity with EC


Regulation 1536/92.

43. Compound foods should not themselves be described directly or by


implication as “natural”, but it is acceptable to describe such foods as
“made from natural ingredients” if all the ingredients meet the criteria in
paragraph 42b), c) and d), as appropriate.

44. A food that does not meet the criteria in paragraphs 42a) or 43 should not
be claimed to have a “natural” taste, flavour or colour.

8
European flavourings legislation requires flavouring manufactures and suppliers to use the terms
“natural”, “identical to nature” and “artificial” for commercial sales of their products. However,
consumers may not differentiate between the concepts of “artificial” and “identical to nature” (or
“nature-identical”) when used to describe those ingredients in relation to the final food.

Revised December 2002 11


45. “Natural” meaning no more than plain or unflavoured should not be used
unless the food meets the criteria in paragraphs 42a) or 43, or is in
accordance with the Dairy Industry Federation Code of Practice for the
Composition and Labelling of Yogurt.

46. “Natural”, or its derivatives, should not be included in brand or fancy


names, nor in coined phrases, in such a way as to imply that a food that
does not meet the criteria in paragraphs 42a) or 43 is natural or made from
natural ingredients.

47. Where the word “natural” forms part of a company name, no undue
prominence should be given to the word on any individual product unless
that product meets the requirements of these criteria.

48. Claims such as “natural goodness”, “naturally better”, or “nature’s way” are
largely meaningless and should not be used.

49. The principles set out above also apply to the use of other words or
expressions, such as “real”, “genuine”, “pure” etc with separate and
distinctive meanings of their own, when used in place of “natural” in such a
way as to imply similar benefits. Guidance on such terms and their
synonyms is offered elsewhere in these advice notes.

50. Other claims (which might be termed “negative claims”) that do not use the
term “natural” or its derivatives directly, but the effect of which is to imply
“naturalness” to the consumer, are potentially misleading and confusing.
The following should not be used:

• a claim that a food is “free from x”, if all foods in the same class or
category are free from “x”;

• statements or implications which give undue emphasis to the fact that a


product is “free from certain non-natural additives or categories of
additives”, when the product contains other non-natural additives;

• a claim that a food is “free from one category of additive”, when an


ingredient or an additive of another category having broadly similar
effect has been used.

These criteria do not affect “negative claims” which do not imply


“naturalness” to the consumer, (such as “free from x”, where “x” is a
particular additive), and where the statement may provide consumers with
accurate and beneficial information.

Revised December 2002 12


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“PURE”

51. The term “pure” is mostly used on single ingredient foods (eg to indicate a
single, named variety of rice) or to highlight the quality of ingredients of a
food (eg “pure butter shortbread” to indicate the butter has not been
blended with other fats).

52. The validity of the use of the term “pure” should be determined by the
properties of the food itself, not its storage conditions.

53. The term “pure” should generally only be used in the following
circumstances.

a) To describe a single ingredient food:

• to which nothing has been added;

• that is free from adventitious contamination by similar foods (ie


tolerances for contamination such as for basmati rice, durum pasta,
GM thresholds, etc should not apply);

b) Compound foods should not generally be described, directly or by


implication, as “pure”. It is, however, acceptable to describe such
foods as “made with pure ingredients”, if all the ingredients meet the
criteria above, or if a claimed, named ingredient meets these criteria
and is the only source of that ingredient. There are two exceptions to
this general rule:

• Fruit juice: “pure” is used only for non-sweetened fruit juice but
may be used for concentrated juice reconstituted with water.
Legislation permits the addition of sugar or citric acid to correct
sweetness and the use of ascorbic acid as an antioxidant during
processing of fruit juices. The term “pure” should not be used on
those products containing added sugar, citric acid or ascorbic acid.

• Jams and marmalades: the term “pure fruit” is used to indicate


that the fruit has not been preserved by sulphur dioxide, prior to use
in the jam/marmalade. This usage is acceptable. The European
Court of Justice has ruled that the expression “naturally pure” is
legitimate, and unlikely to mislead consumers when used on a
strawberry jam made with added pectin and containing low levels of
lead, cadmium and two particular pesticides9. In summary, the
Court took the view that the presence of pectin was readily
apparent to the average consumer by virtue of its declaration in the
ingredient list; the presence of low levels of naturally-occurring
contaminants was unavoidable; and the levels of the pesticide

9
ECJ Case C-465/98 Handel und Gewerbe Koln eV v Adolf Darbo AG

Revised December 2002 13


residues were “particularly low” as compared with the levels
permitted by Community legislation.

54. “Pure” should not be included in any brand or fancy names, nor in coined
or meaningless phrases, in such a way as to imply that a food that does
not meet the criteria above is pure or made from pure ingredients.

55. “Pure” meaning no more than plain or unflavoured should not be used
except where the food in question meets the criteria above.

Revised December 2002 14


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“TRADITIONAL”

56. The term “traditional” is widely used to describe a product or method of


preparation when newer alternatives are available on the market. It
implies more than “original” or “plain”.

57. Unless the term forms part of a name that has been registered under
European rules (eg “Traditional Farmfresh Turkey” 10 ), the term “traditional”
should demonstrably be used to describe a recipe, fundamental
formulation or processing method for a product that has existed for a
significant period11. The ingredients and process 12 used should have been
available, substantially unchanged, for that same period.

58. It is misleading to use the term “traditional”, without qualification, simply to


distinguish an “original” recipe from subsequent variants. Manufacturers
and retailers should pay particular attention to the use of ingredients,
particularly additives, and to the use of processes that have not been used
in food manufacture for the significant period of time indicated above.
They must ensure that the term does not imply a composition or
production method that would not be regarded as “traditional” by the
average consumer and should consider whether the term “original recipe”
or similar expression may be more appropriate. There should be evidence
to substantiate the use of the word for the particular product.

59. Recipes of what might be described as “traditional” products may change


over time to accommodate consumer demands and expectations (eg
Christmas puddings and mince pies made with vegetable rather than
animal fat/suet; and other foods that are traditionally consumed at certain
times of the year). Such foods should not be described as “traditional X”.
However, reference may be made to the traditional nature of these
products, provided this does not imply that the product itself has been
made traditionally/to a traditional recipe unless this is the case. For
example - “Christmas pudding – a rich, steamed fruit pudding traditionally
eaten on Christmas day with custard, brandy butter or cream”.

10
Council Regulation (EEC) No 2082/92 and Commission Regulation (EEC) No 1482/2000 on the
Certificates of Special Character for Agricultural Products and Foodstuffs
11
As a general rule, this should be taken to be of the order of 2 generations/50 years
12
The Chorleywood Bread Process has been used in bread production in the UK for nearly 40 years. It
constitutes no more than the mixing of dough under pressure/vacuum and should not obviate the ability
of bakers to call a loaf “traditional” when in other respects the loaf remains unaltered.

Revised December 2002 15


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“ORIGINAL”

60. Unlike “traditional” the term “original” does not imply, necessarily, that a
product has remained unchanged for a substantial period of time. It is
used to indicate that a product was the first of its type to be placed on the
market, where the original form or flavour has remained essentially
unchanged through the passage of time and hence to differentiate it from
new additions to a range. The term is commonly used to convey “plain” or
“unflavoured” where other variants are offered (eg “original flavour crisps”)
or to indicate the first variant in a series of products.

61. The term “original” should only be used to describe a food that is made to
a formulation, the origin of which can be traced, and that has remained
essentially unchanged over time. It can similarly be used to describe a
process, provided it is the process first used in the making of the food, and
which has remained essentially unchanged over time.

62. To be termed “original”, a product should not have changed to any


material degree and should remain available as the “standard” product
when new variants are introduced. A product re-introduced onto the
market after a period of absence should only be described as “original” if it
can be shown to meet these criteria.

63. The term “original” should not be used to convey “plain” or “unflavoured”
where other variants are offered (eg original flavour crisps), or to indicate
the first variant in a series of products, unless the product can be shown to
meet the criteria in paragraphs 61 and 62.

Revised December 2002 16


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“AUTHENTIC”

64. The term “authentic” has a stronger meaning than “traditional”. It may
imply either that a product has remained unchanged through the passage
of time, or that it actually originates from the area implied by its name (eg
authentic Cornish pasties) when the generic description of the product has
passed into wider usage.

65. The term “authentic” is used

• to indicate the true origin of a product where the description may be in


wider, generic use

• to convey to consumers that a product has particular characteristics that


have not been adjusted for the British palate (eg authentic Indian-recipe
curry dishes)

• to indicate single types of rice, where this is important because they


have particular characteristics.

66. The current, widespread use of terms such as “real”, “genuine” etc in
relation to individual food ingredients (eg “made with real fruit juice”) is
largely unjustified and tautologous. Such use may be taken to imply that
the food or its ingredients possess higher compositional quality than others
in the same class. In view of the fact that food or ingredients that are
analogue or substitute, or a flavouring, should already be clearly indicated
on the label, it is recommended that this use of these terms should be
discontinued.

67. The term “authentic” and related terms like “real” and “genuine” should
only be used in the following circumstances

• to emphasise the geographic origin of a product, for example where it


might be confused with other products of the same name that do not
originate from that location, e.g. “authentic Devon toffees”;

• to describe the recipe used to make a product, the origin of which is


specified, e.g. “authentic Indian recipe curry”;

• to emphasise the purity of single varieties of ingredients where such


purity is essential to deliver specific characteristics.

68. “Authentic” and analogous terms should not otherwise be used, without
qualification, to describe either a food or an ingredient.

Revised December 2002 17


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“HOME-MADE”

69. “Home-made” is a term defined very simply and specifically in dictionaries:

• made or prepared in the home; of domestic manufacture;

• made at home using traditional methods rather than by a manufacturer;

• made by oneself;

• crudely or simply made.

70. Consumers understand the term “home-made” to mean food prepared in a


domestic kitchen rather than in a factory or a manufacturer’s kitchen. The
use of the term, if unqualified, should accordingly be restricted to the broad
criteria above.

71. In order to avoid visual misrepresentation, factory-made foods should not


be shown being made in small kitchens, farmhouses etc.

72. In order to accommodate the production of meals and dishes on


commercial catering premises, the term “home-made” should be restricted
to the preparation of the recipe on the premises, from primary ingredients,
in a way that reflects a typical domestic situation. This should not be
achieved simply by the assembly of wholly pre-prepared elements, or
simple reconstitution from dry base mixes, but must involve some degree
of fundamental culinary preparation. As in domestic preparation, it would
be legitimate for caterers to use partly-prepared ingredients; typical
examples could include the use of pre-prepared raw pastry, bakery bread
in desserts or stock cubes in sauces.

Revised December 2002 18


RECOMMENDED CRITERIA FOR THE USE OF THE TERM
“FARMHOUSE”

73. The use of terms like “country”, “farm” etc or similar visual depictions of
typical rural scenes may mislead if the food to which they are applied has
not been produced on what the average consumer would understand to be
a farm.

74. “Farm House” or “farmhouse” can only be defined as a house on a farm,


and more specifically as the main dwelling of the farmer himself.

75. The baking industry has long used the term “farmhouse” to describe a
style of bread with a single, longitudinal split and sometimes flour dressed.
This use of the term is acceptable.

76. Where the term “farmhouse” is used in connection with foodstuffs other
than bread, it should refer to that produced on a farm. If it is not produced
on a farm but is produced to the same quality and style as that likely to be
produced on a farm, it should be described accordingly.

77. Given the vagueness of the term when used alone, its use should be
avoided in preference of other terms which may be more descriptive and
more accurate (eg “chunky vegetable soup”). When the term is used, its
meaning should be made clear either within the context of sale or by
associated wording (eg “farmhouse-made soup”).

78. Simply describing an ingredient as “farmhouse”, e.g. “x with farmhouse


vegetables”, is meaningless. The term should not be used in this context.

79. The similar expression “country style” does not appear to have any
specific meaning. This phrase should not be used to describe any food or
food ingredient.

Revised December 2002 19


CONTACT DETAILS FOR FURTHER INFORMATION

80. The address for all correspondence relating to the issues set out in this
advice is:

Food Labelling and Standards Division – Room 115B


Food Standards Agency
Aviation House
125 Kingsway
London
WC2B 6NH

Tel: 020 7276 8147


Fax: 020 7276 8193
E-mail: [email protected]

81. For further information on the legislation in the devolved administrations,


please contact

In Wales: Food Standards Agency Wales


1st Floor, Southgate House
Wood Street
Cardiff
CF10 1EW

Tel: 029 2067 8911


E-mail: [email protected]

In Scotland: Food Standards Agency Scotland


St Magnus House
6th Floor
25 Guild Street
Aberdeen
AB11 6NG

Tel: 01224 285155

In Northern Ireland: Food Standards Agency Northern Ireland


10C Clarendon Road
Belfast
BT1 3BG

Tel: 028 9041 7700

Revised December 2002 20

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