On certain features of milk product labeling

08/02/20220 views

It is widely known that milk and dairy products are one of the main and important export areas of the Republic of Belarus. However, it is precisely for this category of goods that disagreements and disputes often arise, up to the restriction and prohibition of imports. In addition, milk and dairy products are convenient targets for falsification by unscrupulous manufacturers and importers, and as a consequence, for misleading consumers. Therefore, knowledge of the legislative requirements of the Eurasian Economic Union (hereinafter referred to as the EAEU) regarding the labeling of milk and dairy products is currently extremely important.

The requirements for the labeling of milk and dairy products intended for circulation within the EAEU are defined by the Customs Union Technical Regulation "Food Products in Terms of Their Labeling" and the Customs Union Technical Regulation "On the Safety of Milk and Dairy Products" (hereinafter referred to as TR CU 033/2013). Taking into account the practical application of these documents, as well as in order to further protect consumers, by the decision of the Council of the Eurasian Economic Commission of 10.11.2017 No. 102, amendments were made to TR CU 033/2013, a significant part of which concerns the clarification of terminology and labeling requirements. The procedure for bringing these amendments into force is determined by the decision of the Board of the Eurasian Economic Commission of 20.03.2018 No. 40.

So, what needs to be known and what is the difference between original dairy products and products that contain milk fat substitutes?

The replacement of milk fats with vegetable fats reduces the cost of the product. By replacing one ingredient with another, the manufacturer saves on raw materials and thus earns more. At the same time, contrary to popular belief, the presence of vegetable oils in

as milk fat substitutes – is not always dangerous. The World Health Organization (WHO) notes that products with milk fat substitutes are safe, provided they do not contain partially hydrogenated oils. Partially hydrogenated oils contain a high amount of trans fats, excessive consumption of which the WHO considers one of the risks for the development of cardiovascular diseases and premature death. However, it is worth noting that hydrogenated oils are primarily used in the production of margarine for industrial purposes, baked goods made with it, deep-fried products, and other products with a long shelf life.

If a genuine dairy product and one that resembles it and is produced with the addition of vegetable oils are prepared in good faith, then there is usually no difference in terms of safety. However, it should be emphasized again – replacing milk fats with vegetable fats is a cost-cutting measure. Industrial production of dairy products with milk fat substitutes is cheaper, which means their price should also be lower. And most importantly – the consumer must be aware of this to make the right choice!

According to the amendments to TR CU 033/2013 that have entered into force, the labelling of dairy products must comply with the following requirements:

· The name of a milk-containing product with a milk fat substitute must begin with the words "milk-containing product with milk fat substitute" (with the exception of cream-vegetable spread, cream-vegetable clarified mixture, ice cream with milk fat substitute).

· Information on the production technology of a milk-containing product with a milk fat substitute is indicated in the form of the words "produced (manufactured) using the technology" with the indication of the concept established for the corresponding dairy product.

· The font size of the name of a milk-containing product with a milk fat substitute must be at least 2.5 mm.

· In the name of a milk-containing product with a milk fat substitute, the word "product" may be replaced by a general technical term characterising the consistency or structure of the product (cream, paste, sauce, etc.).
For example:"milk-containing product with milk fat substitute, produced using the technology"sour cream"; "milk-containing cream with milk fat substitute, produced using curd technology".

· Consumer packaging shall indicate information on the presence of vegetable oils in the milk-containing product with milk fat substitute. The specified information shall be applied to an information field specially designated on the packaging or label, in a font contrasting with the colour of this information field. The information field shall be filled with the following information: "Contains vegetable oils". The information field shall be contrasting in colour with the label or packaging onto which the product marking, including its name, is applied. The font size of the information field on the consumer packaging of a milk-containing product with milk fat substitute shall be at least 3 mm, if the size of the packaging allows filling the information field with information of the specified font sizes. In the event that the size of the packaging does not allow filling the information field with information of the specified font sizes, the specified information shall be applied in the largest possible font size.

· The names of milk-containing products with milk fat substitute may include, at the manufacturer's discretion, terms characterising the specific raw material composition of the product, and its thermal and special processing method (if such processing has been carried out).

Thus, the new labelling requirements allow consumers to understand from the names of milk-containing products that they contain milk fat substitutes. This helps the consumer to easily determine whether they are purchasing a traditional dairy product or a similar product with vegetable fats and to make an informed purchasing decision.