Food label compliance checklist

Mandatory elements (Regulation R146 of 2010)

• The name of the food describes its true nature and is not misleading; a prescribed or customary name is used where one exists.
• The ingredient list is headed as such and lists every ingredient in descending order of mass at the time of manufacture, with compound ingredients broken down and additives declared by class name and name or number.
• Every common allergen present, including in compound ingredients and processing aids, is declared in the ingredient list or an allergen statement (precautionary statements: see the allergen management checklist).
• The name and physical address of the manufacturer, packer, importer or distributor in South Africa appears on the label.
• The country of origin is declared as the regulation requires, including for imported goods and goods packed in South Africa from imported ingredients.
• A batch or lot identification is present and legible, and it links to the production and traceability records.
• Date marking uses one of the terms R146 allows (best before, use by or sell by) in the prescribed date format.
• Use by is chosen where safety ends the shelf life, and the storage instructions on the label keep the date valid (see the shelf-life study checklist).
• The net quantity is declared in metric units in the position and size the Legal Metrology Act and its regulations require, and the fill is verified against it.
• Instructions for use or preparation appear where the food would be unsafe or unusable without them.
• Where an ingredient is emphasised by name or picture, its percentage is declared (QUID).
• Genetically modified ingredient labelling under the Consumer Protection Act regulations has been checked.

Claims, nutrition and special categories

• Nutrition information is given in the prescribed table format wherever a nutrition or health claim is made, and the figures come from analysis or a defensible calculation that is on file.
• Every permitted claim (free from, low, high, source of, natural, fresh, pure, homemade, organic, halaal, kosher) meets the conditions of R146 or the certifying body, with evidence on file.
• Prohibited statements (slimming, health, healthy, wholesome, nutritious and implied health claims) are absent.
• Implied claims in pictures, colours, brand names and endorsements have been checked against the same rules as words.
• Foods with their own regulations (for example infant formula, fortified staples, alcoholic beverages, meat products) meet those regulations in addition to R146.
• Where the product is exported, the destination market's labelling rules have been checked and a separate label used where they differ.

Legibility and artwork control

• Mandatory text is in English (plus any other official language the manufacturer chooses), clearly legible, in the minimum letter height the regulation sets, with adequate contrast and not obscured by seams, folds or sleeves.
• The artwork is checked against the approved recipe, the allergen risk assessment and the specification by a named person, and the check is signed before the print proof is approved.
• A label specification is held for every product, with the current version number, and obsolete labels are removed from stock when a label changes.
• Printed and applied labels are verified on the line at start-up and after every changeover (correct label, correct date, correct batch, legible print) and the check is recorded (FSSC 22000 additional requirement 2.5.2; BRCGS section 6.2).
• Retailer or customer label requirements (private label, specific layout, GS1 barcodes, retailer logos) have been met and signed off by the customer.