Identification of an item may come in different forms but labelling is one sure way of placing identity on objects. When it comes to the sale of food, drugs or cosmetics, manufacturers are obliged to identify what they put on shelves for consumers. The content of products cannot be ascertained unless there is a label on the packaging that confirms what the contents of that package is. The definition of labeling in itself brings to the fore the reasons for labelling. An item used to identify something or someone. A small piece of paper or cloth attached to an article to designate its origin, owner, contents, use, or destination. Labels usually bear a trademark identifying the product or manufacturer.
The Labeling LI
It is often said, that ignorance of the law is no excuse. It is important for manufacturers to note that there is a law that regulates labelling in Ghana. Breach of the law on the back of ignorance will not win you any sympathies are the law courts. The Ghana Standards Board (now Ghana Standards Authority came out with the labeling rules based on the Standards Decree, 1972 (N.R.C.D.173) in 1992, 29th day of April.
Once these rules were made based on the law, it has legal backing and hence must be obeyed and implemented to the letter. Apart from ready to eat foods usually sold in restaurants and other eateries, all pre-packaged foods, cosmetics and drugs must have labels that give more information about the product to inform consumers on what they’re buying.
General Labelling Requirements for pre-packaged food
The Food and Drugs Authority publishes the requirements for labeling pre-packaged food on its website (www.fdaghana.gov.gh). This requirement will pretty much fit into the general requirements for labelling any cosmetic product or even drugs. For drugs, there are a few more additions such as dosage information and side effects. The label of every pre-packaged food or product for that matter should include the name of the product (Brand and Generic names), the net weight, net volume or drained weight for solid in liquid medium.
The drained weight for solid in liquid medium refers to chunks of food which are usually kept in a liquid base. Consumers will normally buy these products based on the solids and not the base in which they are kept per se. Hence sale to consumers shall be based on the weight of the solids and not the base in which they are kept. Examples of these are mackerel in tomato source. It is important for consumer safety purposes to list all ingredients used in formulating that product on the label. These should be specific names of the ingredients used, and must be as specific as possible to be identified by consumers.
All E-numbers should be included in the ingredient list as well. E numbers are codes for substances that are permitted to be used as food additives for use within the European Union and Switzerland. These are internationally recognized and used. The “E” stands for “Europe”. Food additives are substances added to food to preserve flavor or enhance its taste and appearance. For example, E 621 (Monosodium glutamate) and E 150C (Ammonia caramel). It is also mandatory to include the date of manufacture, expiry date or best before date or use by date (not required for solid sugar).
For the purposes of traceability, the batch or lot number is a key requirement on labels of food products, drugs and a large chunk of cosmetic products. Also remember to include the country of origin on the label. So many traders now own products without the slightest idea of how a manufacturing set up is designed. That is the creativity of today’s trade. You can design your own brand with a chosen brand name and ask a factory sitting in China or any part of the world for that matter to produce products for you.
It is important to indicate the country of origin on the label. For illustration purposes, let’s say your company is A&B Enterprise registered in Ghana and a manufacturer called C&D Food Manufacturing Limited located in China is producing food products for you. Your label should indicate country of origin for that product as China. You are also not permitted to write Manufactured by A&B Enterprises but rather, Manufactured by C&D Food Manufacturing Ltd, China for A&B Enterprise, Ghana. The complete address of the manufacturer or agent must be included on the label. If manufacturing is locally done, the physical address of the premises shall be included in the address on the label.
The label shall also include directions for use if any. In most food products, the nutritional information and claims are included on the label. Documentary evidence must be provided to the Food & Drugs Authority to substantiate all nutritional information and claims on labels. It is also important to note, that all vegetable oils, both imported and locally produced are to bear the plant source of the oil and labelled as such e.g., corn oil, groundnut oil, rapeseed, sunflower oil etc.
The manufacturer shall add any instructions for storage and handling. If the product is sensitive to temperature, it is important for the manufacturer to state the conditions under which the product shall be stored. Labelling shall be legible and shall be of indelible ink.
Benefits of Labelling
Consumer Safety – Allergens are hazards considered in HACCP studies. The management of allergens happens on the production floor but preventing a consumer’s allergic reaction to ingredients in your product comes from labelling. Including these allergens in the ingredients list or declaring the allergen boldly on the label protects consumers who may react to such allergens.
Regulatory compliance – Labelling is mandated by law, hence labelling your product is one way of complying with the law.
Competitive urge – Through labelling manufacturers are able to showcase the superiority of their formulation through the listing of ingredients and claims, thereby attracting more customers.
Usage Instructions – To avoid unintended use of products, instructions for use on labels help consumers use products according to the intended use.
Storage Instructions – The shelf-life of products are predetermined during the development process. To maintain this shelf life, most products need to be stored under certain temperature limits. Putting these conditions on labels alerts customers and consumers on how to preserve these products before usage.
Batch or lot numbers are heavily relied on in instances of incident management. The batch number is what helps the manufacturer to effectively recall products which pose a risk to consumers as well as substandard products from the market. Without batch numbers, an organization may be forced to recall huge quantities of products from the market in case of a recall, since they’ll not be able to tell which batch had the issue.
Last but not least, manufacturing dates, expiry or best before dates are very essential to inform consumers as to when the product in question can be used or not.
Labelling therefore is crucial in consumer safety and must be done right. Think of consulting experts to help you when designing your label. The rule is that, labelling must be done right in order not to endanger the lives of the very consumers you wish to excite.
Johnson Opoku-Boateng is the Executive Director & Lead Consultant, QA CONSULT (Consultants and Trainers in Quality/Safety Management, Manufacturing Excellence and Food Safety) and can be reached on +233209996002, email: email@example.com.