EU regulation No 1169/2011 on the provision of food information to consumers is a new European Union directive that affects both manufacturers and retailers. It applies to food business operators at all stages of the food chain, where their activities concern the provision of food information to consumers.
The directive concerns the display of product information on product packaging and online stores; pertaining to food and beverages sold in the EU. The objective of which, is to standardize food labeling and provide greater clarity to consumers on ingredients, nutrition and allergens.
The directive comes into effect in December 2014. Food and beverage manufacturers will have to update their packaging to comply with this new legislation. Online retailers must ensure that the information they provide conforms to the regulation and it must be identical to the product information provided on the manufacturers physical packaging. Compliance with the new legislation will ensure that product information is consistent throughout the supply chain at every consumer touch-point, both in-store and online.
How to implement a GS1-compliant Data Quality Management System in FMCG
Food and beverage manufacturers will be responsible for:
Food and beverage products that do not adhere to the legislation cannot be sold in the EU.
Some exceptions exist for foods that are not pre-packed. Further information is available here.
When the legislation takes effect all food and beverage products retailed must comply with EU 1169/2011 product information labeling and formatting requirements.
Manufacturers and retailers have a joint duty to ensure that food and beverage products retailed comply with this new legislation. EU 1169/2011 stipulates that certain product information is provided at point of sale, this includes in-store and online.
The new regulation will also effect how retailers display product information online. E-tailers and online stores must comply with the legislation on how to display the product information correctly.
What needs to be provided is detailed more in the next section.
Whereas food and beverage manufacturers must update physical packaging to comply, online retailers must replicate that same information online, taking care to highlight pertinent information like allergens in the ingredients list and displaying nutritional information.
If a retailer fails to provide any of the mandatory information set out in EU 1169/2011 online and sells the product they will be breaking the law.
EU 1169/2011 states that the following minimum information must be provided online, before purchase:
LANSA can help you achieve compliance with EU 1169/2011 as well as address the many challenges ahead. Our Product Information Management system (PIM) – Data Sync Direct – supports all the attributes required by the regulation.
Data Sync Direct (DSD) is a fully compliant GS1 solution that can manage the entire GTIN life cycle, its associated product attributes and its relationship within a packaging hierarchy. DSD has been designed to cater for the needs of demand- and supply-side organizations. It's an out-of-the-box solution providing full-service PIM functionality in a single affordable package.
Data Sync Direct makes it easy to manage product information and comply with regulatory initiatives – integrating and automating every step of the process from the creation of a product in a Product Lifecycle Management (PLM) system to its appearance in a retail catalog or online shop.
Manufacturers can quickly fulfill recipient requests as well as benefit from the efficiency gains of end-to-end supply chain automation. Retailers can get instant access to accurate product data – allowing them to get products to shelf quickly and more efficiently.
DSD also looks after publication of changes to trading partners and is fully integrated with the Global Data Synchronization Network (GDSN) through the 1Worldsync data pool.
Data Sync Direct is comprised of modules that address Master Data Management, Data Quality, Product Portfolio Management and Item Publication. Click here for more information
EU 1169/2011 states that specific nutritional information must be accessible by the consumer prior to purchase online.
Nutritional information relating to a product is most commonly consolidated on product packaging. When purchasing a product in-store a consumer is able to view this information and make a buying decision based upon that content. In an online environment a consumer does not have access to the same level of information.
With EU 1169/2011, food manufacturers will have a duty to provide compliant information to their trading partners in a timely fashion, to allow that product to be legally traded. This means that product information must be well structured for consumption by on-line shops. The challenge to food manufacturers is how to mange and administer this information:
How can LANSA Data Sync Direct help?
Data Sync Direct (DSD) contains a pre-configured product data model compliant with both the GDSN and the EU regulation. GDSN validation rules form part of that data model to ensure that any data imported or hand-keyed is GS1 and EU regulation compliant.
Data governance is enforced within DSD through a workflow engine. User roles and permissions can be set to configure workflows that reflect the company's internal processes, as we often see different people having individual responsibilities with regards to the management of product data.
Newly created or updated product data is managed by DSD and can be easily synchronized with the GDSN. DSD supports all of the standard GDSN Messaging.
The EU Regulation states that a physical product's labelling of nutritional information, if available for online purchase, must display identical nutritional information in the web shop.
It is highly likely that multiple versions of the same product will be present in the supply chain, only visibly differentiated by a change in GTIN and the nutritional information label. The challenge presented to retailers is how to manage this 'versioning' of a food product both in terms of inventory management and online provisioning.
To comply with EU 1169/2011 online retailers must ensure that the product information supplied online is tied only to the equivalent version of the physical product that is to be supplied to the consumer. Retailers will be faced with more complex processes to manage product supersession.
How can LANSA Data Sync Direct help?
The workflow engine within Data Sync Direct, combined with the user roles and permissions can be configured in such a way, that no existing product is modified inadvertently and therefore breaking the EU regulation rules.
The EU-Regulation requires all nutrition facts relating to a product be made available to the consumer before a product is purchased – both in-store and online.
If the nutritional facts change or are amended on a consumer-traded pre-packaged food item, the resultant attribute change triggers GS1 GTIN Allocation Rules. These rules stipulate (at least in the short-term) a new GTIN must be assigned to that item.
To be compliant with the regulation new GTINs and product attribute changes must be disseminated through the supply chain immediately, including, but not limited to, retailers, online stores and the Global Data Synchronization Network (GDSN). Failure to do so has the potential to allow an item to be traded containing incorrect consumer information.
Food manufacturers are known to change nutritional facts several times per product, per year. This creates a massive product data management burden, affecting internal systems and processes as well as item publication procedures, i.e. manually having to update Retailer Portals and Content Management Systems.
To become and remain compliant with EU 1169/2011 will be resource intensive and hence very costly. The extra effort necessary will be time-consuming due to the increased data management workload and multiple data entry processes. As a result, data quality will inevitably suffer and workaround processes will also have to be introduced to deal with errors, leading to more cost.
Let's take a frozen food manufacturer as an example. This company produces frozen pizzas. There are 6 varieties, each available in 2 sizes and the product is sold in 10 EU countries with different packaging. The company changes ingredients 5 times per year for each variety. This would require the introduction of 600 new GTINs per year at an item level. This example excludes promotions, multipacks and new product introduction.
The department responsible for product data maintenance would have to update the attributes against each product and then generate 600 new GTINs and associate with the products. This information would then have to be shared with trading partners in the normal manner. When using the GDSN, each GTIN would have to be registered one-at-a-time with its associated attributes and the previous GTINs would have to be discontinued – this would amount to 1,200 updates at an item level. The exercise then has to be repeated to account for packaging hierarchies. If we assume that each item has an associated case and pallet then the number of updates has become 3,600.
How can LANSA Data Sync Direct help?
Data Sync Direct (DSD) automates the GTIN creation process by integrating with your existing systems, like an ERP (Enterprise Resource Planning) or PLM (Product Lifecycle Management). DSD will trigger the appropriate workflows for the newly created products in order to get them enriched (if needed), validated, reviewed and synchronized with trading partners via the GDSN or other means.
The integration functionality built within Data Sync Direct helps with the importing of attributes from any existing system in order to minimize workload associated with manual product maintenance. The workflow engine then helps to structure the data following the creation, review and publication process for any new GTIN.
The GDSN standards will evolve to include a better business process to manage the many variations in a product that may arise as nutritional content is changed in a consumer unit. As part of that evolution, it is expected that the traditional 13-digit barcode seen on packaging today, will be replaced by the GS1 Databar.
The Databar can contain more identification information and it is expected that manufacturers will change the Databar every time they change the packaging to reflect changes in nutritional content.
The impact on systems expected to handle the data, is that physical scanning devices must be capable of reading the GS1 Databar.
Also, databases, applications and message formats that process the GTIN information will need to recognize the "Version Number" and "Nutrition Facts Version Number" fields that will be added to the current GTIN record structure. These version number fields will permit extended information to be added to the current GTIN record, without changing significantly the existing GTIN record structure, so reducing the impact of this change through the GDSN.
This new EU Regulation presents a colossal data management challenge to the industry, for both food manufacturers and retailers. GTIN management will become far more complex and with that, the opportunity for errors will increase and data quality will be impaired. Here are some of the areas that will be impacted:
The EU Regulation does not stipulate the use of the GDSN. However many organisations worldwide use this system to electronically synchronize product information with each other, including attributes that pertain to nutritional information.
While the GDSN is a formidable system to help with EU 1169/2011 compliance, the existing data structure does not fully support all the required attributes in a way that can be easily consumed by either a target system or human. The GDSN uses a variety of attributes in the form of "code lists" or "attribute groups". The item data that a Retailer receives from a GDSN data pool has to be transformed into an understandable format that the consumer is able to read in an Online Shop.
Therefore a recipient of GDSN data would require a system that is able to transform these codes into structured information. Note: The GDSN provides code lists only in English.
|GDSN||Consumer friendly text|
Contains: Nuts and nut products, gluten containing cereals and cereal products containing gluten
Contains: Mustard or mustard products
Contains traces of: Peanuts or Peanut products
Does not contain: Soy or soy products
ENER-, 1247, E14
ENER-, 2224, KJO
PRO-, 0.4, GR
CHOAVL, 10.5, GR
FAT, 11.5, GR
Energy 1247 kcal
Energy 2224 kJ
Protein 0,4 g
Carbohydrates 10,5 g
Fat 11,5 g
How can LANSA Data Sync Direct help?
A product data recipient can use the data format mapping tool within Data Sync Direct to automatically process the information received from the GDSN. DSD will transform code lists and attribute groups into a consumer friendly readable version as shown in the table above.