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148 The nutrition handbook for food processors 6.2.7 Implementation Most legislation is only as good as its implementation and enforcement and the application of these procedures has been variable in the case of the Nutrition Labelling Directive. Some Member States were tardy in including it in their national legislation and some, the UK being a prime example, did it so clumsily hat it would have been a deterrent to use had the Directive itself not already been familiar to most UK food and drink manufacturers and its provisions already widely used on a voluntary basis. Reports from elsewhere in Europe suggest that national implementing rules, which invariably entail a degree of interpretation, have indeed been a deterring factor and have acted as a disincentive in provid- ing nutrition information voluntarily. The UKs record of some 80% of manu- factured food and drink products voluntarily carrying nutrition information remains a matter of surprise, admiration and consternation in other Member UK implementation of the Nutrition Labelling Directive is via the Food Labelling Regulations 1996(as amended). These are complex Regulations cov ering all the essentials of food labelling from batch marking to medicinal claims Implementation of the Nutrition Labelling Directive, which took place in 1994. carried with it the usual burden of complexity that comes with turning the posi tive approach of EU legislation(you are not allowed to do it unless the Directive says so) into the negative style of UK Regulations (you can do what you like unless the Regulations state that No person shall. ) The transposition of Article 4.1 of Directive 90/496/EEC, which states simply that Where nutrition labelling is provided, the information to be given shall consist of either group I or group 2 in the following order: Group I (a) energy value; (b) the amounts of protein, carbohydrate and fat. Group 2 (a) energy value b) the amounts of protein, carbohydrate, sugars, fat, saturates, fibre and became in Schedule 6A Part I of The Food Labelling(Amendment) Regulations 1994 a half page single table listing both Group I and Group 2 nutrients, plus all the additional nutrients allowed to be mentioned, such as polyols under carbo- hydrates and polyunsaturates under fats, with a complex set of cross references to Part Il of the Schedule and subsequent paragraphs of Part I to explain the two separate groups and how they should be set out. It is no wonder that MAFF needed to issue explanatory guidance notes to accompany the amendment to the 2 MAFF Guidance Notes on Nutrition Labelling, issued 18 March 19946.2.7 Implementation Most legislation is only as good as its implementation and enforcement and the application of these procedures has been variable in the case of the Nutrition Labelling Directive. Some Member States were tardy in including it in their national legislation and some, the UK being a prime example, did it so clumsily that it would have been a deterrent to use had the Directive itself not already been familiar to most UK food and drink manufacturers and its provisions already widely used on a voluntary basis. Reports from elsewhere in Europe suggest that national implementing rules, which invariably entail a degree of interpretation, have indeed been a deterring factor and have acted as a disincentive in provid￾ing nutrition information voluntarily. The UK’s record of some 80% of manu￾factured food and drink products voluntarily carrying nutrition information remains a matter of surprise, admiration and consternation in other Member States. UK implementation of the Nutrition Labelling Directive is via the Food Labelling Regulations 1996 (as amended). These are complex Regulations cov￾ering all the essentials of food labelling from batch marking to medicinal claims. Implementation of the Nutrition Labelling Directive, which took place in 1994, carried with it the usual burden of complexity that comes with turning the posi￾tive approach of EU legislation (you are not allowed to do it unless the Directive says so) into the negative style of UK Regulations (you can do what you like unless the Regulations state that ‘No person shall . . .’). The transposition of Article 4.1 of Directive 90/496/EEC, which states simply that ‘Where nutrition labelling is provided, the information to be given shall consist of either group 1 or group 2 in the following order: Group 1 (a) energy value; (b) the amounts of protein, carbohydrate and fat. Group 2 (a) energy value; (b) the amounts of protein, carbohydrate, sugars, fat, saturates, fibre and sodium.’ became in Schedule 6A Part I of The Food Labelling (Amendment) Regulations 1994 a half page single table listing both Group 1 and Group 2 nutrients, plus all the additional nutrients allowed to be mentioned, such as polyols under carbo￾hydrates and polyunsaturates under fats, with a complex set of cross references to Part II of the Schedule and subsequent paragraphs of Part I to explain the two separate groups and how they should be set out. It is no wonder that MAFF needed to issue explanatory guidance notes to accompany the amendment to the Regulations.2 148 The nutrition handbook for food processors 2 MAFF Guidance Notes on Nutrition Labelling, issued 18 March 1994
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