Facilitations to food labelling due to the war in Ukraine

The war in Ukraine causes problems in the availability of raw materials and complicates the operation of production, distribution, and supply chains extensively, as Ukraine is a major producer of raw materials used in foods. The labelling of foods is strictly regulated within the EU. The national Finnish Food Authority has adopted a decision on temporary facilitations to mandatory labelling of certain foods to mitigate the problems caused by the exceptional situation.

The decision by the Finnish Food Authority has been issued under section 55 of the Food Act (297/2021), which concerns the correction of non-compliance with food regulations. The decision aims to facilitate the manufacture and placing on the market of conventional foods in Finland and allows for certain temporary flexibility with regards to food information requirements in the exceptional circumstances. The decision only applies to conventional foods. Therefore, the facilitations under the decision cannot be applied for example, to food supplements or to foods for special groups, such as baby foods and dietary substitutes for weight management.

Despite the facilitations, food safety must not be compromised, and the consumers must not be misled by food labelling or other information on food supplies.


The following requirements must be met for the facilitations to be acceptable:

  • List of ingredients – Conventionally, food ingredients must be placed in order of magnitude on the packaging of the food. The decision of the Finnish Food Authority allows that, if the food manufacturer has problems with the availability of raw materials due to an exceptional situation, the ingredient indicated on the label of the food may be omitted in whole or in part or replaced by another equivalent ingredient. A prerequisite is that the relevance of the ingredient to be excluded or replaced is minimal or non-existent in terms of the characteristics and choice of the buyer. This cannot therefore be the main ingredient of the food, an ingredient referring to the name of the food or, for example, an ingredient associated with the health and nutrition claims made on foods. Foods prepared with only a slightly modified recipe can be packed in a package with the ingredients already printed according to the original recipe.
  • The substances that cause allergies and intolerances must always be indicated on the labelling of the product. If the modified recipe contains such substances, a new labelling of the food or other equivalent measure is necessary to comply with the labelling requirements.  
  • Nutritional value information – Deviations in accordance with the EU Tolerance Guideline are allowed between the nutritional values indicated on the labelling of food and established under an official control. However, if the substituted ingredient significantly changes, for example the fatty acid composition of the food in a detrimental direction, the actual nutritional value information of the product should appear to consumers at least on the operators website. This situation could be at hand if, due to availability problems, the product contains a large amount of coconut oil instead of sunflower oil. When reporting nutritional values, the food sector operator must take food safety into account and avoid misleading consumers.
  • Ensuring traceability – The food sector operators must carry out self-monitoring in a written form. As part of this self-monitoring, operators shall enter in their self-monitoring records those foods of which composition differs from the ingredients indicated on the labelling. The data shall be marked in a way that the deviant food is traceable.
  • Communication – The importance of communication between the different operators in the food sector is emphasized, when products are placed on the market with labelling that deviate from the usual labelling requirements. Thus, the food sector operators supplying other operators’ products with exempted labels, must ensure that those receiving the products also receive an adequate and correct information on the foods and of their ingredients. To ensure effective communication, the food sector operators should also liaise with their local food control authority when there are significant changes linked to foods or other related activities due to the war in Ukraine.
  • Retailers must ensure the accuracy and adequacy of information – Retail trade must ensure that consumers receive information on foods or food groups, which compositional information has changed. Information about the changes and their cause should be communicated in a visible and easily perceptible manner, for example, in the vicinity of foods in the store and in the online store. The retail operators shall keep records of received and sold foods under the exceptional labels, to fulfill their self-monitoring obligations.

The decision of the Finnish Food Authority entered into force March 22, 2022, and will remain in force until September 30, 2022, the latest. It is possible to extend the decision if the problems arising from the war in food chains persist longer. The food sector operators should note that foods covered by the decision and placed in storage and retail sale by September 30, 2022, may be sold out after that date as required by the Finnish Food Authority’s decision.

Product Compliance and Product Liability

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