Food labelling is a complex field, and its ramifications go beyond merely making information available to consumers examining food products on store shelves. For milk processors, dairy manufacturers and retailers, the label on a dairy product is a way of communicating product information to buyers easily and directly. For consumers, it is one of the primary means of differentiating between different products and brands, and making informed purchasing choices.
Essentially a label serves 3 major functions:
- it provides basic product information regarding class designation, composition,common name, list of ingredients, net quantity, “best before” date, country of origin, and name and address of the manufacturer, distributor or importer;
- it provides health, safety and nutritional information. This includes instructions for safe storage and handling, nutritional information (e.g. details in the nutritional facts table regarding the quantity of fats, proteins, glycaemic carbohydrates, vitamins and minerals present per serving of stated size) and specific information for consumers following restricted diets;
- it acts as a vehicle for food marketing, promotion and advertising, in order to encourage sales (via label vignettes, promotional information and claims such as “low-fat,” “cholesterol-free,” “product of South Africa,” “no preservatives added,” etc.).
Regardless of which role a label plays, it must comply with the following principle: the information given must not be misleading. South African regulatory requirements are designed to protect consumers while ensuring fair competition for the industry.
In South Africa, dairy product labelling is subjected to a number of statutes and regulations. The responsibility for developing and administering food labelling requirements is shared and the enforcement of these laws is the responsibility of:
- Department of Health, Provincial Health Departments and Municipal Health Authorities – The Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act 54 of 1972)
- Department of Agriculture, Forestry and Fisheries – Agricultural Product Standards Act, 1990 (Act 119 of 1990)
- Department of Trade and Industry - National Regulator for Compulsory Specifications (NRCS) and the application of the relevant regulations in terms of the Trade Metrology Act, 1973 (Act 77 of 1973)
Together, the above acts and their regulations form a complex regulatory framework that can be difficult to navigate and sometimes, whether intentionally or not, allows for some difficulties in interpretation.
The purpose of this publication is to provide a user-friendly and integrated way for the interpretation of the labelling requirements applicable to dairy products. This publication is by no means exhaustive and the content should, therefore, be treated as guidelines. Readers are advised to consult the applicable regulations, also referred to in the publication.
Dairy product labelling in South Africa is an interesting, and also striking, example of the complexities facing an entire industry, and of the power relationships – or diverging interests – among government departments, dairy processors and distributors and food retailers. In a complex food market, balance among the stakeholders’ various needs is difficult to achieve, which explains why it often takes long to amend regulatory labelling measures. However in the midst of the expected dairy regulation amendments (regulations often only become effective 12 months following
However in the midst of the expected dairy regulation amendments (regulations often only become effective 12 months following the date of publication) it remains imperative that current legislation is adhered to.
This publication is therefore intended to serve as a guideline in terms of the current applicable legislation and will only be amended once new regulations are implemented.
It is our wish that this document will not only serve the interests of the dairy industry and consumer well, but also be used as an effective tool to protect the integrity of dairy products in South Africa.