HomelabelsBulk and pre-wrapped foods, community

Bulk and pre-wrapped foods, community

Il Legislative Decree 231/17, effective from March 9, 2018, attributes specific responsibilities to GDO - on MDD products, as on IDM products (1) - as regards the compliance of the Labels food. In addition, the duties of informing the consumer about bulk foods e prewrap you, as well as on the foods offered by community.

Bulk and pre-wrapped foods, foods offered by communities. Responsible parties

Both large-scale distribution and traditional distribution, both artisan workshops and public establishments (e.g. bars, ice cream parlors and pastry shops, ovens and pizzerias, takeaway and hot tables, etc.) are responsible for providing the consumer with precise information on the nature, composition and characteristics of the food 

Duties of information apply to individual products offered for sale in bulk (e.g. ice cream, sandwiches, sandwiches and other foods to be consumed outside, bakery and pastry products), as well as to the foods provided (e.g. pizzas, hot sandwiches, hot meals and cold to consume on the premises).

All the aforementioned operators they must therefore adopt concrete and suitable solutions to guarantee the effective availability to the consumer of the information required by reg. EU 1169/11 in relation to individual foods. For needs that primarily concern the protection of public health. (2)

Bulk and pre-wrapped foods, foods offered by communities. What news?

'A single sign or a special register or other equivalent system, including digital'- kept well visible near the display counters - they can alternatively be used to display the mandatory information referred to below. Provided, please note, that the allergens refer to the individual products.

  • Name of the food,
  • Ingredients list,
  • Allergenic ingredients,
  • Storage methods for rapidly perishable food products,
  • Expiry date for fresh pasta and fresh pasta with filling,
  • Actual alcoholic strength by volume for beverages with an alcohol content exceeding 1,2% by volume,
  • Percentage of glazing (tare) of glazed frozen products,
  • Designation 'thawed', in the cases provided for. (3)

The additional mandatory indications are reserved prescribed for non-prepacked products. (4) And any requirements established in the production regulations for PDO and PGI products.

For drinks sold by tapping, the sign can be applied directly on the system or next to it.

Drinking water not prepackaged served by the communities must report, where appropriate, the sales denominations'treated drinking water'and'treated and sparkling drinking water'(in case of addition of carbon dioxide).

Confectionery and bakery products sold by the piece or in bulk, 'generally intended for consumption immediately after purchase', although originally prepackaged, they can carry the mandatory information only on the sign or on the container, as long as they are easily visible and legible.

NB: the indication on the presence of allergenic ingredients in public establishments must always be provided in writing - in Italian and easy to read - 'so that it can be traced back to each food, before it is served to the final consumer by the community'. Through a 'menu or register or special sign or other equivalent system, including digital, to be kept in view'. If digital systems are used, the news must also appear on easily available paper registers. (5)

'Thawed', obligation of written information by the community. The public traders, as well as the managers of canteens and shops of catering they also have theobligation to inform patrons when the food is defrosted. (6)

Bulk and pre-wrapped foods, foods offered by communities. The penalties

Failure to indicate allergenic ingredients in individual products is punished with a fine ranging from € 3.000 to € 24.000, 'unless the fact constitutes a crime'.

The indication of allergens in different ways compared to those established by the Ministry of Health with circular 6.2.15 (7), on the other hand, entails the application of a fine ranging from € 1.000 to € 8.000. Penalty that is halved in case of formal errors only. (8)

Dario Dongo


(1) Distributor Brand (MDD), or private-label, and Brand Industry (IDM)

(2) With particular attention to the vulnerabilities of consumers affected by food allergy and intolerances, such as celiac disease. In addition to other news of health importance. See the paragraph 'Food safety and consumer information', in the article https://www.greatitalianfoodtrade.it/etichette/controlli-il-ruolo-dellamministrazione-sanitaria/

(3) See Legislative Decree 231/17, article 19

(4) We note in particular the news that must accompany the sale of fruit and vegetables in bulk. See the article https://www.foodagriculturerequirements.com/notizie/ortofrutta-origine-e-altre-informazioni-obbligatorie/

(5) It is therefore not sufficient to indicate on the register or on the menucontact the staff in case of allergies'. Nor limit yourself to reporting the complete list of allergenic ingredients provided for in Annex II of reg. EU 1169/11. See the article https://www.foodagriculturerequirements.com/notizie/europa-allergeni-nei-pubblici-esercizi-il-memento-del-min-sal/

(6) In this regard, it is worth noting the distinction between defrosted fish and fish products subject to thermal abatement https://www.greatitalianfoodtrade.it/idee/pesce-abbattuto-o-congelato

(7) See article cited in note 5

(8) See legislative decree 231/17, article 23

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

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