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Honey, fruit juices, jams and marmalades, dehydrated milk. Proposals for the reform of marketing standards in the EU

The European Commission has adopted a number of reform proposals of the standard marketing of agri-food products in the EU – relating to honey, fruit juices, jams and marmalades, dehydrated preserved milk (in whole or in part) without lactose. (1)

1) Standard marketing of agri-food products, proposals for the reform of EU regulations

The proposals of reform of the standard marketing of agri-food products in the EU concern the so-called 'breakfast guidelines':

  • honey (directive 2001/110/CE),
  • fruit juices and other similar products intended for human consumption (Dir. 2001/112/EC),
  • jams, jellies and fruit marmalades and chestnut cream (dir. 2001/113/CE),
  • some types of preserved milk, partially or totally dehydrated (dir. 2001/114/CE). (1)

2) Objectives of the reform proposals

The reforms of the standard marketing of fruit and vegetables proposed by the European Commission pursue several objectives, in line with the EU strategy 'Farm to fork':

  • provide consumers with more information about the origin of products, as well as improve the transparency of the internal market through uniform marketing and labeling rules, (2)
  • promote the development of foods with more balanced nutritional profiles (with attention to sugars, in line with the EFSA opinion, 2022) and more sustainable,
  • reduce food waste, encouraging the purchase of local products and surplus donations.

3) 'Breakfast directives', the reform proposals

3.1) Honey, indication of origin

The origin of honey – understood as the place of its collection – has an undoubted influence on the characteristics and quality of the product, as we have seen. His standard marketing however, they still allow the designation of the blend of honeys from several countries with very generic terms such as 'EU', 'non-EU' or even 'EU and non-EU', (Meaning what 'Planet Earth Origin').

La Honey Directive No 2011/110/ECmoreover, it leaves national legislators with the right to define more stringent obligations on the labeling of the origin of honey. With the result of fragmenting the rules, altering competition between operators from different Member States, providing asymmetrical protection to consumers. (3)

The proposed change therefore provides for the obligation to indicate on the label all the individual countries of origin of the honey, even in the case of mixtures. Only one exemption is provided for the Ho.Re.Ca. sector. (Hotel, Restaurant and Catering), with the clumsy excuse of the small size of the single-serving packages that the Court of Justice had already censured, precisely in the specific case of the origin of honey on individual portions. (4)

3.2) Fruit juices 'low sugar'

Fruit juices they cannot contain added sugars, in addition to those naturally present. And it was therefore forbidden to use the nutrition claim 'with no added sugar' on their labels, as a common feature of the product category. (5) Furthermore, consumers are not able to distinguish fruit juices, fruit nectars and other similar drinks in relation to the presence of added sugars.

The proposals of modification of the regulation on fruit juices (Directive 2001/112/EC) therefore provide for:

  • the ability to insert the wording 'sugar free', on the label of fruit juices,
  • the introduction of a new category of fruit juices, consisting of 'low sugar fruit juice' e 'juice from concentrate with reduced sugar content' (-30% compared to similar products, and lower Brix degrees),
  • the new category of fruit nectars 'with no added sugar', whose labels must also bear the wording 'naturally contains sugars',
  • the possibility of using the proteins of sunflower seeds, in the field of authorized treatments, for the clarification of fruit juices.

3.3) Jams and marmalades

Sugar it is traditionally used to give a sweet taste and favor the conservation of jams. Taking into account the widespread need to reduce the intake of simple sugars in the diet, the Commission has proposed to increase the minimum fruit content in jams, from 350 g to 450 g per 1 kg of final product, 550 g in jams extra.

This improves the quality of the product and it stimulates theupcycling of fruit that does not comply with commercial requirements for sale as such, with a possible reduction in food waste (food loss).

The name 'jam' will finally be admitted for all types of jam. Precisely because to this name - and not only to the 'marmalade', which must keep the appropriate name – consumers associate the generality of the products of this category. The citrus juice from concentrate will then be included in the list of permitted ingredients.

3.4) Lactose-free dehydrated preserved milk

The question of lactose-free food products has increased significantly in recent years. The reform of Directive 2001/114/EC should therefore authorize a treatment to obtain lactose-free dehydrated milk, with a view to making lactose-free dairy products.

Italy it stands out for being the only country where the production of cheese with powdered milk is still prohibited (since 1974), in clear contrast to EU law. But the European Commission – which should guarantee compliance with the Treaty – does not seem willing to resolve this or other distortions of the single market (6,7,8,9).

3.5) Political examination, entry into force

The projects of reform of the standard marketing of the products in question are now subject to political scrutiny by the European Parliament and the Council. And it is possible that they will be adopted before the end of the current legislature in the event of an agreement between the EU institutions in the first reading of the text.

Member States will have to transpose the directive within 18 months of its entry into force, operators will have to comply within 24 months of that date. No implementing measures are envisaged by the Commission, since 'Member States have a long experience in implementing the four breakfast directives concerned and the proposed revisions are very technical in scope'.

Dario Dongo and Alessandra Mei


(1) Proposal for a Directive of the European Parliament and of the Council amending Council Directives 2001/110/EC relating to honey, 2001/112/EC relating to fruit juices and certain similar products intended for human consumption, 2001/113/EC relating to fruit jams, jellies and marmalades and sweetened chestnut purée intended for human consumption, and 2001/114/EC relating to certain partly or wholly dehydrated preserved milk for human consumption ( COM/2023/201 final) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2023%3A0201%3AFIN

(2) Beyond the high-sounding premises, the only novelty relating to the indication of origin on the label in the reform proposals of the standard marketing in question concerns honey. See Dario Dongo. Origin labeling, not a priority for the European Commission. GIFT (Great Italian Food Trade). 28.5.21

(3) Marta Strinati. Fraud in honey, from sugaring to misrepresented origins. French test. GIFT (Great Italian Food Trade). 28.20.2021

(4) Judgment of the Court (Third Chamber) of 22 September 2016

Breitsamer und Ulrich GmbH & Co. KG v Landeshauptstadt München (case C-113/15). https://curia.europa.eu/juris/liste.jsf?language=en&num=C-113/15

(5) Sugar-free fruit juices. GIFT (Great Italian Food Trade). 29.6.15

(6) Former European Agriculture Commissioner Phil Hogan laid the groundwork for an infringement procedure against Italy way back in June 2015. Since then, no results. Moreover, Italy has exceeded 100 infringement procedures as of 31.12.21, second only to Spain (see note 6)

(7) European Commission. Monitoring the application of EU law. Annual Report 2021 https://commission.europa.eu/system/files/2022-06/country_factsheet_italy.pdf

(8) One of the national measures in clear conflict with EU law is the setting of an expiry date ex lege, in Italy, for milk. v. TMC and milk expiration date? Clarifications by the lawyer Dario Dongo. FARE (Food and Agriculture Requirements). 18.3.18

(9) The proposed reform of dir. 2001/114/EC, in defiance of the principles governing the Internal Market, even provides that 'Member States may limit or forbid modifications to the composition of milk' to reduce the lactose content (see note 1, art. 4.1.2. XNUMX)

Alessandra Mei

Graduated in Law from the University of Bologna, she attended the Master in Food Law at the same University. You participate in the WIISE srl benefit team by dedicating yourself to European and international research and innovation projects.

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