Primary ingredient means an ingredient or ingredients of a food that represent more than 50% of that food or which are usually associated with the name of the food by the consumer and for which in most cases a quantitative indication is required; The main ingredient may also be a compound food, for example strawberry jam. A food may also have more than one primary ingredient. The operator determines the primary ingredient of the food. The control authority may intervene if necessary.
For example, the primary ingredient in yogurt is milk or the primary ingredient in vegetable buns is vegetables, or the primary ingredient in meatballs is meat.
The country of origin (or place of provenance) of the primary ingredient of a food must be indicated where the country of origin (or place of provenance) of the food is indicated and is not the same as the country of origin (or place of provenance) of the primary ingredient. Where the country of origin of the primary ingredient is the same as the food itself, there is no need to indicate the country of origin of the primary ingredient. For example, rye bread is made in Finland, rye flour is grown in Finland. In this case, there is no requirement to indicate the country of origin of the primary ingredient of rye flour even if the country of origin of the rye bread is indicated.
When is it mandatory to indicate the country of origin of the food itself?
It is mandatory to indicate the country of origin (or place of provenance) of a food where
failure to do so could mislead the consumer as to the true country of origin (or place of provenance) of the food, in particular if the particulars or labels accompanying the food could infer that the food is of a different country of origin (or place of provenance).
Specific legislation may also require the indication of the country of origin of the food (e.g. fresh beef). The country of origin of the food may also be voluntarily indicated on the packaging. For example, the terms “made in”, “made in the country” or “produced in the country” followed by the country or the term “local food” are considered to be the terms of the country of origin (place of provenance).
The country of origin of the primary ingredient can be indicated in two different ways:
a) the country of origin or place of provenance of the primary ingredient is indicated by reference to one of the following geographical areas:
- “EU”, “non-EU” or “EU and non-EU”; or
- a territory or any other geographical area situated in more than one Member State or in a third country, if defined as such by international public law or if it is well understood by the reasonably well-informed average consumer; or
- FAO fishing area, or sea or freshwater area, if defined as such by international law or if well understood by the reasonably well-informed average consumer; or
- Member State (s) or third country (ies); or
- a region or any other geographical area located in a Member State or in a third country that is well understood by the reasonably well-informed average consumer; or
- country of origin or place of provenance in accordance with the specific Union provisions applicable to the primary ingredient as such.
b) “(name of the primary ingredient) does not originate in (country of origin or place of provenance of the food)” or a similar wording likely to have the same meaning for the consumer.
The European Commission has issued guidelines on the indication of the country of origin of the primary ingredient (Commission Communication 2020/C 32/01). The Finnish Food Authority has prepared a set of questions and answers based on questions received from the Finnish Food and Drink Industries' Federation, the Finnish Grocery Trade Association (PTY) and the Finnish Hospitality Association MaRa.
Legislation
Commission Implementing Regulation (EU) No 2018/775. sets out the indication of the country of origin of the primary food ingredient. The Regulation was to be applied from 1 April 2020. The Regulation does not apply to organic food, name-protected foods, geographical indications protected by the Regulation on the organisation of the markets (Regulation (EU) No 1308/2013 of the European Parliament and of the Council), spirit drinks (EC) No 110/2008) and aromatised wine products (EU) No 251/2014) and nor to registered trademarks.
The country of origin of meat used as a food ingredient, the country of origin of milk and the country of origin of milk used as an ingredient in milk products in prepacked food manufactured in Finland
The validity of Ministry of Agriculture and Forestry Decree 218/2017 has been extended until 31 December 2021 (Ministry of Agriculture and Forestry Decree 361/2020. This national decree provides for the indication of the country of origin of meat used as a food ingredient, the country of origin of milk, and the country of origin of milk used as an ingredient in milk products in prepacked products manufactured in Finland