Country of Origin Labelling Guidance by Food Standards Agency in 2008

The sorts of information (other than written declarations or descriptions such as “Made in the UK” or “British”) that could lead consumers to attribute a particular place of origin to a food include:

• use of country or place names in the name of the food or in its trade name, brand name or fancy name;
• written or illustrative information including maps, flags, emblems (e.g. a shamrock), choice of colour (e.g. the colours of a country’s national flag), references to persons associated with a particular place (e.g. “Uncle Sam”) and famous landmarks (e.g. the Eiffel Tower).

For some products the name of a country or place is used to describe their origin as part of the name of the food, for example “British Steak Pie” or “French Beef Bourguignon”, thereby, forming an origin declaration. If the place that is declared as the of origin of the food (according to the principle of last substantial change) is not the same as the place of origin of its primary ingredients, in order not to be misleading it may be necessary to provide information on the origin of those ingredients.

We suggest that to describe a rabbit pie that is made in the UK from imported rabbit as ”Produced in the UK” would not be best practice. We recommend that as a way of ensuring compliance with both the substantial change and the misleading labelling legislation it be described:

“Made in Britain from imported rabbit”, or
“Made in Britain from French rabbit”, or
“Made in Britain from rabbit sourced from the EU” (i.e. from a number of different countries from throughout the European Union).

Download: Country of Origin Labelling Guidance