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Food labelling requirements on exhibitions

​Since 13 December 2014, food brought to market in Germany must conform to the specifications of the Food Information for Consumers (FIC) Regulation (No. 1169/2011). Consequently, any food item intended to be supplied to end consumers now needs to be accompanied by certain mandatory information. One new requirement is that even merchandise that is not packaged needs to be accompanied by information about allergens. For example, the 14 most important substances or products that can trigger allergies or intolerances, such as nuts or soy, must be listed and highlighted in a list of ingredients. The food business operator under whose name or company the food item is marketed, or, if the food business operator is not established in the European Union, the importer importing the food item into the European Union, is responsible for providing the information about that food item.

In the opinion of the Federal Ministry of Food and Agriculture, which is responsible for such classifications, exhibitors who hand out food to visitors at trade fairs either as samples or in the form of hospitality provided to visitors at the exhibitor's stand must be considered "food business operators" and therefore subject to the labelling requirements of the FIC Regulation. However, the labelling requirements do not apply to unpackaged merchandise that is offered free of charge. Consequently, if exhibitors hand out unpackaged food items to trade fair visitors free of charge, they are not subject to the labelling requirements of the FIC Regulation. If food is pre-packaged or sold, the exhibitors must ensure that visitors are given the information required by the FIC Regulation. According to the provisions of the preliminary supplementary regulation to the FIC Regulation (VorlLMIEV), this information can be provided in written form, electronically or orally in Germany. If the information is provided orally, written documentation must be readily available upon request (e.g., as a notebook or fact sheet). In addition, a conspicuous notice explaining how customers can obtain information on allergens must be displayed in a clearly visible place at the point of sale.

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