Nutrition Labelling Exemptions Consultation

Russell Napier
Food Standards Scotland
Pilgrim House
Old Ford Road
Aberdeen
AB11 5RL

Dear Russell

SFMTA represents 420 meat businesses in Scotland including butchers shops, Farm shops and small abattoirs.

We are in continual dialogue with our members through newsletters, email, regional meetings, visits to members' shops and feel that we have a good understanding of the issues facing our members. Nutrition Labelling is something that concerns them greatly not just being able to make the computations but also the costs involved in compliance.

We welcome opportunities to exempt small producers. We know that almost all of the meat businesses we represent manufacture products. Most of these are for direct sale from their own premises or from small local retailers.
We would like to make the following points:-

Micro Company:
We agree with the EU definition of less than ten full time employees and or turnover of less than 2m Euros. Not all will be a legal entity of company so 'business' would be a better description. It would be fair to assume that those businesses with a turnover of that magnitude would have the ability to pay the costs required to comply.

Consultation Question 1:
A threshold of £82,000 is far too low. A hybrid of quantity sold and value would be extremely difficult to enforce. If a burger is selling for £2 does that mean 500,000 could be sold per year (i.e. 1000 per week)? Some smaller producers specialising in burgers could get caught up in that while still having a turnover under £2m Euros.

Consultation Question 2:
Reference point 19. Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer. We agree with 'local' interpretation alongside the hybrid definition of small quantities.

Without exemptions for smaller quantities new product development would be severely hampered since no one would produce a new product that required nutrition information without first testing the market. Cost of compliance and the ability to pay would be a barrier to innovation.

Kind Regards

Douglas Scott
Chief Executive