Lyubomir Panov: The issue of labeling products with different shelf life is still not resolved
‘Which questions remain open? All mandatory requirements are defined according to the principle of shelf life: before 40 and after 40. However, some butter manufacturers produce products that have several expiration dates: 35 days and 120 days, depending on storage conditions. Accordingly, it is unclear what to do with such products. Does it have to be labelled since September 1 or since December 1, when does it have to be withdrawn from circulation? The discussion here was, of course, very intense. What has already been agreed? We have such butter, if it has shelf life of less than 40 days, it hs to be labelled since December 1. There is enough time for putting into circulation and it will have to be displayed at the cash registers since the first of June,’ Lyubomir Panov said.
Nevertheless, the expert noted that it was not possible to reach a consensus with the regulatory authorities on a number of issues:
‘What worries me is that it is not possible to reach an understanding about the traceability of such butter. The Ministry of Industry and Trade stands on the position that such butter should be traced piece by piece. However, the issue is still under discussion, I hope they will satisfy our requests.
Another problem, Lubomir Panov stressed, is package. The rules say that consumer package is subject to labeling, but there is no clear information in the legislation on which package is considered to be consumer package:
‘Somehow we understand that 10 or 20 kg is not a consumer package and such butter does not get into retail chains, but there is a big question of how to prove it at customs or somewhere else. Initially, we had a position that if the product goes for processing, for packaging, in HoReCa, such products should not be subject to labeling. The issue is being discussed, Rospotrebnadzor does not really make concessions to us, so its decision has been suspended.
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