Market study on date marking and other information provided on food labels and food waste prevention : final report.
Date: 2018-02-07
Institutions: Directorate-General for Health and Food Safety
Subjects: agri-foodstuffs, consumer behaviour, consumer information, domestic waste, food safety, food waste, foodstuff, foodstuffs legislation, labelling, packaged product, preparation for market, product life, product quality, storage of food

Market study on date 
marking and other 
information provided on food 
labels and food waste 
prevention 
Final Report 

Written by ICF in association with  
Anthesis, Brook Lyndhurst, and WRAP 

January  2018 

 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Health and Food Safety 

Directorate E - Food and feed safety, innovation  

Unit E1 — Food information and composition, food waste 

E-mail:  sante-consult-e1@ec.europa.eu   

European Commission 

B-1049 Brussels 

 
 
 
EUROPEAN COMMISSION 

Market study on date 
marking and other 
information provided on food 
labels and food waste 
prevention 
Final Report 

Directorate-General for Health and Food Safety 

January, 2018 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

Table of Contents 

Glossary ............................................................................................................ i 
Abstract ........................................................................................................... iii 
Executive Summary ........................................................................................... v 

Method .......................................................................................................... v 
Findings from the desk research ....................................................................... vi 
Findings from the stakeholder consultations and market survey ............................ vi 
Conclusions .................................................................................................... ix 
Recommendations .......................................................................................... ix 

1 

Introduction ...............................................................................................12 

This report ...........................................................................................12 
1.1 
1.2 
Purpose ...............................................................................................12 
1.3  Method ................................................................................................12 
Structure of this report ..........................................................................13 
1.4 

2  Desk research ............................................................................................13 

2.1 
Introduction .........................................................................................13 
2.2  Date-marking practices in the EU food chain ............................................14 
2.3 
Evidence on the links between consumer use of date marks and food waste 16 
2.4  Determinants of product life and its impact on food waste .........................18 
The products that contribute most to food waste in the EU .........................20 
2.5 
The wasted food products most sensitive to date mark and labelling issues ..23 
2.6 

3  Market research ..........................................................................................26 

3.1 
Introduction .........................................................................................26 
3.2  Method ................................................................................................26 
3.3  Market research results and analysis .......................................................31 
3.4  Open-life and on-pack storage advice ......................................................52 
Summary and conclusions .....................................................................56 
3.5 

4  Stakeholder consultations on date marking practice ........................................59 

Research design and method .................................................................59 
4.1 
Stakeholders’ understanding of “use by” and “best before” ........................60 
4.2 
Factors in producers’ choice of date mark type .........................................61 
4.3 
Factors that determine location, format and legibility of the date mark ........64 
4.4 
Factors in setting product shelf life ..........................................................64 
4.5 
4.6 
Storage advice and open life advice ........................................................69 
4.7  Use of date marking in managing the food supply chain.............................70 
Enforcement of date marking rules .........................................................72 
4.8 
4.9 
Barriers to, and facilitators of, better utilisation of date marking in relation to 
food waste prevention ....................................................................................72 
4.10  Stakeholder views on Annex X of the FIC Regulation .................................79 

5  Conclusions ................................................................................................81 

Introduction .........................................................................................81 
5.1 
The existing evidence base ....................................................................81 
5.2 
Choice of date mark type (“use by”, “best before”) ...................................81 
5.3 
5.4 
Product shelf life/ setting of expiry date ...................................................83 
5.5  On-pack storage advice and open-life instructions.....................................84 
Legibility and layout of date mark and on-pack information ........................85 
5.6 
Enforcement of compliance with FIC Regulation and guidance ....................85 
5.7 
5.8  Donation of food past the "best before" date ............................................86 
5.9 
Possible further exemptions to date marking under FIC Regulation Annex X .86 
Overall conclusions ........................................................................................86 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

6  Recommendations .......................................................................................87 

Introduction .........................................................................................87 
Technical guidance and support for dialogue within the supply chain would 

6.1 
6.2 
help to steer FBOs towards best practice in date labelling ...................................87 
6.3 
FBOs should be encouraged to act to address the problem of illegible date 
marks as a priority .........................................................................................88 
6.4 
choices .........................................................................................................88 
Support efforts to extend product life ......................................................89 
6.5 
Address barriers to safe redistribution of food ..........................................90 
6.6 

Further steps could be taken to help empower consumers to make informed 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

Glossary 

Term 

Available life 

Meaning 

The period of time remaining on a product at a given 
stage in the supply chain 

Avoidable food waste 

Edible materials of a food product that could have been 
consumed but become waste for various reasons. 

Company brand 

A brand owned by a food manufacturer 

Defra 

EU 28 

FAO 

FBO 

UK Department of Environment, Food and Rural Affairs 

The 28 Member States of the European Union 

Food and Agriculture Organization of the United Nations 

Food  Business  Operator  –  for  example,  a  company  that 
produces  or  retails  food,  or  an  organisation  that  operates 
a food bank 

FIC Regulation 

Regulation (EU) No 1169/2011 of the European Parliament 
and of the Council on the provision of food information to 
consumers 

Food waste 

FUSIONS 

LBRO 

MAP 

A general term comprising of avoidable and unavoidable 
food waste. 

Food Use for Social Innovation by Optimising Waste 
Prevention Strategies, a multi-stakeholder platform 

Local Better Regulation Office 

Modified Atmosphere Packaging 

Minimum Life On Receipt 
(MLOR) 

The amount of life remaining on a product on receipt into 
a retailer’s depot. Retailers use MLOR to assess whether 
the available life remaining on a product when delivered to 
retail depot is sufficient for retail and consumer stages. 

MS 

Mt 

NACE codes 

NCA 

Open Life 

Member State(s) 

Million tonnes 

«nomenclature statistique des activités économiques dans 
la Communauté européenne» : Statistical classification of 
the economic activities in the European Community 

National Competent Authority 

The period that a product should be consumed within once 
open, e.g. ‘once opened consume within x days’, as 
specified on an information label on the product packaging 

POS 

Point Of Sale 

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Market study on date marking and other information provided on food labels and food 
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Term 

PRODCOM 

Product life or Shelf life 

Meaning 

"PRODuction COMmunautaire" (Community Production): 
statistics on the production of manufactured goods 

The length of time a product may be stored unopened, in 
accordance with storage advice, without becoming 
unsuitable for consumption, with regards to food safety 
and/or quality. 

REFRESH 

Resource Efficient Food and Drink for the Entire Supply 
Chain, EU Horizons 2020 project 

Retailer’s own brand 

A brand owned by a food retailer 

RDC 

SKU 

Total life 

Unavoidable food waste 

Regional Distribution Centre, retailer depot that supplies 
stores within a region 

Stock Keeping Units 

The length of time a product may be stored without 
becoming unsuitable for consumption.  (NB, it is not the 
same as the “maximum life”, which is the technical 
maximum product life that could be set without 
compromising food safety.) 

Inedible materials that become waste when the product is 
used/consumed. In food manufacturing this may also 
include the edible fraction of non-recoverable materials in 
manufacturing processes. 

WRAP 

Waste and Resources Action Programme 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

Abstract 

European law (Regulation (EU) No 1169/2011 on Food Information to Consumers (the 
“FIC Regulation”)) requires that most pre-packed foods display a date mark and 
accompanying wording that explains whether the date signals a threshold in the 
product’s safety (“use by”) or its quality (“best before”). The date mark is intended for 
use by consumers but also informs food chain operations, examples being retailers’ 
stock management and food redistribution systems. 

This study has been carried out to help inform actions of the European Union (EU) to 
prevent food waste, as part of the Circular Economy Action Plan. The study examined 
the practical application of EU date labelling legislation and its implications for food 
waste prevention. It involved: desk research on the use of date labels and their links 
to food waste in the supply chain and in the home, including a review of EU food 
waste data to identify the main categories of foods contributing to food waste; market 
research to collect and analyse date labels on 2,296 products of ten pre-defined food 
product types (pre-prepared fruit/ vegetables, pre-packed sliced bread, chilled fish, 
sliced ham, fresh milk, yoghurts, hard cheese, chilled fresh juice, pre-prepared chilled 
pasta, and sauce (ketchup) that were purchased during 109 retail store visits in eight 
EU Member States (Germany, Greece, Hungary, the Netherlands, Poland, Slovakia, 
Spain and Sweden); and consultations with food businesses, national regulators and 
other stakeholders on their understanding and application of relevant aspects of the 
FIC Regulation. 

The study estimates that up to 10% of the 88 million tonnes of food waste generated 
annually in the EU are linked to date marking. The main food categories contributing 
to food waste were fruit and vegetables, bakery products, meat including fish and 
poultry, and dairy products. 

The over-arching conclusion from the analysis of EU food waste data is that any 
proposals to reduce food waste by driving improvements to labelling practices should 
focus on those food product types for which the consumer decision to discard is likely 
to be informed by reading the on-pack label; and whose contributions to EU food 
waste is significant. Of food product types used in the market research, the greatest 
opportunities for prevention of food waste in relation to date marking exist for milk 
and yoghurts, fresh juices, chilled meat and fish. For other product types, the 
consumer decision to discard is more likely to be informed by visual cues that indicate 
a decline in product quality and palatability.  

Interviewees showed high awareness of the FIC Regulation and its requirements, and 
the market survey showed a high level of compliance. Almost 96% of products 
sampled carried either a “best before” or “use by” date mark and accompanying 
wording that were in line with the provisions of the FIC Regulation. However, the 
legibility of date marks was judged to be poor on 11% of products sampled.  

The market survey found variation in date marking practices within product types and 
among Member States. Of the ten product types sampled for this study, only sauce, 
sliced bread, and fresh juice had predominantly the same type of date mark in all 
eight Member States surveyed. The other product types tended to display a “use by” 
date mark in some Member States but a “best before” date mark in others. Some 
otherwise identical products manufactured by international brands displayed a “use 
by” date in one Member State and a “best before” date in another, and no significant 
difference was found between the average remaining life values for “use by” and “best 
before” labelled products of the same type. There was also wide variation in the 
storage and open life advice found on the same type of product.  

Interviewees advised that the choice of date mark was influenced by different factors 
such as food safety and technology considerations, national customary practice, and 
company-specific factors. Shelf life is normally determined by safety and quality but 
other factors can affect the specified date, such as producers’ expectations of how 

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consumers will store food, retail practices in relation to date marking and the supply 
chain’s temperature regime for chilled foods in the country where the food will be sold. 

The study recommendations call for the production of technical guidance for food 
businesses on how to: determine shelf life; choose between “use by” and “best before” 
date marks; specify storage advice and open life instructions; and examine 
opportunities for possible extension of product life. The study also calls for specific 
action by food producers to remedy the problem of illegible labels. Evidence from desk 
research and stakeholder interviews suggests that many consumers do not understand 
date marks, including the distinction between “use by” and “best before”; however, 
stakeholders were divided as to whether there would be merit in changing the 
terminology. There was also widespread support for pursuing consumer information 
campaigns on date marking, which the study authors advise should be informed by 
results of previous initiatives.  

Further research is also needed regarding consumers' use of date marks and storage 
advice in order to help to inform future policy making. 

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Market study on date marking and other information provided on food labels and food 
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Executive Summary 

Introduction 

European law (Regulation (EU) No 1169/2011 on Food Information to Consumers (the 
“FIC Regulation”)) requires that most pre-packed foods display a date mark and 
accompanying wording that explains whether the date signals a threshold in the 
product’s safety (“use by”) or its quality (“best before”). The date mark is intended for 
use by consumers but also informs food chain operations, examples being retailers’ 
stock management and food redistribution systems. 

This study has been carried out to help inform actions of the European Union (EU) to 
prevent food waste, as part of the Circular Economy Action Plan. The study examined 
the practical application of EU date labelling legislation and its implications for food 
waste prevention.  

The study’s objectives were to:  

 

investigate food business operators’ and national competent authorities’ 
understanding and practices regarding information provided on food labels, 
especially date marking; 

  assess the possible impact of these practices on food waste; and, in doing so, 

  support the work of DG SANTE on date marking in relation to food waste 
prevention and, in particular, its dialogue with all actors on this issue. 

The study was contracted to ICF by the Directorate-General for Health and Food 
Safety (SANTE) of the European Commission. ICF worked in close collaboration with 
Anthesis and was supported by experts from Brook Lyndhurst and the Waste and 
Resources Action Programme (UK). 

Method 

The study involved:  

  desk research on the use of date labels and their links to food waste in the 
supply chain and in the home, including a review of EU food waste data to 
identify the main categories of foods contributing to food waste;  

  market research in the form of a survey that used a ‘mystery shopping’ format 
in which products of ten pre-defined types were purchased from selected stores 
in eight Member States (Germany, Greece, Hungary, the Netherlands, Poland, 
Slovakia, Spain and Sweden). In this survey:  

- 

- 

- 

the eight Member States were selected to capture the variation in 
purchasing patterns across the EU; 

the product types selected were: pre-prepared fruit/ vegetables, pre-packed 
sliced bread, chilled fish, sliced ham, fresh milk, yoghurts, hard cheese, 
chilled fresh juice, pre-prepared chilled pasta, and sauce (ketchup); 

the main factors in the selection of the product types were: the food 
category’s overall contribution to EU-28 avoidable food waste; evidence of 
use of different types of date mark for the same product type; extent to 
which consumers may take into account date marks when deciding whether 
or not to discard particular products; and relevant issues identified for the 
products relating to open life guidance, storage for optimal product life, and 
home freezing advice; 

-  2,296 products from 1,058 brands were purchased in 109 store visits. 

Detailed specifications prepared for each product enabled comparisons in 
date marking and information practices to be made between products across 
different brands, retailers, and Member States. 

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  semi-structured telephone interviews with 39 Food Business Operators (FBOs) 
and 19 National Competent Authorities (NCAs) in the countries targeted by the 
market survey, plus 16 EU-level organisations representing food industry 
sectors, consumers and food bank operators. These interviews focused mainly 
on stakeholders’ understanding of the FIC Regulation and its application. 

Findings from the desk research 

Fruit and vegetables account for the highest proportion of avoidable food waste in the 
EU-28 across the manufacturing/processing, retail, food service, and household 
sectors: 16.2 million tonnes per year (Mt/yr), i.e., 33% of total avoidable food waste. 
This category is followed by bakery products (10.5Mt/yr, 21%); meat, including fish 
and poultry (4.8Mt/yr, 10%); and dairy products (4.7Mt/yr, 10%). No other category 
contributed more than 4.2Mt/yr or 8% of the total. Annual EU-28 food waste 
attributable to date marking issues was estimated at 6.9 Mt/yr - 8.9 Mt/yr across the 
manufacturing/ processing, retail and household sectors. This represents 5%, 55%1 
and 9.5-12% of the food waste from those three sectors, respectively. It was not 
possible to include the food service sector on the basis of data reviewed or to provide 
a breakdown by food product category. The value of 8.9 Mt/yr for food waste 
attributable to date marking issues approximates to 10% of the estimate for total food 
waste in the EU-28 (88 Mt/yr). 

The over-arching conclusion from the analysis of EU food waste data is that any 
proposals to reduce food waste by driving improvements to labelling practices should 
focus on those food product types for which the consumer decision to discard is 
(already) likely to be informed by reading the on-pack label; and whose contributions 
to EU food waste is significant.  Of food product types used in the market research, 
the greatest opportunities for prevention of food waste in relation to date marking 
exist for milk and yoghurts, fresh juices, chilled meat and fish. For other product 
types, the consumer decision to discard is more likely to be informed by visual cues 
that indicate a decline in product quality and palatability.  

Findings from the stakeholder consultations and market survey 

Use and choice of date marks 

The interviews showed a high level of awareness among FBOs and NCAs of the FIC 
Regulation, its requirements, and its intent in distinguishing between “use by” date 
marks and “best before” date marks. This is consistent with the key finding from the 
market survey that almost 96% of products sampled displayed a date mark and 
accompanying wording that were in line with the provisions of the FIC Regulation. 

Nonetheless, the market survey found variation in date marking practices within 
product types and among Member States. Of the ten product types sampled for this 
study, only sauce, sliced bread, and fresh juice had predominantly the same type of 
date mark in all eight Member States surveyed. (Along with hard cheese, these were 
the product types for which more than 80% of products sampled displayed a “best 
before” date mark.) The other product types tend to display a “use by” date mark in 
some Member States but a “best before” date mark in others. Examples were even 
found of otherwise identical products manufactured by international brands displaying 
a “use by” date in one Member State and a “best before” date in another.  

The stakeholder interviews provided insights into the causes of the differences 
observed among FBOs and across the EU. Interviewees also gave examples of 
products listed in Annex X of the FIC Regulation (which details food exempt from “best 
before” labelling obligations) which have a date mark where none is required.  

1 For the retail sector this includes date expiry within stores. 

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Some producers take account of factors beyond the product characteristics when 
determining how to apply the FIC Regulation with respect to date marks. These 
include their perceptions of consumer knowledge of date labels. Some producers apply 
“use by” date marks to products (for which a “best before” date mark would be more 
appropriate) as a precautionary measure given the uncertainties about consumer 
handling of food. This is also due to differences in perceptions of what foods are 
considered to be ‘highly perishable’ in each market as well as retailer preferences for 
date marking. 

Retailers tend to favour a consistent approach to date marking for each product type 
in each national market but are used to accommodating variation in labelling practice 
between national markets. The determination of the preferred type of label in each 
country is influenced by factors that include perceived expectations of consumers and, 
in some cases, guidance provided by a trade association or the relevant NCA. 

Some NCAs provide interpretative guidance of date marks based on the FIC 
Regulation. There is variation among Member States in what this guidance entails.  
There are also examples of NCAs working to harmonise practices across countries 
(e.g. among Nordic countries). 

Product shelf life/ setting of expiry date 

FBOs are responsible for the determination of products’ shelf life, as well as the choice 
of date mark, other than for eggs and poultry meat. The remaining shelf life (as 
measured by the gap between the date of purchase and the “use by” or “best before” 
date on the product) of products purchased in the market research was assessed.  
None of the 10 product types showed a statistically significant difference between the 
remaining life of products carrying “use by” and those carrying “best before” date 
marks. This suggest that date marks were being used interchangeably.  

Interviews with FBOs and NCAs suggest that the declared shelf life is normally 
determined by safety and quality considerations (as informed by microbiological or 
sensory testing), and previous experience of a product or similar products. For some 
FBOs the product life testing also takes account of the variations among countries in 
retailers’ storage temperatures.  

The interviews identified examples of retailers and suppliers working together to 
improve shelf life. FBOs prioritise food safety – and tend to act cautiously to take 
account of differences in storage conditions within the food supply chain and the 
‘worst case’ scenarios for consumer or retail behaviour (e.g. chilled foods being stored 
in ambient conditions). This suggests that greater harmonisation might bring further 
benefits in allowing FBOs to extend shelf life safely and reduce buffers, taking account 
of varying storage conditions. 

Concern about consumer perceptions of products can prevent firms from exploiting the 
potential for extension of shelf life provided by improved storage technology. For 
example, some products which have traditionally been sold as chilled products can 
now be safely stored at ambient temperatures (for example, fruit juice and certain 
cheeses). Producers may resist setting a longer shelf life for fear of undermining a 
product’s association with freshness and quality. 

NCAs are generally not involved in providing technical guidance on product testing or 
setting shelf lives. The main reason given by NCAs for not providing such guidance is 
that setting the date is the producers’ responsibility (as only they can fully understand 
product formulation and issues of food quality and safety) and so the producers should 
continue to be accountable for the date setting choices that they make. 

On-pack storage advice and open-life instructions 

The market survey found a wide range of storage advice on the sampled products, 
particularly in relation to the appropriate storage temperature for chilled products 
(which was expressed either as a maximum temperature or a temperature range). The 

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quoted storage temperatures tended to be lower than the standard maximum retail 
temperatures identified by interviewees as the norm for the relevant market. The 
storage advice in the same product group was often found to vary or even be 
contradictory across different markets, potentially leading to consumer confusion.  

There was variation in prevalence of advice on open life. Such advice was provided on 
majority of fresh juice and pre-prepared chilled pasta products. It was least common 
on yoghurt, tomato sauce, hard cheese and sliced bread. 

Interviewees acknowledged the lack of consistency in storage advice and open life 
advice. There was no consensus on what constituted good quality, non-mandatory 
advice on open life for consumers. The discussions suggested that FBOs’ concern to 
avoid customer complaints and adjustments for factors such as consumer knowledge, 
and uncertainty about the conditions in which the product might be stored, led them 
to use formulations such as ‘consume immediately’ as a precautionary measure. 

Legibility and layout of date mark and on-pack information 

Fieldworkers reported difficulty in reading date marks and/or the wording on 11% of 
the products sampled. The main problems were that the text was too small, the layout 
was unhelpful and the print quality was poor. For example, 20% of pre-prepared 
chilled pasta products had a date mark or associated wording that was unclear, as did 
16% of sliced ham products and 13% of sliced bread. No interviewees mentioned 
specific problems with making dates legible, despite the difficulties faced during the 
fieldwork. 

The market research found that the date wording and date mark were alongside one 
another on some packaging and appeared separately on others. In the latter case, the 
FIC Regulation requires the date wording to state where the date mark is displayed on 
the packaging (e.g., “best before: see date on cap” rather than just “best before:”). 
FBOs explained this variation by reference to historic practices in each market that 
governed the location of the date mark for certain product groups as well as 
limitations due to product format. FBOs did not see the separate location of date mark 
and date wording as a problem for consumer understanding; when asked, they stated 
that such layouts were standard and something that consumers were accustomed to. 

Enforcement of compliance with FIC Regulation and guidance 

Most NCAs considered that the choice of date mark is the responsibility of FBOs and so 
not a matter for them to enforce. However, some NCAs and other actors (e.g. trade 
associations) actively tried to shift date marking practices when these have the 
potential to increase food waste. Examples are: attempts to harmonise storage 
conditions across the chilled food chain; support for stakeholder or cross-industry 
dialogue; guidance clarifying interpretation of “best before” or “use by”; and studies 
on consumers' understanding of date labels. 

Donation of food past the "best before" date 

Interviews revealed a wide range of practices and legal frameworks governing the 
donation of food that has passed its “best before” date. Although allowed under EU 
rules, some Member States discourage or forbid this practice (e.g. Poland) while 
others encourage it (e.g. Italy). The local infrastructure for food distribution, including 
food banks and charity organisations, also influences FBOs’ practices. 

Possible further exemptions to date marking under FIC Regulation Annex X 

Annex X of the FIC Regulation lists food products that are not required to display a 
“best before” date mark. There was no consensus among those consulted on whether 
further exemptions in the FIC Regulation, based on evidence of consumer behaviour in 
relation to date marking, would be helpful in reducing food waste. Consumer 
expectations relating to the presence of information and a date mark played a part in 
this feedback.  

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Conclusions 

Based on the study's findings, the authors conclude that avoidable food waste linked 
to date marking is likely to be reduced where: 

  a date mark is present, its meaning is clear and it is legible; 

  consumers have a good understanding of date labelling (notably the distinction 

between “use by” – as an indicator of safety − and “best before” – as an 
indicator of quality); 

  “use by” dates are used only where there is a safety-based rationale for doing 

so, consistent with the FIC Regulation; 

 

the product life stated on the packaging is consistent with the findings of safety 
and quality tests, and is not shortened unnecessarily by other considerations, 
such as product marketing; 

  storage and open life guidance are consistent with the findings of safety and 

quality tests; 

 

there is a level of consistency in storage of food at retail and guidance for 
consumers regarding the temperatures at which products should be stored in 
the home.   

Recommendations 

The study makes the following recommendations. 

1. Technical guidance and support for dialogue within the supply chain would 

help to steer FBOs towards best practice in date labelling 

A number of issues identified in the research could be addressed by producing 
technical guidance and by giving support to dialogue within the supply chain. Such 
guidance, which is likely to be specific to food product categories, should be developed 
by a multi-stakeholder group and could be coordinated by the Commission through 
the EU Platform on Food Losses and Food Waste. 

  Determination of shelf life and guidance on storage and open life advice 

The uncertainty among FBOs as to how best to determine shelf life and guidance on 
storage and open life could be addressed by technical guidance that takes into account 
food safety and technology considerations as well as best practice. NCAs, scientific 
bodies and trade associations could be consulted. Important areas for guidance 
include the assessment of possible risk to health and the determination of product 
shelf life and open life, taking account of safety and other factors. Where there are 
gaps in evidence, support for new research should be considered.   

  Making a choice between “use by” and “best before” labels 

It would be beneficial to provide technical guidance on when a “best before” date mark 
could be used instead of a “use by” date mark without compromising product safety 
and consumer information. At present, local market conditions and inertia among 
FBOs may be limiting the potential for a consistent approach across Member States, as 
evidenced by conflicting information given on multilingual labels. 

  Management of temperatures of chilled food in the retail supply chain 

The differences in management practices in the supply chain for chilled food among 
Member States that have an effect on producers’ decisions about product shelf life 
could be addressed by guidance or regulations.   

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2. FBOs should be encouraged to act to address the problem of illegible date 

marks as a priority 

The legibility problems − poor print quality and ink retention, excessively small font 
size, layout, and colours that could not be distinguished against the background 
packaging, etc. − should be addressed by FBOs in partnership with retailers, and 
checked by NCAs as part of their monitoring of compliance with the FIC Regulation.  
These problems most commonly occurred when date marks were printed onto plastic 
film and plastic bottles. However, they may also occur when an “overlabel” displaying 
information, for instance in an additional language, is affixed to food packaging but is 
damaged. 

Supplementary measures targeted at FBOs and the packaging sector that could help 
to address this problem are: an online resource that illustrates best practice for 
different packaging formats, considering layout, legibility and compliance with FIC 
requirements; and consultation with the packaging sector/ trade bodies on minimum 
ink adherence/ chemical compatibility for printing onto different materials, taking into 
account product life. 

3. Further steps could be taken to help empower consumers to make 

informed choices 

This study did not involve direct consumer research but evidence and perceptions of 
consumer awareness and behaviours figured prominently in the desk research and in 
the stakeholder consultations. 

  Improving coherence and consistency of food information to consumers 

The problem of inconsistent guidance from various sources, national laws and local 
practices, which may lead to increased food waste in the home or at the point of sale, 
is especially acute on multilingual packaging where information in one language, 
including maximum and minimum temperatures, open-life guidance, and even the 
date wording, may contradict information displayed in another. Thus there appears to 
be a need for stakeholder dialogue or further European guidance on this topic. 

  Ensure that any new consumer education campaigns are informed by a 

synthesis of existing research evidence on consumer behaviour 

There is evidence that many consumers do not fully understand the distinction 
between “use by” and “best before” labels, and that this can contribute to edible food 
being discarded; however, stakeholders were divided as to whether there would be 
merit in changing the terminology. Many interviewees suggested that the European 
Commission should support consumer education campaigns on food waste prevention. 
However, before responding to calls for supporting consumer campaigns, it is 
recommended that relevant existing research evidence is collated and made available 
to inform the communication strategy. This synthesis could usefully be conducted at 
an EU level given the variable depth of evidence available in individual Member States. 

  Research on consumer engagement with date labels and associated 

guidance in the home would help to inform future policy 

The evidence base on how to inform consumers and influence behaviour so as to avoid 
unnecessary food waste through use of “best before” and “use by” dates, storage 
advice and open life advice is comparatively weak. Support for further research in this 
area would help to inform future policy, including by exploring options to increase the 
impact of communications via graphic symbols or smart packaging.  

4. Support efforts to extend product life 

  Guidance highlighting measures that increase product life 

There is evidence that discussions about the Minimum Life On Receipt between 
producers and retailers have helped to improve product life and reduce food waste by 

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encouraging investment in new technologies, such as innovative packaging and “clean 
rooms” (i.e., processing areas in which environmental pollutants are kept at very low 
levels by means of air filtration). NCAs and other stakeholders could highlight good 
practice or use guidance to encourage FBOs to consider extension of product life for 
certain foods.  

5. Address barriers to safe redistribution of food  

This study did not investigate barriers to food redistribution in-depth but the research 
did suggest scope to clarify the legal position and improve consistency of practice with 
regard to the sale or redistribution of food that has passed its “best before” date. (This 
would need to be specific to food product categories.) This recommendation could be 
considered within the scope of work commissioned by DG SANTE to support food 
redistribution in the EU. 

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1 

Introduction  

1.1  This report 

This is the final report of a study that provides evidence on the use of date marking on 
packaged food products in the European Union.  The work was undertaken by ICF2 in 
association with Anthesis3. The core team was supported by experts from Brook 
Lyndhurst and the Waste & Resources Action Programme (WRAP). 

1.2  Purpose 

Date marks were introduced by supermarkets in the 1970s to help ensure the 
freshness of food products and to assist with stock control. They are now additionally 
used on many food products to support these supply chain functions and to help 
consumers to make safe use of food with minimal waste. The use of date marks is 
governed by EU law. 

There is strong evidence to suggest that consumers are confused by the information 
provided on food packaging (including date marking) and by the variation in how food 
businesses apply it4. There is further evidence connecting misinterpretation of date 
marks with food waste5. In that context, evidence on the nature and use of date 
marks could inform the specification of new measures to help consumers reduce the 
amount of food they waste and also to reduce food waste at earlier stages of the 
supply chain. Estimates reported of the share of household food waste in the EU that 
could be linked to date marking range from 15 to 33%.6 Although estimates have 
been made of the amount of food wasted attributable to date labelling, these 
estimates are highly uncertain. Hence they have been subject to review by this study. 

Reduction in food waste was identified by the Commission’s Circular Economy Package 
as important to the creation of a more sustainable food supply chain and to achieve 
more efficient use of resources.  This study is intended to contribute to that effort by 
providing evidence on:  

 

 

the understanding and practices of food business operators and national 
competent authorities with regard to date marking; and  

the possible impact of these practices on food waste. 

The information gathered will help to inform the active dialogue among the European 
Commission, the food industry, national authorities and other stakeholders. 

1.3  Method 

The method adopted for this study is explained in detail in Annexes 1, 2 & 3. (Annexes 
to this report are provided in a separate document.) The core components were: 

  desk research on data on food waste in the European Union (EU); 

  a mystery shopping exercise involving 109 store visits in eight Member States 

that sampled 2,296 products from 1,058 brands of 10 target product types; and 

 

interviews with food business operators and national regulators that examined 
the factors determining the specification of date marking for different food 
types and explored opportunities for food waste prevention. 

2 www.icf.com 
3 https://anthesisgroup.com 
4 Lipinski et al., 2013; Newsome et al., 2014; WRAP, 2010. 
5 Norden, 2016. 
6 Note from the Netherlands and Sweden to the Agriculture Council of the European Union, May 2014;  
WRAP, 2008 

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1.4  Structure of this report 

The remainder of this report is structured as follows: 

  Section 2 describes the desk research to assess the evidence on EU food waste 
data and discusses the key findings that are most relevant to the process of 
selecting food product types to target in the fieldwork stages of research; 

  Section 3 sets out the market research fieldwork undertaken and presents key 

findings; 

  Section 4 presents findings from the stakeholder interviews; 

  Section 5 presents the conclusions of the study based on the findings of the 

desk research, market research and interview programme; 

  Section 6 presents the study recommendations. 

2 

Desk research 

2.1  Introduction 

This section assesses the evidence in the literature on the links between date marks 
and food waste. Forty three articles associated with food waste and evidence of 
possible links with date labels and other food waste drivers were reviewed7. The 
articles were produced by various public and private organisations from around the 
world, including food manufacturers, not-for-profit organisations, EU research projects 
and food labelling companies. Most did not relate to specific research undertaken on 
the direct effects that food labels have on food waste, either in the food chain or in the 
home. The review found that there is more quantitative evidence available on food 
retail and consumers than for manufacturing.  

The most significant work on the causes of food waste in supply chains, including 
specific projects on date labelling and food waste has been undertaken by: 

  The Nordic Council of Ministers, whose reports focus on processes involved in 

generating date labels for different food products or the impacts on consumers 
and retailers8.  

  WRAP, which has examined links between food waste and date labelling in a 
series of report, and provides evidence on the role of date marks in the wider 
context of food waste reduction in the supply chain and with consumers9; and 

  REFRESH (Resource Efficient Food and Drink for the Entire Supply Chain), an 

EU-funded research project that has reported on consumer behaviours relevant 
to food waste, including the confusion caused by date labels. 

These sources make the most significant contributions to the results of the review. 

7 Annex 2 provides full details of the references that were used in this review, identifying links between date 
marks and food waste. 
8 Examples are “Food Waste and Date Labelling” (Norden, 2016) and “Date labelling in the Nordic countries, 
Practice of legislation” (Norden, 2015) 
9 Examples are “Fruit and vegetable resource maps (WRAP, 2011a)”, “Reducing Food Waste through Retail 
Supply Chain Collaboration” (WRAP, 2011b), “Estimates of waste in the food and drink supply chain” (WRAP, 
2013), “Reducing food waste by extending product life (WRAP, 2015)” and “Household food and drink waste – 
A product focus” (WRAP, 2014b).  

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2.2  Date-marking practices in the EU food chain 

Date marking requirements are defined in EU law 

Variation in date marking across the EU can be attributed to differences within the EU 
in the interpretation and application of the terms of the FIC Regulation. The FIC 
Regulation requires:  

 

 

food labelling to bear a date mark, and that marked date to be identified as a 
date of minimum durability (i.e., a “best before” date) or a “use by” date10; 

foods “which, from a microbiological point of view, are highly perishable and 
therefore likely after a short period to constitute an immediate danger to 
human health” to be marked with a “use by” rather than a “best before” date11 
− although it does not identify these foods; 

  where appropriate, food labelling to include a description of storage 

conditions12. 

Foods that are not required to bear a “best before” date mark13 are identified in Annex 
X of the FIC Regulation. They are: 

 

fresh fruit and vegetables which have not been peeled, cut or similarly treated − 
including potatoes, excluding sprouting seeds and similar products such as 
legume sprouts; 

  wines of various kinds; 

  beverages containing 10% or more by volume of alcohol; 

  bakers’ or pastry cooks’ wares “which, given the nature of their content, are 

normally consumed within 24 hours of their manufacture”; 

  vinegar; 

  cooking salt; 

  solid sugar; 

  confectionary products consisting almost solely of flavoured and/or coloured 

sugars; 

  chewing gum and similar chewing products. 

Some EU countries, such as the Netherlands and Sweden, have proposed that Annex X 
be amended to include more food products. The proposed additions are products with 
a long shelf life, such as coffee, pasta and rice (Food Navigator, 2016). Any such 
changes would require agreement at EU level.  

There is some evidence that the requirements are not applied consistently by 
food business operators 

Research has found variation in how food and drink manufacturers and suppliers meet 
the legal requirements for date marking.  For example, one project14 examined the 
use of “best before” and “use by” in date labels by 64 food and drink companies in 

10 From Regulation (EU) no 1169/2011, Article 9(1)(f) 
11 From Regulation (EU) No 1169/2011, Article 24(1) 
12 From Regulation (EU) no 1169/2011, Article 9(1)(g) 
13 From Regulation (EU) No 1169/2011, Annex X, point 1(d) 
14 Norden (2015). 64 food and drink companies, representing 87 products, were surveyed. The researchers 
conducted surveys and in-depth interviews with the companies to identify how date labels used and shelf life 
are determined within the industry. 

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four Nordic countries as part of research into use of date labels and shelf life.  It found 
differences in use of date labelling and in the specified shelf life within the sample of 
products (Table 1). The authors concluded that there is a need for a better 
understanding and guidance on food labelling terms.  In the UK this challenge has 
been addressed by the Department for the Environment, Food & Rural Affairs and the 
Food Standards Agency producing guidance documents on how the FIC regulations 
should be implemented to help businesses comply with the law (Department for 
Environment, Food & Rural Affairs (Defra) and Food Standards Agency, 2016).  

Table 1.  Research with Nordic food and drink manufacturers found variation in date 

labelling practices and shelf life specification 

Product 

Key findings 

Fresh milk, pasteurised.  

  All products used the “best before” label 

  The same product from different manufacturers 
showed differences in shelf life, with some being 
labelled with a date twice as long as other 
products in the same category 

Cold smoked sliced salmon, 
vacuum packed.  

Cooked ham, MAP-packed15. 

Warm smoked ham, MAP-
packed. 

Ready-to-eat salad, containing 
heat-treated chicken. 

Ready-to-eat sandwich, 
containing chicken   

  Difference in the use of labelling across the four 
Nordic countries: “best before” labelling was 
used extensively by Swedish manufacturers for 
cold smoked salmon due to established practice 
& legislative guidance, as well as by Danish and 
Swedish manufacturers for cooked as well as 
warm smoked ham 

  The same product from different manufacturers 
showed differences in shelf life, with some being 
labelled with a date twice as long as other 
products in the same category 

Minced beef without water and 
salt, MAP-packed.  

  The same product from different manufacturers 
showed differences in shelf life, with some being 
labelled with a date three times as long as other 
products in the same category 

Source: Norden (2015) 

Managing date marks within a complex and varied retail environment is an 
ongoing challenge for the sector 

A large supermarket store may have 3,500 “use by” dated product lines, and around 
50,000 individual items with a “use by” date for sale at any one time16. Managing the 
stock to ensure the products on display have not exceeded their “use by” date is a 
significant logistical challenge. Many retailers are embracing new printing technologies 
to improve use of labelling and reduce food waste.  

Strategies for managing stock in relation to date labels need to accommodate the 
variation across the EU food retail sector in how some products are presented for sale. 
A product that is commonly presented ‘loose’ so that consumers can make their own 
selection in one country may be sold in packaged form in another country. Rules on 
date marks provided by the FIC Regulation can assist in the latter context but not in 
the former. 

15 Modified Atmosphere Packaging 
16 UK Local Better Regulation Office (“LBRO”), Business Reference Panel (2011). 

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The rapid growth of online shopping in many countries in Europe adds a new dynamic 
to date labelling and guidance. It is likely that online product information will become 
more important for consumers as online services grow. In the UK, for instance, online 
grocery sales reached £11.1 billion in 2017 (around 10% of total grocery sales (Defra, 
2017)) and are projected to grow at around 11% per annum to £16.7 billion over the 
next 5 years (Mintel, 2017).  

Very few of the food retailers that support online sales display information on their 
websites on “use by” or “best before” dates, or the product life remaining on arrival, 
for the products that are purchased online. Only one of the European retailers’ online 
shopping platforms reviewed for this report enabled the customer to request a 
minimum “best before” date and indicated product life, i.e. number of days next to the 
image of the product.   

2.3  Evidence on the links between consumer use of date marks and 

food waste 

A number of in-depth studies have examined consumer understanding and use of date 
labels and of guidance on food and drinks produce. Most have used a combination of 
interviews and surveys of consumers but do not provide any quantitative data on the 
amounts of food waste generated. Findings of some of the principal relevant studies 
are summarised in Table 2.  

Table 2.  Existing studies indicate imperfect consumer understanding of date marks 

on food products 

Key findings 

Source  

Many consumers need better knowledge of 
the difference between “best before” and “use 
by” 

Food waste and 
date labelling 
(Norden, 2016) 

Consumer understanding of date labels vary 
widely dependent on the research 

Some stock control labels e.g. ‘display until’ 
dates may be misinterpreted by consumers 

Consumer Insight: 
date labels and 
storage guidance 
(WRAP, 2011c) 

  Country 
studied 

  Norway, 
Sweden, 
Denmark and 
Finland 

  UK 

The reason most commonly given for 
discarding baked goods, sliced meat and 
yoghurt/sour cream was that it was "past its 
expiry date" 

Food waste in 
Norway 2014 
(Østfoldforskning, 
2014) 

  Norway 

58% of consumers consider “use by” and 
“best before” dates when shopping and 
preparing meals 

47% of consumers understand “best before” 
labelling 

40% understand “use by” date labelling 

30% does not know difference between use 
by and best before labels 

Consumers’ interpretation of the date mark 
varies according to food type 

  EU 

Flash 
Eurobarometer 
survey (Food 
Navigator, 2015) 

  Belgium 

Understanding and 
attitude regarding 
the shelf life labels 
and dates on pre-
packaged food 
products by Belgian 
consumers (Van 
Boxstael, S., 2013)  

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The most direct evidence of the role that date labels play in the discard of food and 
drink waste in the home is from the kitchen diary data collected by WRAP in the UK17. 
Reasons linked to date labels accounted for a third of the 2 million tonnes of 
household food that became waste because it was ‘not used in time’ (i.e. 0.66 million 
tonnes (Mt)). The main food groups that contributed to avoidable food waste where 
householders cited the ‘date label’ as a factor contributing to the disposal of the food 
are shown in Table 3. 

Table 3.  For certain food products, the date mark is frequently cited by consumers 

as a reason for avoidable food waste 

Food product 

Eggs 

Cakes and desserts 

Yoghurt 

Meat/fish 

Cooking sauce 

Fruit juice and smoothies 

Source: WRAP, 2014b. 

Percentage of avoidable food waste 
attributable to “date label” 

59% 

28% 

70% 

15%−31% 

59% 

18% 

Other reasons cited by consumers for disposing of food were that: 

 

 

they had served too much; 

they had cooked or prepared too much; 

  personal preference – they chose not to eat what had been prepared; 

  accidents; 

 

the product was “not used in time” – instances where the date label was not 
cited. 

In general, products that were ‘not used in time’ where the date label was not cited as 
a factor in them being thrown away were those: 

 

 

 

that had visual cues of deteriorating quality (vegetables/ fruit);  

that were of lower food safety concern (i.e. not subject to “use by” dates); or  

that are either sold loose or generally unpacked once in the home and therefore 
separated from the on-pack labelling information. 

Examples are apples, cucumbers, bananas, lettuce/ leafy salad and standard bread18.  

These findings provide a useful indication of the characteristics of food products for 
which date labels are most likely to be able to contribute to reduction of consumer 
food waste. 

Other studies have explored consumers’ understanding and use of storage and 
durability guidance. Norden (2016) provided specific examples of consumer guidance 
on storage and durability for different food products. These examples show some of 
the different terms used by manufacturers and retailers that can cause 
misunderstandings for consumers. The report concludes that consumers need clearer 

17 WRAP, 2014b. 
18 WRAP, table 15: Reasons for disposal for avoidable food and drink waste by food type, 2014b 

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and more easily accessible information on different labelling, storage temperature and 
durability of products. A similar finding and recommendation was made in the WRAP 
‘Consumer Insight: date labels and storage guidance’ report. 

2.4  Determinants of product life and its impact on food waste 

The literature suggests that the “use by” or “best before” date specified on a food 
product is influenced by various considerations. 

For some products, such as sliced ham, food safety is the limiting factor when setting 
product life. In other cases food manufacturers may specify a product life that includes 
a ‘buffer’ between the stated date on which the product should no longer be consumed 
and the actual date on which the product should no longer be consumed. Beyond the 
stated date, the product is still safe to eat but the quality is not optimal. This is a 
precautionary approach that is applied to product types where an obvious degradation 
in quality can cause consumers to dispose of items that are not yet unsafe to eat, such 
as yoghurt, cheese, juice, milk and salads19. 

Other reasons for manufacturers to specify a product life that is shorter than 
necessary include: 

  concern about the product being kept outside the recommended temperature in 

the home, during transport from store to home, or in the supply chain; 

 

limitations for brand reasons, i.e., setting the expiry date to be before any 
apparent degradation in quality.  

Cautious consumer behaviour due to a lack of understanding and guidance regarding 
the safety and the quality of a product can therefore lead to the disposal of products 
despite goods still being fit for consumption. 

Poor stock rotation of products with a shorter remaining shelf life can contribute to 
food waste in retail stores. If older products are hidden at the back of the shelf, with 
newer stock obscuring them, they are likely to be overlooked by the consumer.  This 
practice can also lead to a larger quantity of products being sold closer to their expiry 
date and therefore having to be marked down in price, or being over-looked by store 
staff and so being disposed of rather than sold at a reduced price. Products with a 
short shelf life may also end up as food waste as a consequence of consumers 
specifically seeking out products with a longer shelf life. 

Extending product life can reduce food waste 

WRAP’s study “Reducing food waste by extending product life” (2015) (WRAP, 2015) 
examines the impact of lengthening product life which may be brought about through 
product/packaging innovations, as well as setting appropriate expiry dates on products 
that may otherwise have unduly shortened shelf life. The study encompassed the 
impact of date marks across various supply chain stages and examined total life of a 
product, the open life, the available life and the Minimum Life on Receipt (MLOR) in 
relation to food waste20. The most relevant supply chain stages related to the delivery 
of product to the retailer regional distribution centre (RDC) from the supplier as well 
as at the retail store and the consumption of products in the home. 

Within the supply chain the length of remaining life on a product delivered to the 
retailer is a key factor driven by the stock control function of date marks. The 
management of remaining life is important to ensure that the retail and ultimately the 
consumer ends up with a significant share of total remaining product life.  However, 
the setting of unreasonable MLOR criteria may result in product returns and food 

19 “Reducing food waste by extending product life”, WRAP (2015). 
20 These terms are explained in the glossary at the front of this report. 

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waste. The use of MLOR might also mask failures in product ordering systems and 
allocation of consignments to their intended destinations or inefficiencies within 
delivery times between supplier and retailer.  

MLOR is set by the retailer for products received from suppliers at regional distribution 
centres (RDCs). It can be a cause of food waste further back in the supply chain, due 
to product returns. MLOR is set with reference to the date on the date mark. Factors 
which influence MLOR specification include the supply chain performance, logistical 
challenges on the supplier side, the order quantity, delivery frequency, and the 
negotiating power of the retailer. Bread is perceived as having the highest MLOR with 
the requirement for delivered product to have at least 86% of date life remaining on 
delivery. Suppliers producing bread may deliver it in smaller batches and more 
frequently to the depot (i.e. daily) on order to maintain high MLOR. Chicken breast 
and lasagne, in comparison, have lower MLORs.   

The main opportunities to extend product life and thereby reduce food waste are 
identified in a hotspot analysis summarised in Table A1.11 of Annex 1. This analysis 
sets date mark reforms within the wider context of a range of inter-related actions 
that contribute to food waste reduction: extension of the total product life, reform of 
the types of date marks used (for instance, elimination of “display until” or use of no 
dates). Some of these opportunities relate directly to the nature and duration of date 
marks applied, for example:  

  removal of ‘display until’ dates (retailer stock control labels that have been 

shown to confuse consumers); 

  variation in the application of “use by” and “best before” dates on certain 

products (e.g. yoghurt and juice) also has potential to cause waste by confusing 
consumers; 

  potential to extend the product life, through innovation and reform of date 

labels applied to existing total life (through a reduction in buffer); 

  extension of product life by reviewing the dates applied. 

WRAP has produced the guidance documents and tools for the food manufacturing and 
retail industry to help them challenge existing product life and ‘open’ life on 
products21. 

The WRAP 2015 study estimated the total benefits associated with product life 
extension through reduction in date expired product arising at manufacturing, retail 
and household stages. From WRAP’s programme of Waste Prevention Reviews, it was 
estimated that 5% of waste at the manufacturing stage was caused by date expired 
products. As producers are incentivised to move product through the supply chain to 
their customers as swiftly as possible, it is unlikely that much of the benefit of 
extended life would accrue to manufacturers and that retailers and consumers would 
benefit most.  

Any reform of date marks and the extension of product life will have benefits in food 
waste reduction within the supply chain but these are likely to be modest compared 
with the benefits at the consumer end, particularly with respect to food products 
where the public have been shown to be more attentive to date marks.   

21 Examples are: (a) A guide to help you and your business challenge existing product life and ‘open’ life 
(WRAP, 2016b). The guide is structured around 5 key stages; fact finding, opportunity identification, validation, 
implementation and review & embed. A worked example has also been produced (WRAP, 2016c) along with a 
template that is available on the WRAP website at http://www.wrap.org.uk/content/extending-product-life-
reduce-food-waste ; and (b) A guide to help you and your business increase ‘available’ product life for 
consumers (WRAP, 2016d). This guide is structured for food manufacturing and the retail industry and 
focuses on improved performance in the supply chain. 

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Table 4.  Estimates of retail waste prevented by adding one extra day to product life 

Amount 
purchased 
by 
households 
in 2011 
(tonnes) 

Mean 
date 
expired 
losses at 
retail (% 
sales) 

Estimated 
date 
expired 
losses at 
retail 
(tonnes) 

Reduction in 
date expired 
losses from 
extending 
available life 
by 1 day (% 
sales) 

Reduction in 
date expired 
losses from 
extending 
available life 
by 1 day 
(tonnes) 

1,600,000 

3.0 

48,000 

1.0 

16,000 

820,000 

4.3 

35,260 

0.9 

7,380 

428,000 

5.3 

22,684 

0.9 

3,852 

1,100,000 

0.4 

4,400 

0.01 

110 

Product 
type 

Standard 
bread 

Poultry 
(chicken) / 
turkey / 
duck 

Pre-
prepared 
meals 

Fruit juice 
and 
smoothies 

Milk 

5,100,000 

Potato 

1,600,000 

0.5 

1.3 

25,500 

20,800 

Lettuce and 
leafy salad 

170,000 

5.5 

9,350 

Sliced ham  236,000 

3.5 

8,260 

0.1 

0.3 

1.6 

0.3 

Yoghurt / 
yoghurt 
drink 

479,000 

1.4 

6,706 

0.1 

5,100 

4,800 

2,720 

708 

479 

Total 

11,533,000  1.5 

180,960 

0.3 

41,149 

Source: WRAP (2015) 

2.5  The products that contribute most to food waste in the EU 

2.5.1  Introduction 

This sub-section reports an attempt to use existing food waste datasets to identify the 
main food products that contribute to EU food waste at manufacture, retail, wholesale, 
food service and consumer/ household sectors22. This attempt uses the available food 
waste datasets for the EU-28 supplemented by data on food production, food 
availability and food consumption. These datasets were reviewed by an EU-funded 
research project called “FUSIONS” (short for “Food Use for Social Innovation by 
Optimising Waste Prevention Strategies”, a multi-stakeholder platform) and are 
described in Annex 1, which provides a more detailed report of the analysis. 

No primary data collection was involved in this desk-based review. As such, the 
outputs are constrained by the availability of data across the Member States, in a 
context where (i) the topic has had much more attention in some countries than in 

22 For the purposes of this review, losses associated with primary production were out of scope.  

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others, and (ii) data on food waste are not commonly collected as part of standard 
waste statistics. 

2.5.2  Food product profiles for EU food waste 

The FUSIONS project estimated that the EU-28 produce around 88 Mt of food waste 
per year23. Across the manufacturing, retail, food service and consumer/household 
sectors, fruit and vegetables account for the highest proportion of total food waste, 
followed by bakery products, meat (including fish and poultry) and dairy products.  

There are differences in this ranking by sector. Bakery products account for the 
highest proportion within retail food waste whereas at the consumer stage (food 
service or in home) fruit and vegetables represent a greater proportion of tonnage. 

The product category profile in manufacturing is different to that of other sectors. 
Significant quantities of food waste relate to rejected inputs to production, materials 
not intended for human consumption (inedible or unsuitable for production) as well as 
quality out-grades, depot returns and wastes associated with plant washing and 
cleaning. Fresh fruit and vegetables make a less significant contribution to food waste 
as more of the losses for these products occur ‘upstream’ of where produce is packed 
(i.e. on farm), rather than within the processing sector. 

Figure 1 and Figure 2 present findings on the quantities of total and avoidable food 
waste in the EU 28 across four sectors. Two food product categories, fresh fruit and 
vegetables and bakery, account for over half of the avoidable food waste, taking retail, 
food service and household together (Figure 3). 

Figure 1.  EU 28 total food waste by food product category, across 4 sectors (Mt/year) 

Source: ICF/Anthesis based on European Commission (FP7), Coordination and Support 
Action (2016a, 2016b); FAO (2011, 2011c); WRAP (2013f, 2016, 2016a) 

23 European Commission (FP7), Coordination and Support Action, FUSIONS, 2016a 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

Figure 2.  EU 28 avoidable food waste by food product category, across 4 sectors 

(Mt/year) 

Source: ICF/Anthesis based on European Commission (FP7), Coordination and Support 
Action (2016a, 2016b); FAO (2011, 2011c); WRAP (2013f, 2016, 2016a) 

Figure 3.  Avoidable food waste profile for combined retail, food service and household 

sectors (Mt / year) 

Source: ICF/Anthesis based on European Commission (FP7), Coordination and Support 
Action (2016a, 2016b); FAO (2011, 2011c); WRAP (2013f, 2016, 2016a) 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

The costs associated with food waste in the EU-28 were estimated by the FUSIONS 
project to be around €143 billion in 201224. This estimate included food waste from 
food production, which is not within the scope of the current project.  

The product category level data compiled for the four sectors by the current study 
permit a more detailed assessment of costs related to food waste. For the 
manufacturing stage, estimates have taken account two factors: the extent to which 
food waste was avoidable and the extent to which losses were ingredients, ‘work in 
progress’ or final product. These factors were derived for each product category, 
based on the WRAP 2016 study and the value of losses were estimated from sales of 
finished product reported within the PRODCOM datasets. For retail and food service 
sector, losses were assumed to be final product, with the lost sales value based on 
data collected by WRAP 2016a and WRAP 2013c.  The estimated value of food waste 
for manufacture, retail, food service and household sectors was in the order of €200 to 
€250 billion, significantly higher than the FUSIONS estimates which were based on a 
single Euro/ tonne value of food waste applied to the EU-28 food waste total.  Further 
research, outside the scope of this study, would be needed to refine these indicative 
estimates to take account of Member State differences in food costs and to establish 
for the manufacturing sector the extent to which food waste is in the form of final 
product, ingredient or waste generated during ‘work in progress’. 

2.6  The wasted food products most sensitive to date mark and 

labelling issues 

There is only a limited amount of research evidence directly linking food waste with 
the use of date marks. The most relevant evidence relates to consumer food waste, 
with one source providing estimates of the significance of date expired products in 
food waste at manufacture, retail and household stages (WRAP, 2015). For the 
purposes of this study those estimates have been adapted based on the more detailed 
statistics collected over the course of the study. An EU-28 extrapolation is provided in 
Table 5. Annual EU-28 food waste attributable to date marking issues was estimated 
at between 6.9 Mt/yr and 8.9 Mt/yr across the manufacturing/ processing, retail and 
household sectors, with the upper value approximating to around 10% of the total 
food waste estimated by the FUSIONS project (88 Mt/yr). 

Table 5.  Estimates for the maximum amount of waste arising attributable to date 

marking issues 

Sectors 

As % of sectoral food 
waste 

Total (Mt / year) 

Manufacture  
(MLOR linked to depot returns) 

Retail 
(Linked to “date expiry” in stores) 

Household 
(Consumers citing date labels in 
their discard decisions) 

Source: ICF, based on WRAP (2014b) 

5% 

55% 

<1 

2.5 

9.5% to 12% 

4.4 to 5.5 

Table 6 draws together the quantitative data based on the product category estimates 
of food waste with the consumer evidence linking food product wastage to date marks.

24 European Commission (FP7), Coordination and Support Action, FUSIONS, 2016a 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 6.  Summary of findings by product category 

Food 
product 
category 

Proportion of 
total food 
available for 
consumption 
(based on 
FAO, 2011)  

Proportion of 
avoidable food waste 
in EU retail, food 
service and 
household sectors by 
product category 
(based on Figure 3) 

Extent to which product packaged + 
date marked (WRAP, 2016a, unless 
otherwise specified) 

Sensitivity to date mark issue at consumer 
stage(WRAP, 2015) 

20.4% 

33% 

  Prepared fruit/ veg require ‘used by’ 

  Varies by product, but evidence suggests 

Fresh fruit 
and 
vegetables 

date; 

 

Loose product does not require a “best 
before” date as covered by exemption 

  95% of UK retail sector fresh fruit and 
vegetable food waste has a date label 

  May not be typical of EU28   

that consumers are less responsive to date 
marks in this product area than others and 
are more likely to take visual cues from 
appearance and product condition. Not 
clear why so much of this category has 
“best before” dates applied in the UK as not 
a legal requirement e.g. potatoes may have 
‘no dates’.  

 

Fresh/ instore bakery products not date 
marked: limited shelf life so high 
wastage rates if demand predictions 
wrong; 

  Standard packaged sliced loaves: lower 

wastage rate. 

  Packaged products may have ‘display until’ 
or “best before” dates; issue of whether or 
not home freezing advice included. 

Bakery 

14.7% 

21% 

Meat, fish, 
poultry 

10.5% 

10% 

  Sold over the counter: no date mark; 

pre-packaged fresh / chilled product 
with “use by” dates 

  Use by dates; consumers more sensitive to 
date labels on fresh/ processed meat, fish, 
poultry products. 

  Use of “best before” labels in some 

cases: by Swedish manufacturers for 
cold smoked salmon; by Danish and 
Swedish manufacturers for cooked and 
warm smoked ham (Norden, 2015) 

21.1% 

10% 

Dairy 
(incl. milk, 
cheese 
and eggs) 

  Over the counter hard cheeses are not 
date marked; majority of products are 
pre-packed; possible variances on 
freezing advice 

  Consumers are more attentive to date 

marks in relation to dairy products (discard 
decisions rely more on ‘date’ than visual 
cues); however, different types of date 

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Market study on date marking and other information provided on food labels and food waste prevention 

Food 
product 
category 

Proportion of 
total food 
available for 
consumption 
(based on 
FAO, 2011)  

Proportion of 
avoidable food waste 
in EU retail, food 
service and 
household sectors by 
product category 
(based on Figure 3) 

Extent to which product packaged + 
date marked (WRAP, 2016a, unless 
otherwise specified) 

Sensitivity to date mark issue at consumer 
stage(WRAP, 2015) 

15.4% 

8% 

  Mix of product types: some with longer 

 

shelf life (e.g. carbonated drinks) 

mark are applied, adding to confusion. Date 
mark / egg codes regime separately 
specified by regulations, including “best 
before” date. 

Fruit juice/ chilled fresh product may have 
a variety of different date marks. Consumer 
research shows sensitivity to date mark in 
consumer decision to dispose of 
unconsumed product. 

3.1% 

4% 

  Chilled product with “use by” dates; 

  Variations in home freezing advice in 

Soft 
drinks/ 
juices 

Pre-
prepared 
meals 

Ambient 
products 

6.8% 

4% 

  Packaged products carrying a “best 
before” date, with a long shelf life25 

frozen with “best before” 

Frozen 
products  

N/A 

N/A % 

 

Frozen products have “best before” 
dates: lower wastage rate than fresh/ 
chilled equivalents (however it is not 
possible to distinguish food 
temperature of storage in consumer 
food waste audits: therefore frozen 
product contribution to total food waste 
cannot be estimated separately) 

Source: ICF 

25 ‘shelf life’ = the date on the product regardless of the label, such as ‘use by’ or ‘best before’. 
26 As above. 

relation to date of purchase may be an 
issue with specific chilled products. 

  Expiry of “best before” date 26 may not 

represent an actual decline in product 
quality 

  Not much scope for different approaches to 

date marks with frozen produce 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

3  Market research  

3.1  Introduction 

Market research was conducted to obtain empirical evidence of the date marking 
practices for a set of selected product types in Member States chosen to represent the 
diversity of food retail markets of the European Union. The main purpose was to 
identify differences and similarities in date marking practices for products that look, 
from a consumer perspective, quite similar. Other relevant information such as the 
length of shelf life available for consumers at time of purchase (i.e., at time of 
survey), and whether foods with shorter shelf life were made available at discount, 
was also documented.   

The research was conducted using a ‘mystery shopping’ format in which pre-specified 
products were purchased from a target list of stores in eight Member States: Germany 
(DE), Greece (EL), Hungary (HU), the Netherlands (NL), Poland (PL), Slovakia (SK), 
Spain (ES) and Sweden (SE).   

3.2  Method 

The market research methodology is set out in full in Annex 3. Target product types 
and fieldwork methodology are summarised in the subsections below. 

3.2.1  Selection and specification of food product types 

Food product types were selected on the basis of the desk research described in 
Section 2. They were: 

  pre-prepared fruit/ vegetables; 
  pre-packed sliced bread; 
  chilled fish; 
  sliced ham; 
 
fresh milk; 
  yoghurts; 
  hard cheese; 
 
  pre-prepared chilled pasta; and  
  sauce (ketchup). 

fresh juice (chilled); 

The main factors in the selection of these product types are set out in detail in Table 
A3.1 of Annex 327. In brief, they are the:  

 

food category’s overall contribution to EU-28 avoidable food waste;  

  evidence of use of different types of date mark for the same product type;  

  extent to which consumers may take into account date marks when deciding 

whether or not to discard particular products;  

  relevant issues identified for the products relating to open life guidance, storage 

for optimal product life, and home freezing advice. 

27 The selection of product types also took into account the final selection of six products by the Horizons 2020 
REFRESH project for use in consumer-facing date label and consumer storage advice research in June 2017, 
namely: yoghurt, carrots, oranges, fresh meat, fresh (pasteurised) juice, and bread. However, the REFRESH 
selection of products reflects a different project remit, with the research focusing on visual testing of clarified or 
enhanced date mark and storage information across the selected products. 

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Frozen products were not retained because date labelling issues are generally of lesser 
significance for these products, as explained in Section 2.6 (Table 6). 

Detailed product specifications were defined for each of the 10 product types (Table 
7). These enabled valid comparisons in date-marking and information practices to be 
made between products (of the same type) across different brands, retailers, and 
Member States28. Despite being set tightly, the product specifications allowed 
fieldworkers (the “mystery shoppers”) to purchase substitute products if the target 
products were unavailable. 

3.2.2  Sampling strategy 

The main objective was to maximise the diversity of date marking and other 
information on food labels. To achieve this, it was necessary to maximise the diversity 
of items purchased within the 10 defined product types.  To maximise the diversity of 
items purchased, care was taken to prioritise larger retailer organisations (“retailers”) 
and larger store formats and to visit one store of each selected retailer only once. The 
strategy is described in detail in Section 3.2 of Annex 3.   

Retailers were selected on the basis that selecting them would: 

 

increase the likelihood of fieldworkers obtaining the target food products (or 
suitable substitutes) at store visits; 

  enable the widest possible selection of products to be obtained at each retail 

store visit; and 

  account for different shopper demographics and retailer market positioning. 

The sampling strategy was designed to: 

  balance discounters and conventional stores; 
 
 

take account of overall market shares; and, where possible, 
include a mix of endemic and multinational retailers.  

In total, the market research involved 34 visits to discounters and 75 visits to 
conventional retailers (supermarkets and hypermarkets). Table 8 indicates the number 
of visits to discounters and the number of visits to conventional retailers conducted in 
each Member State.

28 Use of less-detailed specifications might have led to products being purchased that are subject to different 
date-marking practices because of differences in product characteristics such as composition, preparation, 
size, or in-store storage conditions.)  

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Table 7.  Description and exclusion criteria for each of the food products to be purchased during the mystery shopping 

Product 
type 

Product 
description  

Pre-
prepared 
fruit/ 
vegetables 

Pre-packed 
green salad/ 
pre-cut lettuce 
leaves 

Item 
size 

90g – 
120g 

Storage  Examples of exclusions 

Acceptable substitutions 

Chilled  Whole lettuce heads. Organic lettuce. Baby 

lettuce. Lettuce hearts. Rocket, spinach, 
chard, watercress, radicchio, lambs’ lettuce. 
Salad with grated beetroot or carrot, 
tomatoes, or croutons.  

Mixed green leaf salad 
(mixture of lettuce and 
other leaf types).  Bag 
larger than 120g, e.g., 
150g. 

Pre-packed 
sliced bread 

White, medium 
sliced bread  

800g  

Ambient  Seeded, granary, brown, 50/50, “best of 

both”, unsliced, organic, “free-from”, “stay 
fresh”, or “toastie”. Non-wheat bread. 
Unsliced. Small packs of same composition. 
In-store bakery or loose.  

Chilled fish  Pre-packed 

smoked salmon 

100 – 
120g  

Chilled 

Deli counter, loose, pre-cooked, flavoured, 
coated, frozen, mixed pack, chopped. 

Thin-sliced or thick-sliced 
white. White, sliced “toast” 
bread is acceptable if 
standard white, sliced bread 
is not available.  

Pack larger than 120g, e.g., 
150g. Smoked mackerel (a 
2-piece pack)   

Sliced ham  Pre-packed 

125g 

Chilled 

sliced prosciutto 
/ serrano dry-
cured ham’ 

Fresh milk 

Semi-skimmed 
cows’ milk  

1 litre 

Chilled 

Honey roast, breaded, smoked or wafer thin 
ham. Ham from in-store delicatessen. 

Sliced pre-packed cured 
beef  

Skimmed, organic, lactose-free, UHT, long-
life, flavoured, ultra-filtered.  Goats’ or ewes’ 
milk.  Plant milk (e.g., almond, coconut or 
soya) 

Whole (i.e., full fat) cows’ 
milk 

Yoghurts  

Strawberry 
yoghurts in a 
multipack 

4 pack  

Chilled 

Organic, lactose-free, or low-fat yoghurts. 
Yoghurt drinks, Muller corners. Active/ live/ 
bio-yoghurts or single pots (unless no others 
available).  

4 pack of summer berries, 
red fruits, 2 strawberry & 2 
raspberry.  

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Market study on date marking and other information provided on food labels and food waste prevention 

Product 
type 

Product 
description  

Hard cheese  Sliced cheddar 

Item 
size 

240 – 
250g 

Storage  Examples of exclusions 

Acceptable substitutions 

Chilled 

Light/ reduced fat, extra-mature, medium, or 
smoked cheddar. Organic. Lactose-free. 
Grated, unsliced, loose, or in individual 
portions. Niche products. Cheese from in store 
delicatessen. Soft cheese. Goats’ or ewes’ 
milk cheese. 

Sliced emmental or gouda. 
(Ideally, the same strength 
sliced hard cheese should 
be purchased in all store 
visits.  If mild unavailable, 
medium is acceptable.) 

Fresh juice   Smooth fresh 
orange juice  

1000ml 

Chilled 

Freshly squeezed. Organic. Mixed fruit 
flavour. ‘Juice drink’. Multipacks or single 
portion bottles. 

Fresh orange juice with bits, 
smooth fresh apple juice 

Pre-
prepared 
chilled pasta 

Pasta with a 
vegetable filling 

400g  

Chilled 

Non-vegetable filling. Pasta stored at ambient 
temperature. Cannelloni & lasagne. Lunch 
pots.   

Pack larger than 400g. 
Fresh pasta with a 
mushroom filling. 

Sauce 
(ketchup) 

Tomato ketchup 
(‘squeezy’ 
bottle) 

460-580g  Ambient  Other table sauces, e.g., barbeque sauce, or 

relishes, e.g., salsa. Organic. Low sugar or 
salt. 

Tomato ketchup in glass 
bottle 

Source: ICF. 

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Market study on date marking and other information provided on food labels and food 
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Table 8.  Number of visits to discounters and conventional retailers conducted in each 

Member States by mystery shoppers 

Member State 

Supermarkets and hypermarkets 

Discounters 

Number of visits 

Number of visits 

Germany 

Greece 

Hungary 

Netherlands 

Poland 

Slovakia 

Spain 

Sweden 

TOTAL 

Source: ICF 

11 

9 

8 

8 

11 

10 

10 

8 

75 

7 

3 

4 

4 

5 

2 

5 

4 

34 

3.2.3  Data gathering and quality assurance checks 

Fieldworkers purchased single items of each brand (company brand or retailer’s own 
brand29) found during each store visit, working to the pre-defined product 
specification. After each store visit, they recorded, via an online questionnaire: 

  contextual data about the store (such as date and time of visit, store format, 

any promotions applied to the selected products) and  

 

information about each product (such as location of date labels of the 
packaging, the date, and the exact wording used).  

A full specification of the information recorded is provided in Section 3.2.4 of Annex 3. 
Table A3.6 of Annex 3 provides a fictional example of data gathered during a store 
visit for illustration. 

Fieldworkers provided photographs of each product. These showed the front of the 
pack, date label information, (including any supplementary advice), the ingredients list 
and barcode. In the case of food products that had both food contact packaging and 
outer packaging (such as cardboard sleeves), the photographs covered both packaging 
elements. The photos included any date marks appearing on the products as well as 
other relevant open-life instructions and on-pack storage advice, such as home 
freezing advice, “once opened, eat within x day” and home storage instructions. 

The study team reviewed each fieldworker’s data entries and corresponding 
photographs and then gave feedback on any errors. This feedback resulted in 
correction of errors or in amendment to products purchased in subsequent store visits.  

29 A “company brand” is a brand owned by a food manufacturer; a “retailer’s own brand” is owned by a food 
retailer 

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Market study on date marking and other information provided on food labels and food 
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3.3  Market research results and analysis 

3.3.1  Products sampled by product type and Member State 

Over the course of 109 store visits in eight Member States, 2,296 products within 
the scope of specifications set out in Table 7 were purchased. Table 9 gives a 
breakdown of these products by product category and Member State.  In total, 1,058 
brands were sampled. Table 10 gives a breakdown of these brands by product 
category and Member State.  

Of the items purchased, 71% were target products according to the specifications 
set out in Table 7, and 29% were acceptable substitute products. Table 11 gives 
a breakdown by product category.   

The high proportion of substitute cheeses (85%) is due to a widespread lack of 
availability of cheddar cheese (though there was a good availability of substitute pre-
sliced hard cheeses such as Edam, Gouda, Herregård and Emmental).  The high 
proportion of substitute yoghurts (75%) is due to a widespread lack of availability of 
the 4-pack format (strawberry flavoured yoghurts are commonly available in other 
packaging formats). 

The availability of four-pack strawberry yoghurts varied by country (Table A4.1 in 
Annex 4). The most common substitute product was the single-pot strawberry 
yoghurt. Other substitutions were strawberry yoghurts in other types of multi-pack (2-
pack, 3-pack or 6-pack) or yoghurts of other flavours (in single pots or various types 
of multi-pack). 

Semi-skimmed fresh milk was widely available, except in Germany and Greece. In 
Germany, full-fat milk or low-fat30 milk were bought as substitutes. In Greece, the 
only substitute purchased was low-fat milk (Table A4.2 in Annex 4). 

Bread purchases had to accommodate the differences in bread culture across the eight 
countries (Table A4.3 in Annex 4). In Greece, Hungary, Poland and (to a lesser extent) 
Sweden and Germany, the pre-packaged bread products mainly available were those 
specifically marketed for toast/sandwich making. 

30 Low fat milk in this case means with a fat content typically around 1.8%, i.e., lower than that of semi-
skimmed milk (2.5%) but greater than that of skimmed milk (0.1%). 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 9.  Products sampled by product type and Member State 

Product Type 

Member 
State 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-
packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
vegetables 

Sauce 

Sliced 
ham 

Yoghurt  ALL 

DE 

EL 

HU 

NL 

PL 

SK 

ES 

SE 

34 

18 

16 

16 

39 

15 

31 

18 

39 

59 

51 

19 

50 

27 

21 

20 

31 

55 

49 

26 

56 

21 

17 

22 

43 

28 

33 

28 

64 

32 

22 

31 

35 

53 

21 

11 

57 

20 

27 

24 

32 

4 

11 

10 

13 

8 

28 

22 

26 

18 

8 

12 

22 

13 

22 

15 

26 

22 

33 

29 

85 

33 

32 

26 

40 

45 

18 

17 

23 

33 

17 

11 

30 

44 

22 

38 

58 

23 

30 

18 

351 

292 

278 

179 

460 

229 

281 

226 

TOTAL 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2,296 

Source: ICF 

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Table 10.  Brands sampled by product type and Member State 

Product Type 

Member 
State 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
vegetables 

Sauce 

Sliced 
ham 

Yoghurts  ALL 

DE 

EL 

HU 

NL 

PL 

SK 

ES 

SE 

18 

15 

9 

9 

23 

11 

17 

11 

24 

24 

17 

12 

18 

15 

15 

9 

28 

26 

29 

15 

25 

13 

9 

11 

27 

12 

15 

18 

35 

18 

19 

20 

18 

15 

10 

11 

34 

14 

14 

7 

SUM 

113 

134 

156 

164 

123 

98 

110 

142 

142 

110 

TOTAL 
(excluding 
duplications) 

Source: ICF 

17 

4 

6 

8 

12 

6 

18 

11 

82 

59 

17 

9 

5 

12 

12 

11 

15 

9 

90 

84 

15 

15 

20 

12 

31 

16 

18 

10 

33 

14 

14 

16 

21 

16 

36 

22 

19 

6 

11 

3 

16 

16 

12 

3 

216 

140 

136 

116 

227 

136 

173 

113 

137 

172 

86 

1,257 

105 

144 

64 

1,058 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 11.  Numbers and proportions of target products and substitute products for each product type 

Product Type 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
vegetables 

Sauce 

Sliced 
ham 

Yoghurts  ALL 

184 

268 

207 

41 

157 

92 

114 

274 

238 

57 

1,632 

98% 

94% 

75% 

15% 

63% 

72% 

84% 

96% 

100%  25% 

71% 

3 

18 

70 

240 

91 

36 

22 

12 

0 

172 

664 

2% 

6% 

25% 

86% 

37% 

28% 

16% 

4% 

0% 

75% 

29% 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2,296 

Target 
product 
(no.) 

Target 
product (%) 

Substitute 
product 
(no.) 

 Substitute 
product (%) 

 All products 
(no.) 

Source: ICF 

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Market study on date marking and other information provided on food labels and food 
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3.3.2  Retailers’ own-brands and company brands 

Of the 1,058 brands sampled, 328 were “retailers’ own brands” and 730 were 
“company brands” – a ratio of 31%:69%. Table 12 shows this ratio in terms of 
numbers sampled and percentages for each of the 10 product types sampled. 

Yoghurt, chilled fish, and hard cheese each have a ratio of retailers’ own brands to 
company brands very similar to the average (31%:69%). The product type with the 
largest representation of retailers’ own brands was pre-prepared fruit/ vegetables 
(38%:62%), the product with the largest representation of company brands was sliced 
ham (24%:76%). 

Table 12.  Brand breakdown by product type: retailers own brands, company brands, 

total 

Product type 

Chilled fish (number and %)  

Fresh juice (number and %)  

Fresh milk (number and 
%)   

Hard cheese (number and 
%)  

Pre-packaged sliced bread 
(number and %)  

Pre-prepared chilled pasta 
(number and %)  

Pre-prepared fruit/ 
vegetables (number and %)  

Sauce (number and %)  

Sliced ham (number and %)  

Yoghurts (number and %)  

Total (number and %)  

Source: ICF 

Retailers’ own- 
brands 

Company 
brands 

29 

30% 

39 

35% 

37 

26% 

41 

29% 

40 

36% 

21 

36% 

32 

38% 

35 

33% 

34 

24% 

20 

31% 

328 

69 

70% 

71 

65% 

105 

74% 

101 

71% 

70 

64% 

38 

64% 

52 

62% 

70 

67% 

110 

76% 

44 

69% 

730 

31% 

69% 

Total 

98 

100% 

110 

100% 

142 

100% 

142 

100% 

110 

100% 

59 

100% 

84 

100% 

105 

100% 

144 

100% 

64 

100% 

1,058 

100% 

Of the products purchased, 24% displayed a retailer’s own brand and 76% displayed a 
company brand (see Table 13). The proportion of products purchased from 
discounters that were retailers’ own-brand products (38%) is almost twice as high as 
the proportion of products purchased from conventional grocery retailers that were 
retailers’ own-brand products (21%). 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

Table 13.  Breakdown of “retailers’ own brand” products and “company brand” product 

totals by retailer type 

 Retailer type 

“Retailers’ own brand” 
products sampled 

“Company brand” 
products sampled 

Conventional retailers 
(number and %) 

Discounters (number 
and %)  

Total (number and %) 

370 

21% 

191 

38% 

561 

24% 

Source: ICF 

1,420 

79% 

315 

62% 

1,735 

76% 

Total 

1,790 

100% 

506 

100% 

2,296 

100% 

For each of the 10 product types, Figure 4 shows the ratio of “retailers’ own brand” 
products to “company brand” products at conventional retailers and the ratio of 
“retailers’ own brand” products to “company brand” products at discounters.  These 
two ratios are most similar to each other for pre-prepared fruit/ vegetables and most 
different from each other for chilled fish.  

Figure 4.  Ratio of “retailers’ own brand” products and “company brand” for each of 

the 10 product types at conventional retailers and at discounters 

Source: ICF 

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Market study on date marking and other information provided on food labels and food 
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3.3.3  Findings on date marks and date wording 

The FIC Regulation31 requires that food labelling must32 display one of the following 
two types of date33: 

  a “best before” date: the date until which the labelled food retains its specific 

properties when properly stored, also known as the “date of minimum 
durability”34; or 

  a “use by” date: the deadline for consumption of the labelled food, after which 
it will be deemed unsafe for human consumption even when properly stored 
throughout the preceding period. 

Annex X of the FIC Regulation specifies the exact wording that should be used to 
identify the marked date as either a “best before” date or a “use by” date35. Table 14 
provides the “date wording” specified by the FIC Regulation in the languages of the 
Member States in which market research was undertaken. 

Annex X also defines the format for “best before” dates and “use by” date marks. Both 
kinds of date mark must consist of “the day, the month and, possibly, the year in that 
order and in uncoded form.” However, the FIC Regulation provides flexibility in how a 
“best before” date is indicated depending on the length of the product's shelf life36.   

31 Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the 
provision of food information to consumers. Available here. (Last accessed 19 December 2017.) 
32 Annex X, point 1(d) of the FIC Regulation provides a list of foods that are not required to bear a Best Before 
date. This list does not include any product types purchased during the market research phase of this study. 
33 FIC Regulation, Article 9(1)(f): 
“1. [In accordance with Articles 10 to 35 and subject to the exceptions contained in this Chapter,] indication of 
the following particulars shall be mandatory: … 
… (f) the date of minimum durability or the ‘use by’ date” 
34 Regulation (EU) No 1169/2011, Article 2(2)(f): “’date of minimum durability of a food’ means the date until 
which the food retains its specific properties when properly stored” 
35 Annex X, point 1(a) for the “best before” date: 
“1.The date of minimum durability shall be indicated as follows: 
(a) 
- 
- 
Annex X, point 2(a) for the “use by” date: 
“2.The ‘use by’ date shall be indicated as follows: 
(a) 
36 Annex X, point 1(c) for the “best before” date: 
“1.The date of minimum durability shall be indicated as follows:… 
(c) 

the date shall be preceded by the words: 
‘Best before…’ when the date includes an indication of the day, 
‘Best before end…’ in other cases,” 

the date shall consist of the day, the month and, possibly, the year, in that order and in uncoded 
form. 

the date shall be preceded by the words ‘use by’;” 

However, in the case of foods: 
- 
- 

which will not keep for more than 3 months, an indication of the day and the month shall be sufficient, 
which will not keep for more than 3 months but not more than 18 months, an indication of the month 
and the year shall be sufficient, 
which will keep for more than 18 months, an indication of the year shall be sufficient” 

- 
Annex X, point 2(a) for the “use by” date: 
“2.The ‘use by’ date shall be indicated as follows:… 
(c) 

the date shall consist of the day, the month and, possibly, the year, in that order and in uncoded 
form.” 

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Market study on date marking and other information provided on food labels and food 
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With regard to the presence, wording and format of date marks, the research found 
that (Table 15): 

  There was a high level of compliance with the terms of the FIC Regulation: 

-  The great majority of products sampled (2,196, 95.6% of total) displayed a 
“best before” or “use by” date mark with wording that is in line with the 
relevant requirement of the FIC Regulation; 

-  All date marks displayed were in one of the appropriate formats (e.g., day 

and month, or month and year). 

  A small minority of products showed some form of non-compliance: 

-  100 individual products (4.4% of products sampled) did not display date 

wording that is in line with the relevant requirement of the FIC Regulation. 
Of these: 

◦  43 products (1.9%) displayed no date wording (though a date was 

provided, see commentary in the following section); 

◦  39 products (1.7%) displayed date wording whose meaning could not be 
determined with certainty (although in some cases, it appeared similar to 
“best before” or “use by” wording in the relevant language); 

◦  15 products (0.7%) displayed forms of date wording that identified the 
date marks as neither “best before” nor “use by” (for example, packing 
dates, delivery dates, “display until” dates, “sell by” dates, and – for a 
chilled fish product – a date of catch); 

◦  2 products (0.1%) display date wording only in a language other than 
that of the Member State in which the products were purchased; and 
◦  1 product (<0.1%) displays both a “best before” date mark and a “use 

by” date mark. 

  Non-compliances were concentrated in a small number of product types: 

-  25 pre-prepared fruit /vegetable products (18.4% of total) did not display 

date mark and wording consistent with the provisions of the FIC Regulation. 
For 14 cases, the date mark was absent; for the remaining 11 cases, the 
date wording was absent or not consistent with the provisions of the FIC 
Regulation; 

-  19 pre-packed sliced-bread products (7.7% of total) did not display date 

wording consistent with the provisions of the FIC Regulation. The two main 
reasons for this were: (i) the display of date wording whose meaning could 
not be determined with certainty; and (ii) to the date wording indicating a 
“sell by” date or date of packing. 

-  10 chilled fish products (5.3% of total) did not display date wording 

consistent with the provisions of the FIC Regulation. In most cases, this was 
because the meaning of the date wording could not be determined with 
certainty. 

-  For all other product types, the incidence of products purchased failing to 
display date wording consistent with the FIC Regulation was less than the 
average incidence across all product types (i.e. less than 4.4%). 

  For some product types the packaging usually displayed “best before” dates 
while for other product types the packaging usually displayed “use by” date 
marks (Table 16): 

- 

“best before” date marks predominated for: sauce (98.6% of products 
sampled); pre-packed sliced bread (86.3%); fresh juice (85.3%); hard 

January , 2018 

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Market study on date marking and other information provided on food labels and food 
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cheese (81.9%); sliced ham (73.1%); and pre-prepared chilled pasta 
(53.9%).  

- 

“use by” date marks predominated for: chilled fish (75.4% of products 
sampled); pre-prepared fruit/ vegetables (70.6%); fresh milk (68.1%); and 
yoghurts (64.3%). 

Table 16 shows, for each product type, the Member States in which a “best before” 
date mark was more popular and those in which a “use by” date mark was more 
popular. Figure 5 shows the variation in usage of “best before” and “use by” date 
marks by product type and Member State in graphic form. 

Table 17 provides examples found of date wording that could not be determined with 
certainty to be either “best before” or “use by”. Table A5.1 of Annex 5 shows 
examples of the precise date wording found on products, some of which is consistent 
with the FIC Regulation, and some which is not.   

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 14.  Date wording specified by Regulation (EU) No 1169/2011, Annex X, points 1(a) and 2(a) 

Member 
State 

Minimum durability (“best before”) date wording… 

“use by” date wording 

…when the date mark 
indicates the day, i.e., “best 
before” 

…when the date mark includes only the 
month & year, i.e., “best before end…” 

Germany 

Mindestens haltbar bis… 

Mindestens haltbar bis Ende... 

Zu verbrauchen bis… 

Greece 

Ανάλωση κατά προτίμηση πριν 
από... 

Ανάλωση κατά προτίμηση πριν από το 
τέλος… 

Ανάλωση έως… 

Hungary 

Minőségét megőrzi… 

Minőségét megőrzi … végéig 

Fogyasztható… 

Nether-
lands 

Ten minste houdbaar tot... 

“Ten minste houdbaar tot einde...” 

Te gebruiken tot... 

Poland 

Najlepiej spożyć przed… 

Najlepiej spożyć przed końcem… 

Należy spożyć do… 

Slovakia 

Minimálna trvanlivosť do… 

Minimálna trvanlivosť do konca… 

Spotrebujte do… 

Spain 

Consumir preferentemente antes 
del… 

Consumir preferentemente antes del fin 
de… 

Fecha de caducidad… 

Sweden 

Bäst-före… 

Bäst före utgången av… 

Sista förbrukningsdag… 

Source: Regulation (EU) No 1169/2011. 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 15.  Number of purchased products by date type for all product types 

Date Type  

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Product type 

Pre-
packed 
sliced 
bread 
214 

Pre-
prepared 
chilled 
pasta 
69 

Pre-
prepared 
fruit/ 
veg. 
15 

Sauce 

Sliced 
ham 

Yoghurt  ALL 

282 

174 

73 

1,427 

36 

244 

90 

230 

19.3%  85.3%  32.5%  81.9%  86.3%  53.9% 

11.0% 

98.6%  73.1%  31.9%  62.2% 

141 

32 

178 

39 

15 

54 

96 

0 

58 

156 

769 

75.4%  11.2%  64.3%  13.9% 

6.0% 

42.2% 

70.6% 

0.0% 

24.4%  68.1%  33.5% 

177 

276 

268 

269 

229 

123 

111 

282 

232 

229 

2,196  

94.7%  96.5%  96.8%  95.7% 

92.3%  96.1% 

81.6% 

98.6%  97.5% 

100.0%  95.6% 

0 
0 

0 

0 

0 

0 

0 

2 

0 

8 

0 
0 

0 

0 

0 

0 

0 

7 

0 

2 

0 
0 

0 

0 

0 

0 

0 

9 

0 

3 

7 
2 

0 

0 

0 

0 

0 

9 

0 

1 

0 
0 

0 

0 

0 

0 

1 

1 

0 

3 

0 
3 

1 

0 

1 

0 

0 

0 

14 

6 

0 
0 

0 

0 

0 

0 

0 

0 

0 

4 

0 
0 

0 

0 

0 

0 

1 

4 

0 

1 

0 
0 

0 

0 

0 

0 

0 

0 

0 

0 

7 
5 

1 

1 

1 

1 

2 

39 

14 

29 

Best Before (no. and as 
% of all products) 

Use By (no. and as % of 
all products) 

Sub-total in line with FIC 
Regulation provisions 
(no., % of all products) 
Sell by date/ date of sale  0 
Date of packing 
0 

0 

1 

0 

1 

0 

7 

0 

1 

Delivery date 

Use By & Best Before 

Display until 

Date of capture (fish) 

Wording in wrong 
language for country 
Uncertain date type 

No date displayed 

Date displayed but no 
wording displayed 
Sub-total not in line with 
FIC provisions (no, %) 

Total products 

10 
5.3%  3.5% 

10 

9 
3.2% 

187 

286 

277 

12 
4.3% 

281 

19 
7.7% 

248 

5 
3.9% 

128 

25 
18.4% 

136 

4 
1.4% 

286 

6 
2.5% 

238 

0 
0.0% 

229 

100 
4.4% 

2,296 

Source: ICF.  Note: Emboldened numbers relate to points highlighted in the accompanying text. 

January , 2018 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 16.  Number of purchased products that display a “best before” date mark or a “use by” date mark for all product types  

Date type  

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Product type 

Pre-packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ veg. 

Sauce 

Sliced 
ham 

Yoghurt  ALL 

“best before” 
(no. and as %*) 

36 

244 

90 

230 

214 

69 

15 

282 

174 

73 

1,427 

“use by”  
(no. and as %*) 

20.3%  88.4%  33.6%  85.5%  93.4% 

56.1% 

13.5% 

100.0% 

75.0
% 

31.9%  65.0% 

141 

32 

178 

39 

15 

54 

96 

0 

58 

156 

769 

79.7%  11.6%  66.4%  14.5%  6.6% 

43.9% 

86.5% 

0.0% 

25.0%  68.1%  35.0% 

Sum 

177 

276 

268 

269 

229 

123 

111 

282 

232 

229 

2,196  

Countries where 
“best before” is 
predominantly 
applied to 
product type 

Countries where 
“use by” is  
predominantly 
applied to 
product type 

EL, SE 

All 

DE, NL, 
SE 

DE, EL, 
NL, PL, 
ES, SE 

DE, HU,PL, 
SK,ES,SE 

DE,NL,SE, 
EL 

SE 

All 

DE,EL, 
NL, 
ES, SE 

DE, SE 

DE, HU, 
PL, SK, 
ES 

None 

EL, 
HU,PL, 
SK,ES 

HU 

None 

ES, SK, 
HU, PL 

DE, EL, 
HU, 
PL,SK,ES 

None 

HU, 
PL, SK 

EL, HU, 
NL, PL, 
SK, ES 

* As a percentage of products purchased that have a date mark that is in line with the FIC Regulation provisions, whether Best Before or Use By 

Source: ICF 

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Market study on date marking and other information provided on food labels and food waste prevention 

Figure 5.  Variation in usage of “best before” and “use by” date marks between product types and Member States 

Source: ICF 

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 17.  Examples of date wording found that could not clearly be determined as either “best before” or “use by” 

Member State  Date wording in local 

English translation 

language 

Product types on which this date 
wording was found 

Slovakia 

Vychutnávajte si ma do 

Enjoy me in 

Poland 

Przydatności do spożycia  

[This is a term which is sometimes 
used as ‘suitable for consumption 
until’ as well as “best before”] 

Fresh juice 

Sliced ham 

Greece 

Spain 

Source: ICF 

Ημερομηνία λήξης  

Caducidad 

Expiry date 

Expiration 

Chilled fish, hard cheese, sliced ham 

Sliced ham 

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Market study on date marking and other information provided on food labels and food 
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3.3.4  Location of date wording in relation to date mark 

Annex X of the FIC Regulation allows the date wording to be placed alongside the date 
mark or to be apart from it, provided that the date wording is accompanied by a 
reference to where the date is given on the product labelling37.  

The analysis of the location of the date wording and indication of the location of the 
date mark on the purchased products determined that: 

 

the location of date mark in relation to the date wording varied by packaging 
format. The data suggest that: 

-  product types that are generally sold in relatively flat packaging, such as 

sealed trays, tend to display the date mark and date wording alongside each 
other (pre-prepared chilled pasta is an exception to this). 

-  product types sold in other types of packaging (such as pots, bottles, and 
cartons) tend to display the date mark and date wording apart from each 
other. 

 

this pattern reflects physical constraints: locating the date wording alongside 
the date mark is more difficult to achieve with certain packaging formats than 
with others 

  date marks and date wording generally appeared alongside each other on 

packaging for: 

-  hard cheese (85.4% of products sampled); 

-  chilled fish (78.1%); 

-  pre-prepared fruit/ vegetables (70.6%); and 

-  sliced ham (68.9%). 

  date marks and date wording generally appeared in different locations of the 

packaging for: 

-  yoghurts (72.1% of products sampled); 

-  sauce (69.9%); 

-  pre-packed sliced bread (66.5%); 

- 

fresh milk (66.1%); 

-  pre-prepared chilled pasta (59.4%); and 

- 

fresh juice (54.2%). 

37 FIC Regulation, Annex X, point 1(b) for “best before”: 
“1.The date of minimum durability shall be indicated as follows:… 
the words in point (a) shall be accompanied by: 
(a) 
‘either the date itself, or, 
- 
a reference to where the date is given on the labelling 
- 
FIC Regulation, Annex X, point 2(b) for “use by”: 
“2.The ‘use by’ date shall be indicated as follows:… 
(b) 
- 
- 

the words in point (a) shall be accompanied by: 
‘either the date itself, or, 
a reference to where the date is given on the labelling 

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The review also found that: 

  bottles, whether plastic or glass, generally displayed date marks on the bottle 
tops on the filling line and date wording on the label on the side of the bottle. 

  cartons were more likely than bottles to show the date mark and date wording 
adjacent to each other.  The majority of cartons of fresh juice displayed date 
mark and date wording together, whereas the majority of cartons of fresh milk 
displayed date mark and date wording apart from each other. 

  most single pot yoghurts displayed date mark and date wording apart from 
each other (with the date mark being printed onto the metallised plastic 
covering lids and the date wording appearing on the label on the side of the 
pot). By contrast, a majority of the 4-pack yoghurts displayed date mark and 
date wording together, generally on the film lid of each pot. 

Data describing the position of the date type and date wording relative to each other 
in the products that were purchased are provided in: 

  Table 18 for all product types; 

  Table 19 for yoghurt; 

  Table 20 for each packaging format of fresh juice; 

  Table 21 for each packaging format of fresh milk. 

Annex 6 provides photographic examples of the most common arrangements of date 
mark and date wording for each product type in each typical form of packaging.

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Market study on date marking and other information provided on food labels and food waste prevention 

Table 18.  Count of number of purchased products against relative position of date mark and date wording for all product types 

Relative 
position of date 
mark and date 
wording 

Date and 
wording together 
(number and %) 

In different 
locations 
(number and %) 

Adjacent, but 
wording mixed 
with other text 
(number and %) 

No wording 
(number and %) 

Product type 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-
packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
vegetables 

Sauce  Sliced 

Yoghurt  ALL 

ham 

146 

123 

90 

240 

82 

48 

96 

80 

164 

64 

1133 

78.1%  43.0%  32.5%  85.4%  33.1% 

37.5% 

70.6% 

28.0%  68.9%  27.9% 

49.3% 

32 

155 

183 

38 

165 

76 

20 

200 

71 

165 

1105 

17.1%  54.2%  66.1%  13.5%  66.5% 

59.4% 

14.7% 

69.9%  29.8%  72.1% 

48.1% 

8 

0 

2 

0 

0 

1 

0 

2 

2 

0 

15 

4.3% 

0.0% 

0.7% 

0.0% 

0.0% 

0.8% 

0.0% 

0.7% 

0.8% 

0.0% 

0.7% 

1 

8 

2 

3 

1 

3 

20 

4 

1 

0 

43 

0.5% 

2.8% 

0.7% 

1.1% 

0.4% 

2.3% 

14.7% 

1.4% 

0.4% 

0.4% 

1.9% 

Total products 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2296 

Source: ICF 

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Table 19.  Relative location of date mark and date wording for yoghurts 

Number of yoghurt 
pots in product 

Date and 
wording together 

In different 
locations 

Single pot  

2-pack  

3-pack  

4-pack  

6-pack  

 Total  

Source: ICF 

4 

3.0% 

2 

33.3% 

14 

100.0% 

41 

55.4% 

3 

100.0% 

64 

27.9% 

128 

97.0% 

4 

66.7% 

0 

0% 

33 

44.6% 

0 

0% 

165 

Total 

132 

57.6% 

6 

2.6% 

14 

6.1% 

74 

32.3% 

3 

1.3% 

229 

72.1% 

100.0% 

Table 20.  Relative location of date mark and date wording for fruit juice 

Packaging 
format 

Date and 
wording 
together 

Carton 

119 

55.6% 

Plastic bottle 

4 

5.6% 

Glass bottle 

0 

0.0% 

123 

43.0% 

 Total  

Source: ICF 

In different 
locations 

No wording 

Total 

87 

40.7% 

67 

94.4% 

1 

100.0% 

155 

54.4% 

8 

3.7% 

0 

0.0% 

0 

0.0% 

8 

2.4% 

214 

74.8% 

71 

24.8% 

1 

0.3% 

286 

100.0% 

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Table 21.  Relative location of the date mark and date wording for milk 

 Packaging 
format 

Date and 
wording 
together 

In different 
locations 

Adjacent, but 
wording mixed 
with other text 

Total 

Carton 

66 

87 

43.1% 

56.9% 

Plastic bottle 

22 

87 

19.8% 

78.4% 

Glass bottle 

0 

4 

0.0% 

100.0% 

Plastic bag 

4 

44.4% 

 Total 

92 

33.2% 

Source: ICF 

5 

55.6% 

183 

66.1% 

0 

0.0% 

2 

1.8% 

0 

0.0% 

0 

0.0% 

2 

0.7% 

153 

55.2% 

111 

40.1% 

4 

1.4% 

9 

3.2% 

277 

100.0% 

3.3.5  Legibility of date mark and date wording 

The research design was constructed to provide evidence on the sampled products’ 
compliance with Article 13 of the FIC Regulation. Article 13 requires that mandatory 
food information (which includes the date mark and date wording) must be presented 
visibly, legibly and, where appropriate, indelibly on the food packaging38. 

Although the majority of products were judged to be compliant with Article 13, 
fieldworkers reported problems with legibility of date mark and/or wording on 247 
products sampled (10.8% of total). The incidence of such legibility problems ranged 
from less than 5% for fresh milk products up to 20.8% of the pre-prepared chilled 
pasta sampled. 

The most common legibility problems reported were that the date mark and/or date 
wording were printed too small (affecting 6.6% of products sampled) and that the 
date mark was printed unclearly or with fading ink (affecting 2.2% of products 
sampled). 

Excessively small print was the main legibility issue for 9 out of the 10 product types 
(pre-prepared fruit / vegetables being the exception). A typical example of problem 
reported was, “Datestamp on lid is small and the opposite way up to the wording 
relating to it” (a comment registered in relation to a sauce product purchased in 
Germany). 

38 FIC Regulation, Article 13 states that: 
“1. Without prejudice to the national measures adopted under Article 44(2), mandatory food information shall 
be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, 
indelible.  It shall not be in any hidden, obscured, detracted from or interrupted by any other written or pictorial 
matter or any intervening material. 
2. Without prejudice to specific Union provisions applicable to particular foods, when appearing on the 
package or on the label attached thereto, the mandatory particulars listed in Article 9(1) shall be printed on the 
package or on the label in such a way as to ensure clear legibility, in characters using a font size where the x-
height, as defined in Annex IV, is equal to or greater than 1.2 mm. 
3. In case of packaging or containers the largest surface of which has an area of less than 80 cm2 the x-height 
of the font size referred to in paragraph 2 shall be equal to or greater than 0.9 mm.” 

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Unclear printing and/or fading ink was the main legibility problem for pre-prepared 
fruit/ vegetables.  Fading ink was a particular problem for date marks printed onto 
plastic bottles and bottle tops (and hence sauce and fresh milk).  A typical example of 
problem reported was: “Information was clearly displayed but the ink is very sensitive 
and if you touch it many times fades out” (a comment relating to a pre-packaged loaf 
of sliced bread purchased in Greece). 

Table 22 shows the incidence of legibility problems reported for all ten product types. 

3.3.6  Products’ remaining life 

A product’s ‘remaining life’ is the period between the date of purchase and the date 
shown by the date mark, whether “best before” or “use by”. The remaining life of each 
product purchased was calculated from the date mark displayed on the packaging and 
the date of purchase reported by the fieldworker. Figures A7.1 to A7.10 in Annex 7 
show the results of these calculations for each product type.  

There was wide variation in the remaining life of the products sampled within each 
product type. The widest variations were observed for fresh juice and sauce. For fresh 
juice, this variation is likely to reflect differences in product specification (the on-pack 
labels do not provide sufficient information to relate this to the processing 
technologies applied). For sauce, it may to be due to poor stock rotation or an 
inconsistent approach to setting shelf life.  Some of the fresh milk products had a 
longer remaining life due to higher levels of pasteurisation/ micro-filtration applied to 
some of the sampled products (see Table A7.1 in Annex 7). 

Within all 10 product types, no significant variation was found between the average 
remaining life of products that displayed a “best before” date mark and the average 
remaining life of products that displayed a “use by” date mark (in terms of number of 
days). 

January , 2018 

50 

 
 
Market study on date marking and other information provided on food labels and food waste prevention 

Table 22.  Legibility problems were reported by mystery shoppers for all product types 

Legibility problem 
identified (no. products 
affected, and as % of all 
in-scope products) 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

too small 

10 

9 

4 

19 

Product type 

Pre-packed 
sliced 
bread 
24 

Pre-
prepared 
chilled pasta 
16 

Pre-
prepared 
fruit/ veg. 
1 

Sauce 

Sliced 
ham 

Yoghurt  ALL 

26 

24 

19 

152 

5.3%  3.1%  1.4%  6.8% 

9.7% 

12.5% 

0.7% 

9.1% 

10.1%  8.3% 

6.6% 

date mark difficult to find   1 

3 

1 

3 

1 

5 

1 

4 

3 

2 

24 

date mark ink faded/ 
printing not clear 

wrong language/ 
incorrect translation 

date mark does not give 
year 

date and wording on 
different sections of pack 

not clear wording that 
relates to date mark 

stickers on pack 
obscuring info 

0.5%  1.0%  0.4%  1.1% 

0.4% 

3.9% 

0.7% 

1.4% 

1.3% 

0.9% 

1.0% 

3 

3 

4 

5 

3 

2 

3 

13 

6 

3 

45 

1.6%  1.0%  1.4%  1.8% 

1.2% 

1.6% 

2.2% 

4.5% 

2.5% 

1.3% 

2.0% 

0 

0 

0 

0 

0 

0 

2 

0 

2 

1 

5 

0.0%  0.0%  0.0%  0.0% 

0.0% 

0.0% 

1.5% 

0.0% 

0.8% 

0.4% 

0.2% 

0 

0 

0 

0 

4 

0 

0 

0 

0 

1 

5 

0.0%  0.0%  0.0%  0.0% 

1.6% 

0.0% 

0.0% 

0.0% 

0.0% 

0.4% 

0.2% 

1 

1 

0 

1 

0 

3 

1 

1 

0 

1 

9 

0.5%  0.3%  0.0%  0.4% 

0.0% 

2.3% 

0.7% 

0.3% 

0.0% 

0.4% 

0.4% 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0 

1 

0.0%  0.0%  0.0%  0.0% 

0.0% 

0.0% 

0.0% 

0.3% 

0.0% 

0.0% 

0.0% 

1 

0 

0 

1 

1 

0 

0 

0 

0 

1 

4 

0.5%  0.0%  0.0%  0.4% 

0.4% 

0.0% 

0.0% 

0.0% 

0.0% 

0.4% 

0.2% 

other stated problem 

0 

0 

0 

0 

0 

0.0%  0.0%  0.0%  0.0% 

0.0% 

16 

16 

9 

29 

33 

0 

0.0% 

26 

0 

0 

2 

0 

2 

0.0% 

0.0% 

0.8% 

0.0% 

0.1% 

8 

45 

37 

28 

247 

8.6%  5.6%  3.2%  10.3%  13.3% 

20.3% 

5.9% 

15.7%  15.5%  12.2%  10.8% 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2,296 

All products with a 
legibility problem 

Total products 

Source: ICF 

January , 2018 

51 

 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

3.4  Open-life and on-pack storage advice 

Article 9(1)(f)39 and Annex X40 of the FIC Regulation require the display of any special 
storage conditions applying to the product and of any advice on the life of the product 
once the packaging has been opened be displayed (“open-life” advice).  In addition, 
Article 25 of the FIC Regulation requires special storage conditions and/or conditions 
of use to be indicated, as well as the storage conditions and time limit for consumption 
of the product once the product has been opened41. 

The data collected from the purchased products enable the compliance of the overall 
sample with these aspects of the FIC Regulation to be assessed. 

For fresh juice and pre-prepared chilled pasta, a majority of the products sampled 
provided open-life advice (91.9% and 97.6% respectively).  For the other product 
types, only a minority (from 7% to 48%) of the products sampled provided open-life 
advice.  Where products did provide open-life advice it was either in the form of: 

  Information on the number of days within which the product should be 

consumed once opened (this was present for the majority of the fresh juice and 
pre-prepared chilled pasta products that were sampled); or 

  An instruction to consume immediately after opening (for all product types this 

was present on a minority of the products that were sampled). 

The overall situation for storage advice was more complex than that for open-life 
advice. The research analysis found that storage advice provided on the food 
packaging generally included advice relating to storage temperature – either a 
maximum temperature or a temperature range.  There was some variation by product 
type: 

  Chilled products (such as chilled fish, dairy products, sliced ham, pre-prepared 

chilled pasta, and pre-prepared salad) were more likely to carry specific 
temperature advice than ambient products (such as sauce and bread). The 
exception was chilled juice (Table 25); 

  For sauce and bread, on-pack information sometimes included temperature and 

storage advice for the unopened pack that was different to that given for 
reference once it has been opened. 

39 FIC Regulation, Article 9(1)(f): 
“1. [In accordance with Articles 10 to 35 and subject to the exceptions contained in this Chapter,] indication of 
the following particulars shall be mandatory: … 
… (g) any special storage conditions [and/or conditions of use] 
40 FIC Regulation, Annex X, point 1(b): 
“…If need be, these particulars [date wording] shall be followed by a description of the storage conditions 
which must be observed if the product is to keep for the specified period;” 
FIC Regulation, Annex X, point 2(b): 
“…Those particulars [date wording] shall be followed by a description of the storage conditions which must be 
observed;” 
41 FIC Regulation, Article 25: 
“1. In cases where foods require special storage conditions and/or conditions of use, those conditions shall be 
indicated 
 2. To enable appropriate storage or use of the food after opening the package, the storage conditions and/or 
time limit for consumption shall be indicated where appropriate” 

January , 2018 

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Market study on date marking and other information provided on food labels and food 
waste prevention 

There was also some variation by country: 

  In Germany and the Netherlands, products displayed storage temperature 

advice alongside the date wording, regardless of whether the date type was 
“best before” or “use by”; 

  In Sweden, products displayed advice on storage temperature alongside the 

date wording if the date type was “use by” but apart if it was “best before” (so 
in the latter case, the advice on storage temperature was not linked as 
obviously to the date mark); 

  In Greece, Hungary, Poland, Slovakia and Spain, products displayed storage-

temperature advice apart from the date wording; 

  The text on yoghurts that provided advice on storage temperature generally 

displayed: 

-  a maximum storage temperature in Germany, the Netherlands and Sweden,  

-  a temperature range in Greece, Hungary, Poland, Slovakia and Spain. 

  In Germany, the wording that was provided on storage temperature was the 

same across all the yoghurts sampled. 

Table 23 shows the average open life by product type. 

Table 24 gives a breakdown by product type of open-life information. Figures A8.1 to 
A8.4 in Annex 8 show variations in open life for product types whose open life varied 
across the eight Member States. These product types are fresh juice, fresh milk, hard 
cheese, and sauce. 

Table 25 gives a breakdown by product type of on-pack storage advice related to 
temperature. Results for each product are provided in Annex 9. There is significant 
variation in maximum and minimum temperatures advised on products indicating 
storage temperature ranges (Figure A9.1 to Figure A9.8 in Annex 9). 

Table 23.  Average open life by product type 

Product type 

Chilled fish 

Fresh juice 

Fresh milk 

Hard cheese 

Pre-packed sliced bread 

Pre-prepared chilled pasta 

Pre-prepared fruit/ vegetables 

Sauce 

Sliced ham 

Yoghurts 

Source: ICF 

Mean 

2.13 

3.09 

2.65 

2.32 

1.98 

2.57 

1.12 

33.15 

3.14 

1.00 

N 

75 

261 

137 

40 

47 

88 

19 

47 

55 

2 

Standard 
deviation 

0.96 

1.14 

1.58 

1.20 

0.95 

0.77 

0.33 

20.99 

1.81 

0.00 

January , 2018 

53 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food waste prevention 

Table 24.  Open-life information displayed on purchased products for all product types 

Product type 

Open-life 
information 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-
packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
veg. 

Sauce  Sliced 

Yoghurt  ALL 

ham 

No open life 
(number and %) 

Number of days 
of open life 
stated (number 
and %) 

Eat immediately 
(number and %) 

104 

23 

143 

231 

199 

39 

102 

236 

172 

212 

1,461 

55.6%  8.0% 

51.6%  82.2%  80.2% 

30.5% 

75.0% 

82.5%  72.3%  92.6% 

63.6% 

75 

260 

115 

40 

47 

88 

19 

47 

55 

2 

748 

40.1%  90.9%  41.5%  14.2%  19.0% 

68.8% 

14.0% 

16.4%  23.1% 

0.9% 

32.6% 

8 

3 

19 

10 

2 

1 

15 

3 

11 

15 

87 

4.3% 

1.0% 

6.9% 

3.6% 

0.8% 

0.8% 

11.0% 

1.0% 

4.6% 

6.6% 

3.8% 

Total products 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2,296 

Source: ICF 

January , 2018 

54 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food waste prevention 

Table 25.  On-pack storage relating to temperature of purchased products for all product types 

Product type 

On-pack storage 
relating to 
temperature 

Chilled 
fish 

Fresh 
juice 

Fresh 
milk 

Hard 
cheese 

Pre-
packed 
sliced 
bread 

Pre-
prepared 
chilled 
pasta 

Pre-
prepared 
fruit/ 
veg. 

Sauce  Sliced 

Yoghurt  ALL 

ham 

Products showing 
no storage advice/ 
specific temp 
(number and %) 

Products showing 
specific 
temperature or 
temperature range 
(number and %) 

Products showing 
advice on storage, 
no temperature 
stated (number 
and %) 

5 

3 

1 

4 

85 

5 

15 

14 

11 

2 

145 

2.7% 

1.0% 

0.4% 

1.4% 

34.3% 

3.9% 

11.0% 

4.9% 

4.6% 

0.9% 

6.3% 

166 

40 

248 

246 

0 

104 

99 

24 

187 

220 

1,334 

88.8%  14.0% 

89.5%  87.5%  0.0% 

81.3% 

72.8% 

8.4% 

78.6%  96.1% 

58.1% 

16 

243 

28 

31 

163 

19 

22 

248 

40 

7 

817 

8.6% 

85.0%  10.1% 

11.0% 

65.7% 

14.8% 

16.2% 

86.7%  16.8%  3.1% 

35.6% 

Total products 

187 

286 

277 

281 

248 

128 

136 

286 

238 

229 

2,296 

Source: ICF 

January , 2018 

55 

 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

3.5  Summary and conclusions  

The market research yielded a large number and wide distribution of product samples 
as well as a high level of detail on the labelling of the sampled products. Overall, a 
good level of consistency was achieved in the purchasing. Where there was variance 
from the precise product specification (e.g. single pot yoghurts vs. four-pack 
yoghurts) it was within acceptable bounds and has added interest to the findings.   

Among the points of interest arising are the: 

  differences among Member States in the predominant approach to date 

labelling and storage advice for the same product type, and even for the same 
product; 

  differences by type of product in the predominant approach to date labelling; 

  relatively few instances of date wording that did not meet the requirements of 

the FIC Regulation; 

  relatively high frequency of problems with the legibility of the date mark. 

Table 26 provides an overall summary of the results for each food product.  These 
results informed the interviews of food industry stakeholders (food business operators, 
national competent authorities, and various organisations that represent food sector or 
other stakeholder interests at EU level) in the final phase of the study. 

January , 2018 

56 

 
 
 
 
 
 
Table 26.  Overview of results for each product type purchased during the mystery shopping in terms of key parameters 

Market study on date marking and other information provided on food labels and food waste prevention 

Product description 

Consistency of date 
mark type applied* 

(exceptions) 

Food temp. 

(unopened 
pack) 

Main 
packaging 
formats 

Vacuum packed 
plastic, with or 
without 
cardboard 
sleeve 

Storage temp. advice  Remaining life 

Once opened advice 

[mean value across all 
products purchased that 
indicate expiry date] 

[mean value across all products 
purchased that indicate number 
of days open life] 

Location / legibility of date 
mark and associated 
wording 

Chilled product: more 
likely to have storage 
temperature range 

[15 days] 

(DE 6 days) 

 56% products no open life 
stated 

 78% date & wording appear 
together 

[2.1 days (n=75)] 

13% unclear 

DE, NL mainly use max. 
storage temperature 
linked to date mark 

SE, ES higher open life (max 7 
days) 

Home freezing advice on 8 
products: 4 ‘do not freeze’ 

BB = 36 (19.3%) 

Chilled 

UB = 141 (75.4%) 

Other = 10 (5.3%), 
including one instance 
of BB AND UB 

(Mainly BB: EL, SE) 

(Mainly UB: DE, HU, PL, 
SK, ES) 

(Split: NL) 

BB = 244 (85.3%) 

UB = 32 (11.2%) 

Other = 10 (3.5%) 

(BB predominates in all 
8 MS) 

Chilled Fish: Pre-packed 
smoked salmon 

N=187 

Fresh Juice: smooth 
fresh orange juice  

N=287 

Fresh Milk: semi-
skimmed cows’ milk  

N=276 

Hard Cheese: sliced 
cheddar or other hard 
cheese 

N=281 

Pre-packed sliced 
Bread: white, medium-
sliced 

N=248 

BB=230 (81.9%) 

Chilled 

UB=39 (13.9%) 

Other = 12 (4.3%) 

(Mainly BB: DE, EL, HU, 
PL, SK, ES) 

(Mainly UB: HU) 

(Split: SK) 

BB = 214 (86.3%) 

Ambient 

UB = 15 (6.0%) 

Other = 19 (7.7%) 

(Mainly BB: DE, EL, HU, 
PL, SK, ES, SE) 

(NL has “sell by” only) 

Ambient or 
Chilled 

Cardboard 
carton with 
plastic cap, 
plastic bottle 

Specific storage 
temperature advice less 
likely 

[182 days] 

 90% state open life 

NL, ES, SE purchased 
products had significantly 
shorter remaining life 

[3.1 (n=261)] 

ES, SE  

BB=89 (32.5%) 

Chilled 

UB=178 (64.3%) 

Other = 9 (3.2%) 

(Mainly BB: DE, NL, SE) 

(Mainly UB: EL, HU, SK, 
ES, PL) 

Plastic bottle 
with plastic cap 
or cardboard 
carton with 
plastic cap  

(PL glass milk 
bottle) 

Chilled product: more 
likely to have storage 
temperature range 

DE max. storage 
temperature linked to 
date mark; NL link not so 
direct 

[9 days] 

 51% no open life stated 

consistent across all 
countries 

‘consume immediately’ (n=21) 

[2.7 days (n=137)] 

No correlation found between 
level of pasteurisation and open 
life  

Vacuum 
packed, may be 
re-sealable 

Chilled product: more 
likely to have storage 
temperature range 

[64 days] 

 82% no open life stated 

(EL 100 days) 

‘eat immediately’ (n=10) 

DE max. storage 
temperature linked to 
date mark 

[2.3 days (n=40)] 

Plastic bottles: 95 % date and 
wording different locations  

Cartons: 56% date & wording 
appear together 

23% of plastic juice bottles 
unclear/ difficult to read; 

Only 8% of cartons 

Plastic bottles: 78 % date and 
wording different locations  

Cartons: 43% date & wording 
appear together 

25% of plastic milk bottles 
unclear / difficult to read; 

only 3% of cartons were 
criticised 

 85% date & wording appear 
together 

15% wording/ date unclear 
difficult to read 

Plastic bag with 
clip tie 

Contradictory storage 
advice across different 
MS, e.g.: EL most 
frequent advice to store 
in fridge; PL advice to 
store at room temp. 

[11 days] 

 80% products state no open life 

(EL =18 days, NL=0 
days) 

[2.0 days (n=47)] 

Advice on home freezing 
provided on 7 products 

 67% date & wording different 
locations: date on clip tie 

32% unclear 

January , 2018 

57 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food waste prevention 

Product description 

Consistency of date 
mark type applied* 

(exceptions) 

Food temp. 

(unopened 
pack) 

Main 
packaging 
formats 

Storage temp. advice  Remaining life 

Once opened advice 

[mean value across all 
products purchased that 
indicate expiry date] 

[mean value across all products 
purchased that indicate number 
of days open life] 

Location / legibility of date 
mark and associated 
wording 

Pre-prepared chilled 
pasta with a vegetable 
filling 

N=128 

BB = 69 (53.9%) 

Chilled 

UB = 54 (42.2%) 

Other = 5 (3.9%) 

(Mainly BB: DE, EL, NL, 
SE) 

(Mainly UB: HU, PL, SK, 
ES) 

Vacuum packed 
in plastic 

Chilled product: more 
likely to have storage 
temperature range 

DE max. storage temp. 
linked to date mark 

[31 days] 

 69% state open life 

59% in different locations 

[2.6 days (n=88)] 

No correlation between 
remaining life and period to 
consume once opened  

36% wording/ date unclear 
difficult to read {most 
comments about difficulty of 
finding/ text too small] 

Pre-prepared fruit/ 
vegetables: pre-packed 
green salad/ pre-cut 
lettuce leaves 

BB = 15 (11.0%) 

Chilled 

UB =96 (70.6%) 

Other= 25 (18.4%) 

N=136 

(Mainly BB: SE) 

Plastic bag, 
plastic box with 
plastic bag 
wrapper 

Chilled product: more 
likely to have storage 
temperature range 

NL max. storage 
temperature 

 [3.8 days] 

 75% products state no open life 

no difference in 
remaining life between 
products with UB or BB 
dates 

1.1 days (n=19) 

71% date & wording  appear 
together 

15% no wording 

18% unclear 

Sauce: tomato ketchup 
in squeezy bottle 

N=286 

Sliced ham: pre-packed 
sliced prosciutto / 
serrano dry-cured ham’ 

N=238 

Strawberry Yoghurts in 
a multipack 

N=229 

(Mainly UB: the 7 other 
MS) 

BB = 282 (98.6%) 

Ambient 

UB = None 

Other = 4 (1.4%) 

(BB predominates in all 
8 MS) 

BB = 174 (73.1%) 

Chilled 

UB = 58 (24.4%) 

Other = 6 (2.5%) 

(Mainly BB: DE/, EL, 
NL, ES, SE) 

(Mainly UB: HU, PL, SK) 

BB = 73 (31.9%) 

Chilled 

UB = 156 (68.1%) 

Other = None 

(Mainly BB: DE, SE) 

(Mainly UB: EL, HU, NL, 
PL, SK, ES) 

Plastic bottle 
with plastic cap 
and nozzle 

Ambient product: 
temperature advice  

[321 days], (PL 270) 

 83% no open life stated 

70% in different locations 

No correlation between 
remaining life and period 
to consume once opened  

[33.2 days (n=47)] 

EL, HU, SK more likely to state 
open life, SK mean 60 

38% wording/ date unclear 
difficult to read (dates rub off 
tops) 

Vacuum packed 
in plastic 

Chilled product: more 
likely to have storage 
temperature range 

[71 days], (ES 125 days) 

 72% no open life stated 

Correlation between 
products with longer life 
& period to consume 
‘once opened’  

‘eat immediately’ (n=11) 

[3.1 days (n=55)] 

69% date & wording appear 
together 

28% unclear 

Plastic pots, 
with cardboard 
sleeve 

Chilled product: more 
likely to have storage 
temperature range 

[18 days] 

 93% no open life stated 

(EL 28 days) 

‘eat immediately’ (n=15) 

Multi-pack: 62% date & 
wording appear together 

Single pot: 97% date & 
wording in different locations 

30% unclear, but related to 
single pots 

* BB means “best before” date mark; UB means “use by” date mark; “Other” means a date mark that is neither definitely a “best before” date mark nor definitely a “use by” date mark 

Source: ICF 

January , 2018 

58 

 
 
 
 
 
Market study on date marking and other information provided on food labels and food 
waste prevention 

4 

Stakeholder consultations on date marking practice 

Interviews were undertaken with 74 food sector stakeholders to discuss findings from 
the desk research and market research phases of the study. 

4.1  Research design and method 

Stakeholders from the three following groups were interviewed: 

  National Competent Authorities (NCAs), specifically: 

-  NCAs of the Member States in which the market research was undertaken 

(i.e. Germany, Greece, Hungary, Netherlands, Poland, Slovakia, Spain, and 
Sweden); and  

-  NCAs from European countries42 that are members of the EU Platform on 

Food Losses and Food Waste or of the Working Group on Food Information 
to Consumers. 

  European organisations, specifically:  

- 

trade associations representing food manufacturing, retail and service 
sectors;  

-  consumer organisations; and 

-  organisations representing operators of food banks.  

-  Priority was given to those who are members of the EU Platform on Food 
Losses and Food Waste or are otherwise active in food waste prevention.  

  Food business operators (FBOs), giving priority to: 

-  producers of the food products that were purchased in the market research; 

- 

- 

retailers from whom those target food products were purchased; and 

food banks and other charity organisations involved in the recovery and 
redistribution of foods. 

  Most of the FBO representatives were employed in the quality assurance 
department of their respective firms.  Others worked in corporate social 
responsibility, public affairs or marketing functions. 

Positive responses were received from NCAs from 19 countries, 16 European 
organisations, and 39 FBOs.  In-depth interviews were conducted with these 
stakeholders using a “semi-structured” format to allow focused, conversational, two-
way communication between respondent and interviewer.  

Semi-structured interviewing starts with more general questions or topics and allows 
the interview to evolve and address issues and topics that may not have been 
foreseen in the original topic guide. This approach enables an open discussion with 
each stakeholder that covers a broad set of issues (such as the way food practices in 
the food chain are impacting on food waste).  This means that the interview is not 
limited to coverage of date marks, associated advice and information provided to 
consumers on the pack, and how that information and advice may be leading 
behaviours.   

The interview topic guides for NCAs, European organisations, and FBOs are presented 
in Annexes 10, 11 and 12 respectively.  Interviewers were also given a list of issues 
identified in the analysis of the market research data for use as discussion points.   

42 This includes one country that is not an EU Member State – Norway.  

January , 2018 

59 

 
 
                                           
Market study on date marking and other information provided on food labels and food 
waste prevention 

The qualitative data obtained from the interviews were coded for analysis. A synthesis 
of the results was then prepared.  Findings from the interviews have been grouped 
under to the following topic headings: 

  Stakeholders’ understanding of the terms “use by” and “best before”; 

  Factors in producers’ choice of date mark type; 

  Factors that determine location, format and legibility of the date mark; 

  Factors in the determination of product shelf life; 

  Storage advice and open life advice; 

  Use of date marking in managing the food supply chain; 

  Enforcement of date marking rules; 

  Barriers to and facilitators of better utilisation of date marking in relation to 

food waste prevention; 

  Stakeholders’ views on Annex X of the FIC Regulation 

The rest of this section considers the evidence obtained on each of these topics 
through the interviews, also taking into account (where relevant) evidence from the 
previous market research and desk research. 

4.2 

 Stakeholders’ understanding of “use by” and “best before” 

In general, awareness of the FIC Regulation’s requirements in relation to date marking 
of foods was high. The FIC Regulation seems to be well regarded; no interviewees 
raised major concerns about it. 

NCAs and most of the European organisations clearly understood the definitions of 
“use by” and “best before” date marks in their respective national languages.  Many 
interviewees from both NCAs and European organisations did not have a strong 
understanding of the practices that producers use to choose one date mark type over 
another or to set a particular date. Even so, European trade associations did 
understand that variation in their members’ practices would lead to differences in the 
date marks placed on products. One stated that: 

“The use of durability dates also depends on producers’ choice and retailer 
conditions in each Member State or region, and of course consumer habits in each 
country – for the same product you will have different ways of placing the date 
across the EU.” 

Trade association 

The market research carried out for this study supports the associations’ view that 
there are variations in the usage of “best before” and “use by” date marks within the 
same product groups across different Member States, as discussed in Section 3.3.3  
and summarised in Figure 5. (Reasons given for choosing one type of date mark over 
the other are discussed in Section 4.3). 

The majority of FBOs gave clear answers that demonstrated an accurate 
understanding of the difference between “use by” and “best before” (in their 
respective languages) in line with the FIC Regulation. In a minority of instances, some 
producers understood “use by” and “best before” to be more or less the same, and 
others viewed the difference to be on the basis of overall shelf life (with shorter shelf 
lives necessitating a “use by” date mark, and longer shelf lives necessitating a “best 
before” date mark). Nonetheless, there is wide variation in producers’ views of what 
foods pose a higher risk to food safety and should therefore be subject to a “use by” 
date mark - even among the producers who demonstrated an accurate understanding 
of the difference between “use by” and “best before”.  

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Producers have the responsibility for displaying a date mark (and associated date 
wording) on the packaging of their products. Most of the producers interviewed stated 
that they act in line with the FIC Regulation, although one stated that it does not put a 
date mark on bagged salad and that it considers “use by” and “best before” to be 
different ways of saying the same thing. 

4.3 

 Factors in producers’ choice of date mark type 

Producers’ perceptions of product characteristics and food safety 

The most common determinants of producers’ choice of date mark are their 
perceptions of product characteristics and food safety, which is consistent with the FIC 
Regulation. In particular, producers cited either the presence/ absence of food safety 
risks or microbiological concerns. For some products, the absence or presence of food 
safety processes during production (such as heat treatment for pasta or pasteurisation 
for juice) were given as the deciding factor for choosing between “use by” and “best 
before”.  

Producers often linked their food safety concerns to the overall shelf life of their 
product. Producers of products with longer shelf lives (e.g., cheese, ketchup) tended 
to cite [long] overall longevity (sometimes described as “microbiological stability”) as 
their reason for applying a “best before” date mark. Producers of products with shorter 
shelf lives (e.g., fish, milk) had a greater tendency to cite food safety concerns as a 
reason to choose to apply a “use by” date mark.  

Decision on basis of shelf life or storage conditions 

A few producers explained their choice without reference to food safety or product 
characteristics, which is not consistent with the FIC Regulation. For example, one 
producer stated that the type of date mark that it applied to a product was based 
simply on the storage conditions that it had specified for that product.  Hence, a “use 
by” date mark was applied to chilled products, and a “best before” date mark was 
applied to ambient products.  

In another example, some dairy producers reported that they base their choice of date 
mark for a given product directly on the length of shelf life, without reference to food 
safety concerns or product characteristics. They apply a “use by” date mark to 
products with a shelf life shorter than two or three months (depending on the 
producer) and a “best before” date mark to products with a shelf life longer than 
that43. 

Factors beyond the producer’s product knowledge 

Although the decision of whether to apply a “use by” date mark or a “best before” date 
mark is a matter for the producer, the producer can be influenced by factors beyond 
its product knowledge. As a result, that producer may decide to apply a “use by” date 
mark to a product for which a “best before” date mark may be more appropriate. 
Figure 6 summarises the factors stated by FBO interviewees that may cause producers 
to choose “use by” date marks instead of “best before” date marks. 

Two particular factors were discussed extensively in interviews with FBOs, namely 
common practices in national markets (often referred to by interviewees as “local 
market norms”) and consumers’ understanding of “use by” and “best before”. 

43 By contrast, the market research undertaken for this study suggests that a producer’s choice of date mark 
for a product does not depend on that product’s remaining life (Sections 3.3.6 and 5.4) 

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Figure 6.  Factors favouring the application of “use by” date marks over 

 “best before” date marks 

"use by" seen to be more 
consistent with brand 
values/positioning 
(‘freshness’) 

The term "use by" should only be 
applied on foods which, from a 
microbiological point of view, are 
highly perishable and are therefore 
likely, after a short period, to 
constitute an immediate danger to 
human health 

Customer complaints (e.g. on 
quality changes, e.g. yogurt 
‘separating’) 

Judgement based on 
perishability alone (vs 
safety risk) 

"use by" date 
mark applied 

Desire for consistent date 
type within or across range 
(vs some with "use by", 
some with "best before") 

Absence of good data on 
safety risk (i.e. ‘better to be 
safe’) 

Retail customer 
requests a "use by" 
date mark 

Trade body or 
other guidance 
advises a "use 
by" date mark 

Source: ICF 

Common practices in national markets 

The choice of date mark (“best before” or “use by”) is partly driven by what FBOs 
(especially retailers) think consumers in a given market will prefer or expect to see 
due to common practices within that market. Retailers reportedly exercise more 
influence over the choice of date marks applied to retailers’ own-brand products than 
to company-branded products. 

For instance, a ham producer stated that, although it applies a “best before” date 
mark on its products for its domestic market, retailers in certain export markets 
request a “use by” date mark. A similar situation was mentioned by a dairy producer. 
The firm stated that, although it applies a “best before” date mark to all products for 
sale in its home market, it applies a “use by” date mark to products for sale in 
European export markets where “use by” was the standard type of marking in that 
jurisdiction. 

Although fresh fruit and vegetables which have not been peeled, cut or similarly 
treated are exempt from date marking, some producers reported that they sometimes 
apply a date mark to their packaging because of common practices within a national 
market or because of retailer influence.  

Consumer understanding of “use by” and “best before” 

Interviewees reported few cases of consumer behaviour directly leading to changes in 
date marking practices. Focus group testing was mentioned by one FBO. Another 
referred to consumer testing that occurred alongside product development. (This sort 
of testing would not specifically focus on a particular aspect of date marking, but 
would contribute to the FBO’s overall knowledge of how consumers use its products.)  

Most of what FBOs had to say about consumer behaviour was anecdotal and rooted in 
the interviewees’ personal experience. Only one FBO mentioned conducting specific 
consumer research on how “use by” and “best before” are understood, concluding that 
consumers were not aware of the differences in labelling. FBOs generally perceive 
consumer understanding of “use by” and “best before” to be poor. This has led some 

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producers to “err on the side of caution” by applying a “use by” date mark. One dairy 
producer described the situation as such:  

 "Marking products with “use by” is not great for food waste because consumers get 
scared and throw away products, but “use by” ensures [i.e., provides a sense of 
security to] the industry, as you can never be sure how consumers store and use the 
products." 

Dairy producer 

Some FBOs believe that consumers are more likely to treat the date mark as an 
indicator of food safety rather than of quality, regardless of the type of date mark 
applied.  

There were some instances of FBOs learning about consumer behaviour through 
customer complaints. A few stated that complaints had led them to add the caveat “if 
unopened" to the wording accompanying a “best before” date mark. 

NCAs were, for the most part, not seen by FBOs (or by themselves) as having a 
significant influence on the choice of date mark. However, the role of the NCA in 
enforcing date wording stipulated by regulation was mentioned.  For example:  

  one producer indicated that it was aware that date labelling was the subject of 
enforcement, and that this was why it uses the stipulated “best before” date 
wording on its products, despite not necessarily agreeing that that wording 
provides clarity for consumers; 

  one retailer had focus group results that suggested an alternative “best before” 
wording performed better for a particular product. It attempted to change the 
wording to the non-standard text but was instructed by its NCA to revert to the 
official wording as the alternative was not compliant with the FIC Regulation; 

  one producer mentioned that when exporting to a new market it would first 

send an image of its proposed label, with all relevant wording, to the local NCA 
for approval; and 

  one producer described how the NCA in an export market had wielded a more 
direct influence on their choice.  When exporting a yoghurt that had been 
assigned a “use by” date mark, the producer received an official letter from the 
NCA requiring that they switch the date mark to “best before”. The producer 
complied with the request but was surprised and felt that “best before” did not 
appropriately safeguard consumers in the case of yoghurts.  

Many FBOs raised the issue of “use by” and “best before” date wordings, and whether 
they were understood as intended by consumers. Many interviewees thought the date 
wording specified by the FIC Regulation makes sense and is helpful. Others stated that 
their own comprehension of the terms was informed by their technical background. 
There were no indications of specific problems with any one national wording. 
However, one FBO in Germany indicated that, while the English “best before” in 
English would exclude the marked date from the period of minimum durability, the 
German equivalent “mindestens haltbar bis” would include the marked date in the 
period of minimum durability. This could present challenges for FBOs when deciding 
what date to use, especially for FBOs who export and those who use multilingual 
packaging.  

Stakeholders were divided on whether there would be merit in changing the wording 
accompanying a “best before” date mark to communicate more effectively that it is an 
indicator of product quality. Some believed that a different form of words would be 
clearer, such as "best quality before" or "best before, but still consumable after". Many 
thought that such wording would be clear but insufficiently concise. Others believed 
that it would be best not to change date wordings because consumers are only now 
becoming accustomed to them, and the priority should be to increase awareness and 

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understanding of the date wording currently in use. Several thought changes would 
not matter because consumers do not read the wording.  

Producers generally viewed the formulation of date wording as being outside their 
control and responsibility. 

4.4 

 Factors that determine location, format and legibility of the date 
mark 

According to the producers that were interviewed, the location of the date mark (and 
date wording) depends on common practices in national markets as well as on a 
concern to display the date mark in an obvious location.  No producer raised the issue 
that displaying the date mark separately from the date wording might impede 
consumer understanding. When asked if it might be, producers stated that displaying 
date mark and date wording apart from each other was standard for certain products 
(for example, the date being displayed on a fastening clip for sliced bread products, 
and the date wording on the plastic packaging) and something that consumers were 
accustomed to.  

As the market research showed (Section 3.3.4), certain product types are more likely 
to display date mark and wording alongside each other and other product types are 
more likely to show them apart. Clearly, displaying date mark and date wording 
alongside each other makes them easier to understand.  However this is difficult to 
achieve on certain packaging formats, especially those that are not flat, because – as 
producers explained – date marks are generally printed at a separate stage from the 
other information on the packaging, and the way in which they are printed on the 
packaging depends on the equipment used.   

The printing equipment and methods can affect legibility. No interviewees mentioned 
any specific problems with making dates legible.  However, the market research 
revealed problems with legibility of date mark and/or wording on 11% products 
sampled, making it the most widespread problem encountered (Section 3.3.5). 

Producers did not give any insights into how the choice of date mark format (e.g., 
day/month/year, or month/year) is made. All products sampled during the market 
research displayed date marks in a format in line with the provisions of the FIC 
Regulation.   

4.5 

 Factors in setting product shelf life 

Producers’ practices in setting product shelf life vary widely and are generally 
consistent with the factors explored by the WRAP study of 2015 (WRAP, 2015) as 
discussed in Section 2.4. 

Product testing results 

Producers tend to set shelf life during product development. Shelf life is established 
through tests or determined on the basis of producers’ knowledge of similar products 
in the same category. Some producers mentioned specific methods or standard 
procedures for food safety testing set by standardisation bodies such as AFNOR 
(Association Française de Normalisation), BRC (British Retail Consortium) and IFS 
(International Featured Standards). Most producer descriptions of testing, however, 
indicated that decisions were made either internally or in partnership with testing 
laboratories. There was little mention of external guidance on how to conduct shelf life 
tests.  

For products given a “use by” date mark, producers mentioned measuring Listeria 
growth and predictive microbiological modelling. If microbiological risk is found not to 
be a factor, tests are conducted to determine a “best before” date.  

Testing for determination of a “best before” date involves both qualitative and 
quantitative aspects. Producers mentioned inspecting organoleptic properties at 

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various stages in the product's lifespan and using consumer acceptance testing. 
Consumer acceptance testing includes considering changes in product condition that 
would be unwelcome to customers – e.g., changes in appearance, taste or smell – 
regardless of whether those changes affect safety or quality. The characteristics tested 
are product-specific and vary significantly among producers. Parameters mentioned by 
FBOs in the context of “best before” testing are: 

  appearance; 
  colour; 
  smell; 
 
taste; 
 
texture or consistency; 
  characteristics related to functionality (e.g. spreadability, melting point); 
  mould growth; 
  staleness; 
  degradation; 
 
  weight loss. 

freshness; and 

Some differences in where tests are undertaken were reported. Most producers stated 
that they perform the tests themselves. Some use external laboratories. Others use a 
combination of internal and external testing. 

Many of the producers mentioned testing procedures for monitoring, controlling and 
fine-tuning shelf life. This is especially common for fresh produce, for which factors 
outside the producer's control (such as weather conditions or the time of year) can 
have a significant impact on shelf life. In these cases, producers commonly have a 
storage room in which produce is constantly monitored. Testing of other products was 
reported to occur less frequently. One producer reported undertaking tests every 
month; another mentioned testing yoghurts twice a year. Others did not specify any 
particular frequency. 

A dairy producer who stated that it determined the use of “best before” and “use by” 
based on overall shelf life described its product testing procedure thus:   

The microbiological results from the accredited laboratory decide on the type of 
label. The accredited laboratory performs tests according to the valid legislation for 
the given product type at the start and end of the “use by” and “best before” time. 
The product is also assessed by sensors in the laboratory and “use by” or “best 
before” is determined based on these tests. Then, until the end of “use by” or “best 
before”, products are stored at the required temperature in an accredited 
laboratory – we call this a ‘storage test’, and on the basis of this test the product's 
durability is finally determined. 

Retailer influence 

Most retailers stated that they trust the dates applied by their suppliers but push for a 
minimum life on receipt (MLOR) wherever possible. Several retailers and a number of 
producers of retailers’ own-brand products indicated that this influence is stronger for 
retailers’ own-brand products. For example, a dairy producer stated:  

Dairy producer 

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Of course, sometimes if we are producing cheese for a private label44, we might 
receive a requirement from the customer that they want 120 days shelf life on a 
product, and in such an instance we then have to give them a cheese with 120 
days of life. 

No producer explicitly stated that retailer pressure had led it to increase the shelf life 
of a product. Many did mention that retailer pressure had played a role in their 
decisions to invest in innovations such as:  

Dairy producer 

  “clean rooms”45; 
 
innovative packaging; 
  new packing methods; and 
  changes in recipe. 

Some producers stated that a longer shelf life on a product can provide a competitive 
advantage. A dairy producer explained:  

If you're competing with another producer, this might also end up being a 
consideration. If company A can produce a product with two weeks shelf life and 
company B makes the same thing but with four, this could play into retailers' 
decisions. 

Dairy producer 

Minimum Life on Receipt (MLOR) 

Many of the producers and retailers stated that MLOR is a key parameter in their 
contracts. One interviewee with a background in retail suggested that this might affect 
some producers’ shelf life calculations but did not identify those producers or the 
relevant product categories. This suggestion was not confirmed by any producer 
interviewed. 

Several producers stated that retailers or wholesalers request a specific number of 
days of MLOR. These producers make logistical decisions (about which locations to 
deliver their product from and when to do so) on the basis of that number of days. 
This issue is more important for producers of products with relatively short lives than 
for producers of products with relatively long shelf lives; however, the latter producers 
did mention this issue as being of importance to them. Just one producer stated that 
MLOR is almost always stated as a percentage of total shelf life rather than as a 
specific number of days. 

No producer claimed that MLOR considerations influence its practices when setting a 
“use by” or “best before” date. MLOR was, however, cited as a reason to invest in 
innovations (see above).   

Caution by producers 

Many producers set “best before” dates that are cautious, i.e., shorter than necessary, 
because they consider the “best before” date to be their guarantee of quality and thus 
that it needs to be correct whatever the circumstances. Testing was frequently 
described as anticipating the "worst case scenario."  

The need to avoid consumer complaints was mentioned frequently by producers, 
including those who produce products for sale under a retailer’s brand.  As one 
producer stated: 

44 The FBO was using the term “private label” in the sense of a product manufactured or provided by one 
company for offer under another company's brand, also known as a "phantom brand".  
45 “Clean rooms” are processing areas in which environmental pollutants, including microbes, are kept at very 
low levels by means of air filtration. 

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Our performance is measured on service and delivery but also against customer 
complaints, so it's in our interest to make sure that the right date is on the pack. 

Fresh produce producer 

Shelf life and consumers’ perceptions of freshness 

Interviews with FBOs suggest a hesitancy on the part of producers to extend the shelf 
lives of products that are perceived as "fresh." Consumer purchasing trends have 
favoured products without preservatives and with more "natural" ingredients. Such 
characteristics can seem incompatible with long shelf lives, even though they are 
compatible. As one producer stated:  

We also consider observed product specifications. For example, we might offer a fresh 
product, and if you put a fresh product on the market with a very long shelf life, that 
doesn't quite make sense.  

Dairy producer 

Another producer described a consumer-perception problem with products (such as 
cheeses) that had traditionally been sold chilled but which, as a result of technological 
innovations, could now be stored at ambient temperatures:  

When there are such products displayed in store at an ambient temperature, however, 
it can be difficult for both consumers and authorities to understand that this is okay. 
We had one case where the retailer had our cheeses standing out and the authorities 
were about to throw out all the cheese because it was [supposedly] a case of 
breaching the regulation. So it's not the regulation itself that is an issue, but rather a 
problem of consumer perception. 

Dairy producer 

One producer stated that retailers might be overly cautious about the shelf life of pre-
packed salad because of their concerns about consumers’ perceptions of freshness: 

If we say that the shelf life is 9 days, retailers might choose to set 7 days instead so 
that they have a better chance the salad still looks great up until the last day. 

Fresh produce producer 

The cold chain and chilled-product storage temperatures 

Many producers stated that they could not assume that retailers and consumers would 
maintain the integrity of the cold chain. They factor cold chain interruptions and 
prolonged storage at ambient temperatures into the testing of chilled products. 
Consequently, the product lives established are shorter than would be possible if the 
integrity of the cold chain were maintained until consumption. 

A few countries have introduced legal requirements (e.g., Denmark, Finland, Sweden 
and Norway) or guidance (e.g., Austria) on storage temperature. There is some 
variation in what these laws require. Sweden is working towards harmonised 
temperature standards among the Nordic countries with the aim of facilitating food 
exports and maintaining the cold chain. 

Some producers also stated that they factor the variations in retailers’ storage 
temperatures between different countries into their product life testing and hence into 
the determination of product shelf life.  For example, they stated that they know the 
typical temperatures for storing chilled products to be 5°C in Denmark, 6°C in Finland, 
8°C in Sweden and 10°C in Germany. They also stated that in some countries these 
temperatures are mandated by NCAs, whereas in other countries temperatures are 
advised by local trade association guidance or are simply a matter of customary 
practice. One such producer stated:  

It is usually said that if you lower the temperature by 1 degree you win one day in 
duration. So, on a product we are selling to the consumer market in Sweden we 

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have a storage temperature of 8 degrees, and maybe we have 7 days of duration; 
but if we sell it to Finland, we can put 8 days duration and if we lower the 
temperature further, we can have 9-10 days duration. So, on the same product we 
might have different durations because we have specified different storage 
temperatures. 

Fresh produce producer 

Another such producer stated that it tests products explicitly on the basis of a cold 
chain guaranteed by a particular customer. 

Other producers did not claim exact knowledge of storage temperature variations 
across countries or of their customers’ storage temperatures. One such producer 
stated, however:  

What is interesting is that display cases in other countries will be kept much colder, 
at two degrees for example. This is also true for very hot countries. In Germany, 
by contrast, the display cases are not so cold. I don't have any proof for this, but 
this is what I've heard elsewhere too. 

Dairy producer 

These producers therefore test products on the basis of a “worst case scenario”: either 
a highest likely chilled temperature or, in the case of fresh produce, ambient 
conditions.  

NCA influence 

NCA influence on product life reportedly extends only to defining maximum storage 
temperatures in national legislation. A poor understanding of regulation by some 
producers led to a perception of influence, however. For example, one producer who 
claimed that the shelf life used for fresh milk (7 days) was prescribed by EU 
regulation. 

Retailer controls 

Some retailers conduct testing of product life (as well as quality control of product 
information labels). One retailer explained:  

We trust the dates our suppliers set, however, we do our own testing to ensure 
that the date marks set by the producers are correct. When doing this, we conduct 
both sensory and microbiologic analyses. This is mainly on the products that carry 
our own name, as these are the products we can affect the most. 

If it happens that the date is incorrect, we keep a dialogue and ask the supplier to 
change. It is however very rare that the supplier's date setting is incorrect. If the 
producer’s date is not correctly set, we discuss this with them in order to establish 
the cause for the discrepancy–was it an exception or has this been seen before–
and then we request they get back to us with an analysis. We set requirements 
that the producers/suppliers should have established routines for such analysis. 

Retailer 

Another retailer described conducting similar tests, stating that they did so for 
between 10-20% of cases, mostly for products coming from smaller suppliers. 

Such routines might be important for retailers to ensure food safety, but having more 
rigorous control of suppliers’ date marking practices could also help retailers to reduce 

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their own waste and loss. Every additional day of shelf life for retailers means more 
flexibility and a greater prospect of being able to sell the product.46  

As one retailer stated: 

We also negotiate with some producers so that they supply their products as soon 
as they are produced (we have more time to keep them on shelves) but we also 
try to encourage them to put ‘the longest date’ that is allowed by the law (for 
example, if the law allows 20 days before production and consumption and 
producer stipulates 14 days, we have clear case to stretch it here). 

Retailer 

Although there is no such legal requirement, this reference to an unspecified law 
indicates a reticence on the part of the retailer to push the issue too far without an 
appropriate mandate. 

Some retailers mentioned that the variation in date marking practices for similar 
products has led to them work more closely with their suppliers to foster greater 
consistency of approach. 

4.6 

 Storage advice and open life advice 

Storage advice and rationale 

Several producers mentioned that they include storage advice such as "keep in a cool, 
dry place" or "keep refrigerated" on the label. Others mentioned that they include a 
specific temperature for chilled products. One such producer said the choice of storage 
temperature depends on product type. Another producer stated that the storage 
temperature that it displays depends on the cold chain that could be guaranteed by 
the retailer. 

The data gathered during the market research conducted for this study suggests that 
temperatures specified on product packaging tend to be lower than the standard 
maximum retail temperatures mentioned by interviewees. For example, although the 
temperature for shelf life testing mentioned by producers that send products to the 
Swedish market is 8°C, the maximum storage temperatures listed on ham, yoghurts 
and salad bought in Sweden for this study are 7°C, 6°C and 5°C respectively. In 
addition, storage advice for products of the same product type was often found to vary 
or even be contradictory across different markets, potentially leading to further 
confusion. 

Some producers felt that the large amount of information they need (for example, 
because of retailer influence, common practices in national markets, or legal advice) 
dilutes their ability to appropriately communicate “best before” or “use by”, and 
further contributes to consumer confusion. These interviewees were resistant to 
inclusion of any additional wording about the date, considering it to be “information 
overload”.  

One retailer described the process that it uses to establish on-pack storage or open 
life advice:  

Always when a particular type of food requires, we also include storage conditions 
and / or conditions of use on the packaging. This will always result from 
consultations with the manufacturer, customers, their compliance officers, and 
after consultation with an external law firm. 

46 One study found that each additional day of shelf life reduced total waste by 42.8 percent, while increasing 
on-shelf availability by 3.4 percent. This had the largest impact on products with shelf lives of eight days or 
less. Source: Broekmeulen et al. (2016) Sell more, waste less. A report by the ECR Shrinkage & On-Shelf 
Availability Group. 

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Retailer 

Only one FBO described NCA influence as playing a role in deciding storage advice. A 
retailer described switching from using "keep cool" to "keep cool and dry" based on 
advice received from the NCA that "keep cool" was being understood as instructions to 
store in the refrigerator. 

Open-life advice and rationale 

Open-life advice (i.e. instructions about how to keep a product fresh and extend its life 
once opened) was a contentious matter. Many producers stated that they only include 
such information at the specific request of their customers. Concerns about the lack of 
knowledge of consumers’ treatment of products influence the information that 
producers put on the pack. Consequently, either the stated open life would be set 
intentionally short (at just a few days) or the pack would provide advice such as 
"consume immediately after opening”. One dairy producer described why it prefers not 
to include such advice, explaining that:  

You can imagine you have a breakfast table with a nice camembert and with the 
same knife you used for the camembert, you cut into a hard cheese – the 
camembert cultures will be all over the hard cheese. The cultures will grow and a 
few days later the consumer might call up and complain that their cheese has gone 
mouldy. Of course, you can't know what the consumer has been doing with this 
cheese. 

Dairy producer 

There was no mention of open life advice being informed by testing. Producers who 
provide open life advice do so on the assumption that products will be taken in and 
out of the fridge frequently by consumers, cross-contaminated with other products, 
left out for significant periods of time, and generally subjected to poor storage 
conditions. 

4.7 

 Use of date marking in managing the food supply chain 

Additional uses of date marks 

Date marks are commonly used to support stock rotation in stores. They help retailers 
to measure availability and predict future demand. Date marks were also mentioned 
by some producers as having a logistical value: they are used in producers’ 
traceability systems and in the setting of a limit on the time for which the producer is 
liable for the quality of that product. As one producer commented:   

As a producer, you cannot feel permanently responsible for the quality of your 
product.  

Bread producer 

What happens after the displayed date has passed? 

Date marks are used in decisions about a product's fate as the end of the shelf life 
approaches. FBOs discussed a variety of practices that vary according to product 
category and date mark type. Retailers are usually responsible for the disposal of 
products at or near expiry, but in some instances the producers take back unsold 
product. For example:  

  one bread producer mentioned taking back unsold product a few days before 

expiry because it did not want consumers buying a product that was not fresh. 
This producer would then sell the product on to be used as animal feed.  

  one dairy producer said it takes back unsold milk daily so that the products 
available on the shelves were “as fresh as possible.” It stated that this is 
common practice in its markets and that consumers have high expectations of 
how ‘fresh’ milk, above all other products, should be. This company tests the 

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returned products to ensure their quality has not been compromised and then 
uses them in the production of other milk-based products.  

  several other producers discussed their practices of donating, selling on or 
reducing the price of stock as it approached expiry. Retailers usually had 
responsibility for disposal of expired foods but there were example of producers 
taking back and further utilising excess stock. 

The practice of reducing a product’s price as it approached expiry was mentioned by 
several retailers and NCAs. One retailer stated explicitly that it does not do this 
because: 

Our goal is to guarantee consumers the high quality of products. Also, shortening 
the period between when we take the product off the shelf and its expiration would 
have an impact of logistics, including product management. Additionally, if we 
shortened that period, we could not pass the products to foodbanks, as the law 
prohibits to do that. We would have consequently wasted more food. 

Another retailer stated that it keeps food on the shelves until the last possible date 
and does not respond to donation requests because donation of food that has passed 
its “best before” (or “use by”) date is forbidden under local legislation.  

Interview with retailer 

Other practices mentioned were: 

  donating products to be used in biogas production; 

  donating leftover produce to zoos; and 

  selling food that had passed its “best before” date to a social enterprise that 

markets these products to the general public. 

Retailers and producers alike felt that the best way to prevent this type of waste was 
through improved planning and ordering systems.  

There was some variation among countries in the treatment of products that were 
beyond their “best before” date. Some countries (such as Poland) do not allow food 
that is past its “best before” date to be placed on the market of food. National 
legislation in some other countries (such as Austria and Greece) states that products 
that have passed their “best before” date can still be sold or redistributed. In other 
cases (e.g., France), EU rules are considered sufficiently clear, and no additional 
provisions have been introduced.  

Where sales of products that have past their “best before” date is allowed, national 
legislation may also specify that such products should be clearly marked and 
distinguished from other foods. 

Other implementation issues 

Date marks are generally printed separately from the rest of the packaging. The way 
in which date marks are placed on the packaging depends on the equipment used by 
the producer. There are some common practices governing the location of the date 
mark for certain product groups.  Many FBOs stated either that they follow these 
practices or that they place the date in the most obvious location. No interviewees 
mentioned specific problems with the legibility of the dates. Some noted that, where 
necessary, the date wording is placed in a different part of the pack from the actual 
date. This was not mentioned as a problem for consumer understanding; and when 
asked, producers stated that this layout was standard and something consumers were 
accustomed to (for example, the date being placed on the tie for bread products).   

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4.8 

 Enforcement of date marking rules 

The organisation of enforcement activities varies across Member States. In many 
cases, enforcement is responsibility of local inspectors who undertake random 
sampling and include date marking as part of these controls.  

NCAs generally reported that EU date marking rules are clear and thus they did not 
identify issues with enforcement. One NCA found that some inspectors issued 
sanctions when they had found food on the market that was passed its “best before” 
date – even though this was legally permissible – and stated that this was possibly 
due to some misunderstanding of EU rules. The NCA planned to advise inspection 
bodies that foods can be sold after the “best before” date as long as they are safe. 

Another NCA described enforcement issues as follows: 

"The highest priority is that no one gets sick; sometimes you have a feeling 
that businesses want to be 150% sure that the label is correct. It is difficult for 
inspectors to challenge this – businesses know all the rules, they know the 
product and the production processes and inspectors have to challenge the 
business decisions." 

NCA 

Some NCAs had specifically discussed the setting of date marks and what date 
marking is appropriate with FBOs. FBOs in Norway had collaborated with enforcement 
authorities to trial a non-standard wording for date marks. A producer in Sweden had 
trialled a new wording, although this was declared non-compliant by enforcement 
authorities: 

"[A retailer] tried last year to change the date labelling on their own yoghurt 
products. They wrote "lasts at least until" instead of “best before” to press on 
the fact that a product actually last at least until the set best before date. They 
challenged the National Food Administration a little around this labelling, but 
were not supported so now they have been forced to go back to the “best 
before” labelling. It was legal rules that forced them to stop with this 
“alternative” marking. The Swedish National Food Administration told them that 
you are not allowed to write like that because it is linked to the [FIC] 
Regulation.” 

Data gathered during the mystery shopping exercise revealed some date marks or 
wording not to be in line with the requirements of the FIC Regulation.  Interviews 
undertaken with the FBOs that produced these products found:  

  one instance of where the producer did not seem to be aware of the FIC 
Regulation and believed their product (an unmarked bagged salad) to be 
exempt from any dating requirements (as it was unwashed and not a 
"convenience" product); 

  one instance where the producer was aware of the FIC Regulation but believed 

 

the product (also an unmarked bagged salad) to be exempt as it was 
unwashed; and 
two instances of non-compliant products that were sold through 
wholesalers/importers, who seemed both unaware and unconcerned with the 
FIC Regulation. 

4.9 

 Barriers to, and facilitators of, better utilisation of date marking 
in relation to food waste prevention 

Most NCAs and FBOs felt that EU date marking legislation was not a major issue. Their 
main concerns about the legislation related to: 

  consumer misunderstanding of date marking; 
  differences in FBOs’ interpretations of EU rules; and 

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  barriers to donation of foods that were close to their “use by” or “best before” 

dates, or had passed the “best before” date.  

Some countries have introduced national policies to address these issues, as 
summarised in the table below. NCAs have not systematically gathered information on 
the impacts of these policies (many rules had been operational for only a short period 
and interviewees believed it was too soon to draw conclusions about their impacts.) 
When given by interviewees, evidence of impacts was rather anecdotal and based on 
NCAs’ and FBOs’ self-assessment. Table 27 describes barriers to achieving the 
objectives of the date labelling legislation and how these barriers have been tackled. 

Table 27.  Overview of barriers to achieving the objectives of the date labelling 

legislation and how these barriers have been tackled  

Perceived 
barriers 

Initiatives to 
address them 

Examples and impacts 

Consumer 
understandi
ng of date 
marking 

Consumer 
education 
campaigns 

Changes in the 
wording of date 
marking 

NCAs and other organisations have developed 
communication and education materials to raise 
awareness of food waste and promote understanding 
food labels, including date markings (e.g., UK, 
Finland, Denmark, and Spain). 

Alternatives to the “best before” wording are being 
trialled by FBOs, such as: “best before, but not bad 
after”47, “Best before, and normally usable until”48, 
or “lasts at least until” (Sweden, Norway)49. These 
initiatives are at a trial stage, or were interrupted as 
labels were judged non-compliant with date marking 
legislation. No information is available on their 
impacts. 

Smart packaging  Food packaging with a colour indicator has been 

trialled by an FBO (Sweden, Norway). The indicator 
changes colour according to the state of the product. 

FBOs’ 
interpretatio
n of EU rules 

NCAs’ and FBOs’ 
guidance on 
date marking 

Guidance documents on date marking have been 
introduced in several countries under initiatives by 
NCAs and FBOs (e.g., UK and Denmark).  

Barriers to 
food 
donation  

Guidance or 
legislation 
supporting food 
donation  

Some NCAs have established platforms for dialogue 
with food stakeholders to discuss date marking rules 
(e.g., Czech Republic, Estonia, Finland, Germany, 
Lithuania, Luxembourg, the Netherlands and 
Norway). Other authorities provide more ad hoc 
support on FBOs’ request (e.g., UK).  

Guidance on which foods can be donated and within 
what timeframes in relation to date marking exist in 
several Member States (Austria, Belgium, Finland 
Italy, Luxembourg and others). Lithuania has specific 
legislation that addresses these issues. Some 
countries have also introduced legislation that 
explicitly allows for donation past the “best before” 
date (Austria, Czech Republic, Greece).  

Source: ICF 

47 ‘Best før, men ikke dårlig etter ….’ in Norwegian 
48 ‘Best før …. Normalt brukbar til….’ in Norwegian 
49 The wordings reported in this report are the English translations of national wordings. 

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Consumer understanding of date marking 

The nature of the problem 

FBOs and NCAs shared the view that consumer misunderstanding of date marking 
may lead to edible food being thrown away. Interviewees suggested that consumers 
pay little attention to date marking information. Figure 7 illustrates the dynamics 
acting between FBOs and consumers that can lead to use of “use by” dates where they 
are not needed and to shorter product shelf lives.  These dynamics have the potential 
to contribute to increased food waste. 

Figure 7.  Illustration of current relationship between consumer habits/ behaviour and 

FBO application of dates  

Source: WRAP 

Some interviewees believed that many consumers only look at the date on the label, 
without reading the wording. They also expressed a personal belief that consumers 
have become dependent on these dates and no longer use their own senses to 
determine whether products are fit for consumption.  

In support of their comments, NCAs cited evidence from national and EU research into 
consumer understanding of labels, such as:  

  Flash Eurobarometer 425 (this was mentioned several times, though not all 
NCA interviewees were aware of it). This found that just under half (47%) of 
Europeans understand the meaning of “best before” and somewhat fewer 
(40%) are aware of the meaning of “use by”. In both cases, a quarter or more 
think, incorrectly, that the meaning of date marking differs according to the 
type of food for which it is used.  

  national studies on consumers and food waste (e.g., in Sweden, Finland, 

Denmark, Norway, Croatia, Estonia, Hungary, Latvia, the Netherlands and 
Lithuania), which showed different degrees of understanding of date markings 
among consumers. Examples of findings from these studies are provided in the 
box below. 

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Insights from national research into consumer understanding of date 
marks 

This box provides examples of findings from national research into consumer 
understanding of date marks and possible consequences on food waste 
generation, as explored by interviews with NCAs. 

Estonia: 

“The latest survey50 on how consumers understand food labels was done in 
2014. Results showed that people most frequently look for the [“best before”] – 
78% look for it, followed by information on country of origin, list of ingredients 
and additives. […]. The majority of respondents were aware of the meaning of 
the “best before” date (75%), while 23% of people think that the product is 
good until the “best before” date and then cannot be consumed at all, and 2% 
did not know anything. 55% know the meaning of “use by”, 43% think that the 
product is good until the “use by” date but can be consumed later as well, and 
2% did not know.”   

Finland (comment relates to Nordic Cooperation Council states): 

“[…] a study looking at why consumers throw away food can be found in the 
Norden report (p. 69)51. The main reason was mould, followed by the expiration 
of the “best before”/”use by” date. The big question is then how and to what 
extent you can minimise this. One third of food wasted was due to the 
expiration of the “best before” date.” 

Latvia: 

“While the “use by” date is well understood among the Latvian population, the 
interviewee argued that consumers are often misled by the “best before” date. 
This has been verified in a 2016 study conducted by the Ministry of 
Agriculture52.” 

In some countries, legislation that was in place before the FIC Regulation came into 
force may have contributed to consumer confusion. For example, Danish legislation 
established that foods past the “best before” date could not be sold. The Danish NCA 
therefore believed that consumers had to be educated on the changes introduced by 
EU date marking rules. 

Some NCAs and FBOs mentioned issues arising from EU provisions which require a 
double date marking for eggs. For example, an NCA stated that:  

“…products have both a 'to be used by' and a 'to be sold by' date. This can be very 
confusing for consumers and they don't understand that some of the marking is just 
for the retailer.” 

In a small number of cases, date wordings in different languages were identified as a 
possible cause of consumer misunderstandings. 

50 The survey referred to is TNS Emor (2014), “Toidu märgistuse alase uuringu aruanne” [Food Label Survey 
Report]. An English-language executive summary is contained in slides 12–17 of a presentation available on 
the website of the Ministry of Rural Affairs of Estonia, available here (Accessed 5 December 2017). 
51 The study referred to is Silvennoinen, K. et al. (2012), MTT Agrifood Research Finland, “Food waste volume 
and composition in the Finnish supply chain: special focus on food service sector” 
52 The survey referred to is a 2016 survey by the Ministry of Agriculture which consulted 691 Latvian residents 
“to better understand the issue of date marking and how the citizens are using food products based on date 
marking”. The results of that survey are available (in the Latvian language) here (Accessed 5 December 2017) 

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Action taken to address the issue 

Nearly all of the NCA interviewees mentioned consumer education initiatives as a 
useful tool for improving understanding of date markings, although only a minority 
had undertaken any. Many of these initiatives were developed in co-operation with 
other actors, such as FBOs and environmental NGOs. For example: 

  dissemination of awareness-raising materials targeted at consumers, indicating 
that foods can still be eaten after the “best before” date, and explaining for how 
long these can be eaten. These initiatives also aimed at teaching consumers 
how to use their own senses and knowledge to understand when foods are still 
good to eat; 

  organisation of events (such as exhibitions and fairs) to explain food labelling 

and date marking; and 

  development of educational materials for schools to raise awareness about food 

waste. 

Most authorities had not gathered data on the success of these initiatives, although 
they believed that they improved understanding. A Danish survey that measured 
consumer understanding before and after an information campaign on date marking 
had found an increase in understanding, but it not clear how far these improvements 
were a direct result of the campaign. 

To improve understanding of “best before”, operators in Norway and Sweden trialled 
alternative date wording53, such as “best before, but not bad after”, “best before, and 
normally usable until”, or “lasts at least until". Interviewees in Norway indicated that 
the use of “best before, but not bad after” on milk helped to improve consumer 
understanding. Other businesses were reluctant to change their labels, as this could 
mean having to change aspects of their production process and also mean additional 
costs. It should be noted that terminology for date marking is harmonised and 
explicitly laid down in the FIC Regulation.  

Finally, FBOs had tested innovative ways of conveying information to consumers on 
remaining shelf life. For example, a Swedish FBO piloted a carbon dioxide indicator 
which changes colour according to the level of freshness of packed salads. A related 
initiative is being implemented in Norway, where the industry-led organisation leading 
on food waste reduction (Matvett) is working with a partner to promote the use of a 
technology that can communicate to consumers the durability of a product depending 
on the temperatures it has been stored in (so if the product has been stored in optimal 
conditions, the technology enables consumers to know how long it will last). The latter 
innovation is expected to have an impact on reducing waste, especially in the food-
service sector. 

FBOs’ interpretation of the FIC Regulation 

The nature of the problem 

Both producers and retailers discussed issues arising from different interpretations of 
EU rules. NCAs pointed to some product-specific issues which may impact on food 
waste levels. For example: 

 

the Croatian NCA often receives questions from FBOs (especially smaller ones) 
regarding how honey should be labelled. Many FBOs think that honey should be 
exempted from “best before” date marking. NCAs advised them that honey is 
not exempt and that FBOs are responsible for implementing EU rules; and 

53 The FIC Regulation specifies the exact wording which should be used for "best before" and “use by” date 
(Table 14 in Section 3.3.3).  

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  an Estonian NCA reported that some quick-frozen products (such as meat) 

sometimes had a “use by” date mark applied.  However, the NCA then went on 
to state that a “best before” date mark could be applied to such products 
because they are not highly perishable if stored at the right conditions and 
temperature.  

Action taken to address the issue 

NCAs have issued guidance to help FBOs setting the correct date marking and storage 
advice, such as guidance: 

  on what the different date labels mean, and how best to decide which date to 
apply in relation to curtailing food waste (e.g., Denmark, Netherlands, Poland, 
Sweden and UK). Other countries planned to introduce similar guidance in the 
future (e.g., Croatia). 

  which specifies the type of products that should bear a certain date marking 

(e.g., Finland). 

  on running studies on the best conditions for product storage (this is an 

ongoing activity in Estonia). 

In some cases, this was complemented by sector-specific guidance by FBOs, such as a 
software tool to predict the microbial stability of sweet fillings and therefore establish 
their durability54. This tool was developed by Belgian universities in cooperation with 
the confectionery industry and the Flemish region. 

NCAs in the Czech Republic, Estonia, Finland, France, Germany, Lithuania, 
Luxembourg, the Netherlands, and Norway also established platforms for dialogue 
with food stakeholders (such as businesses, scientists and NGOs) on date marking and 
labelling. Other authorities provide more ad hoc guidance on date marking, based on 
requests for clarification by individual FBOs (e.g., UK).  

Examples of dialogue between NCAs, food businesses and other food waste 
stakeholders are given in the box overleaf. 

Barriers to food donation 

The nature of the problem 

Interviewees discussed different barriers to food donation, including: 

  FBOs’ confusions about the conditions under which foods can be donated; 

  donor FBOs’ concerns over their own liability when donating foods;  

  restrictive legislation, such as the prohibition on donating foods for human 
consumption past the “best before” date (this is the case, for example, in 
Poland and Hungary); 

  cost to the donor of donation to the food bank or charity; 

 

tax reliefs that favour certain types of uses of edible foods (such as anaerobic 
digestion) over food donation; 

  a lack of donation infrastructure in certain countries or regions; and 

  difficulties in donating certain types of products – for example, some foodbanks 
receive too much bread or chilled products, which presents additional logistical 
challenges. 

54 Vlaams Innovatiennetwerk, “Project:more stable confectionery fillings while maintaining structure and taste” 
(online) (in Flemish). Available here (Accessed 13 December 2017) 

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Examples of dialogue between NCAs, food businesses and other food 
waste stakeholders 

This box provides examples of initiatives aimed at facilitating businesses’ 
interpretation of EU date marking rules.  

Czech NCAs meet around four times a year with trade associations (such as 
the Czech Food and Drink Federation) and food waste NGOs (such as Save 
Food) to discuss food waste issues and potential initiatives. They also provide 
funding to some of these NGOs. 

Estonian NCAs also hold different meetings with retailers to explain date 
marking rules.  These are mainly informative meetings: NCAs explain existing 
rules and give examples of correct application. They inform businesses of what 
issues have been found through inspections, and discuss cases of non-
compliance. NCAs also present businesses with consumer complaints about 
goods that exceed the “use by” date being still available in store. 

France set up working groups with food operators, associations, NGOs, and 
authorities as part of its national programme against food waste. One working 
group is dedicated to date labelling. Its aim is to reflect about the issue of 
understanding of dates, education, and evolution of EU legislation on food date 
labelling.  

United Kingdom Food Standards Agency and the Waste and Resources Action 
Programme launched a consultation exercise in February 2017 for to update 
industry guidance on the application of on-pack date and related advice 
(storage and freezing guidance). This revised guidance took account of 
submissions from FBOs and other stakeholders and was published in November 
201755. 

Actions taken to address the issue 

The Czech Republic has clearly stated in national legislation that distribution of foods 
past the “best before” date is allowed. There were, however, ethical concerns about 
donating “lower quality food to those in need”. 

Some authorities introduced guidelines for FBOs which indicate what foods can be 
donated. For example, in 2013 Finland issued a guideline which indicates some 
exceptions on use of products that have passed their “use by” date if further 
processed prior to their redistribution to the final beneficiary. The given conditions are 
very specific and restricted only to the specific context of foods donated for charity 
and which are further processed. Charity organisations that prepare food using fresh 
foodstuffs that have been donated can use products on the day after the “use by” 
date. The condition is that the sensorial quality of the product is evaluated and the 
products are heated to at least 70 °C during preparation. Based on positive feedback 
from FBOs and foodbanks, the Finnish NCA believed that these guidelines resulted in 
increased food donations. 

Lithuanian authorities introduced national legislation which indicates which foods can 
be donated. For example, the legislation states that pre-packaged food can be 
donated after the “best before” date, but within certain recommended timeframes. 
Timeframes are defined by product category. 

55 Waste and Resources Action Programme “Labelling guidance: Best practice on food date labelling and 
storage advice” (2017). Available here (Accessed 20 December 2017) 

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Italy introduced a law to limit food companies’ liability for product they donate to 
charities. This law was aimed at addressing companies’ and foodbanks’ concerns over 
their responsibility for the safety of donated foods, which presented an obstacle to the 
development and growth of food redistribution infrastructures. The law enabled the 
creation of a redistribution programme involving food banks, retailers and the food 
service industry. Over the 10 years since the introduction of the law in 2003, this 
programme supported the recovery of a significant amount of foods to be donated, 
such as: 2.6 million portions of ready meals, 800.000 kilos of bread, and almost 
900.000 kilos of fruit56.  

In Germany, to address issues associated with logistics and infrastructure, FBOs and 
food banks established voluntary agreements on donation.  

Some countries have introduced tax reliefs on foods distributed to charities in order to 
address issues associated with the costs of donation. For example, food donations in 
Hungary, Italy and Belgium are exempt from value added tax (VAT). These countries 
also provide further benefits to businesses: in Hungary, 20% of the value of donations 
can be deducted from the corporate tax base. In Italy, the cost of donated items can 
be deducted from the tax base, up to a value corresponding to 5% of business 
income. 

4.10   Stakeholder views on Annex X of the FIC Regulation 

Several NCAs were in favour of further discussions on the list of foods exempt from 
"best before" labelling specified under Annex X of the FIC Regulation, but many were 
reluctant to see this happen and did not view it as a priority. There were concerns that 
consumers were used to the “best before” date on some longer life products and 
removing the date might have counterproductive effects. It was also felt that there 
were many products with long shelf lives, such as coffee, where quality would still 
deteriorate, and for that reason it would make sense to keep a date. However, the 
Dutch NCA was strongly in favour of extending the list of foods exempt from "best 
before" labelling and has carried out a risk assessment to determine criteria for 
selecting such foods based on product qualities and characteristics that could be used 
to select foods which could be added to Annex X.57  

Among FBOs and European organisations, a similar range of opinions was expressed. 
A large number of the producers interviewed were unaware of the list or had no 
opinion on it, as their own products did not warrant exemption. Some believed that 
extensions and additional criteria should be considered, especially considering the 
ongoing advances in food processing technologies. Others believed that additional 
products should not be added, as such an extension would lead to inferior products 
being placed on the market. One producer, the bread producer quoted in Section 4.7, 
went so far as to say that all food products should display a date mark – in other 
words, that none should be exempt.   

You can lengthen the shelf life all you want but there should still be a date 

Across all stakeholder groups, there were suggestions of additional products or 
product categories that could be added to the list. Examples are:  

Bread producer 

  dried pasta; 

  cheese wheels; 

56 Banco Alimentar, “Good Samaritan Law: two million ready meals recovered in 10 years” (2013) (in Italian) 
(online). Available here (accessed 13 December 2017) 
57 Ministry of Economic Affairs of the Netherlands: “Options to extend the list of foods that are exempted from 
the requirement to bear a date mark” (2016) (online) – available here (accessed 20 December 2017) 

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  canned, sweetened condensed milk; 

  some preserved meats that can be stored in ambient conditions; 

  coffee; 

 

tea; and 

  cheese in brine 

For many of these products, it was suggested that including just a production date 
would be more helpful than “best before” labelling. There was concern among many 
stakeholders, however, that adding a type of date that consumers were not used to 
and is in the past rather than the future would only add to consumer confusion58.  

Lastly, some NCAs suggested that producers were not making enough use of the 
existing provision in the FIC Regulation for longer life foods to be labelled with a “best 
before” date consisting of month and a year, or a year alone in the case of very long 
life products. They suggested that this might be because of consumer preference, 
traceability or simply long standing local market practices.   

58 This is confirmed by an experiment conducted by the European Commission in 2015, which showed that 
including only the production date led to more food waste than either “best before” dates or no date at all 
(European Commission: “Milan BExpo 2015: A behavioural study on food choices and eating habits” (2015) –
available on the website of DG Justice and Consumers of the European Commission at 
http://ec.europa.eu/consumers/consumer_evidence/behavioural_research/docs/bexpo_milan_final_report_we
bsite_en.pdf ). This same work found that products with a non-expired “best before” date were thrown away 
less than products with no date, but that after the date had passed, the situation reversed. This can be 
compared to work by Holthuysen et al,, which found that long shelf life products were thrown away less 
frequently (12% reduction) when the “best before” date was removed. Adding "Long Shelf Life" to the 
packaging on top of this further reduced food waste (31%), but it was also found that these results varied 
greatly depending on product type. 

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5 

Conclusions 

5.1  Introduction 

This section presents conclusions from the project research.  Following some 
introductory remarks on lessons drawn from the desk research, the main conclusions 
of the market research and stakeholder consultations are provided under the following 
headings: 

  Choice of date mark type (“use by”, “best before”) 

  Product shelf life/ setting of expiry date 

  On-pack storage advice and open-life instructions 

  Legibility and layout of date mark and on-pack information 

  Enforcement of compliance with FIC Regulation and guidance 

  Possible further exemptions to date marking under FIC Regulation Annex X. 

The stakeholder consultations provide some explanation of the findings of the market 
research insofar as they shed light on the practices and perspectives of FBOs and 
NCAs. These conclusions inform the recommendations on how to prevent food waste 
through actions related to date labelling of foods that are provided in Section 6.    

5.2  The existing evidence base 

The desk research component of the study reviewed research on industry use and 
consumer interpretation of date labels on food, and analysed data on the scale and 
distribution of food waste in the EU.  

The over-arching conclusion from the data analysis is that any proposals to reduce 
food waste by driving improvements to labelling practices should focus on those food 
product types for which the consumer decision to discard is (already) likely to be 
informed by reading the on-pack label; and whose contributions to EU food waste is 
significant.  Of food product types used in the market research, the greatest 
opportunities for prevention of food waste in relation to date marking exist for milk 
and yoghurts, fresh juices, chilled meat and fish. For other product types, the 
consumer decision to discard is more likely to be informed by visual cues that indicate 
a decline in product quality and palatability, such as fresh produce and bread. 

The main findings from the review of existing research are that: 

  date marking is frequently cited by consumers as a reason behind avoidable 

food waste; 

  extending product life is possible and would reduce avoidable food waste; 

 

there is considerable variation in practices concerning date marking and other 
information provided on food labels, leading to a greater potential for avoidable 
food waste; and 

  consumers have an imperfect understanding of date marks and other 

information displayed on food labels, and they need clearer and more easily 
comprehensible information if avoidable food waste is to be reduced. 

5.3  Choice of date mark type (“use by”, “best before”) 

The interviews suggest a high level of awareness among FBOs and NCAs of the FIC 
Regulation, its requirements, and its intent in distinguishing between “use by” date 
marks and “best before” date marks. This is consistent with the key finding from the 
market research that almost 96% of products sampled displayed a date mark and date 
wording that were in line with the requirements of the FIC Regulation.   

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Nonetheless, the market research found variation in date marking practices within 
product types and among Member States. Of the ten product types sampled for this 
study, only sauce, sliced bread, and fresh juice had predominantly the same type of 
date mark in all eight Member States surveyed. (Along with hard cheese, these were 
the product types for which more than 80% of products sampled displayed a “best 
before” date mark.) The other product types tend to display a “use by” date mark in 
some Member States but a “best before” date mark in others. Examples were even 
found of otherwise identical products manufactured by international brands displaying 
a “use by” date in one Member State and a “best before” date in another.  

In general, “use by” date marks were less commonly found on products purchased in 
Sweden and Germany than on the same products purchased in other Member States.  
There is survey evidence59 of particularly low levels of consumer understanding of “use 
by” date marks in these two countries (Figure 8). 

Figure 8.  % Public correctly understanding “use by” dates (Eurobarometer 425, 

2015) compared with  % of sampled product purchased for current study 
with “use by” dates applied, by Member State 

70%

60%

50%

40%

30%

20%

10%

0%

SE

DE

NL

ES

SK

HU

PL

EL

% public understand 'UB' -Eurobarometer % sampled product 'UB' -market survey

Source: ICF based on Eurobarometer data and current study market research results.  
Note: ‘UB’ = “use by” date mark. 

The stakeholder interviews provided insights into the causes of the differences among 
FBOs and among Member States in what type of date mark is regarded as appropriate 
for which type of product and why: 

  a product type carrying “use by” in some markets will carry a “best before” date 

mark in others;  

  “use by” date marks are being used on some products where there is no 

apparent food safety reason for doing so and thus where a ‘”best before” date 
would be more appropriate; and 

 

there are examples of products listed in Annex X of the FIC Regulation having a 
date mark where none is required.  

59 Eurobarometer 425, 2015. 

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Some producers are taking account of factors beyond the product characteristics 
when determining how to apply the terms of the FIC Regulation.  These include their 
perceptions of consumer knowledge of date labels. Some producers apply “use by” 
date marks to products (for which a “best before” date mark would be more 
appropriate) as a precautionary measure given the uncertainties about consumer 
handling food safely. This is also linked to: 

  different perceptions as to which foods are ‘highly perishable’ in each market;  

  retailer preferences for date marking practices, including examples of: 

-  a preference for using “use by” dates for particular categories of product, 

such as all chilled products or all fresh produce; and 

-  a preference to use “use by” dates to indicate freshness to the consumer. 

Retailers tend to favour a consistent approach to date marking for each product type 
in each national market but are used to accommodating variation in labelling practice 
between national markets. The determination of the preferred type of label in each 
country is influenced by factors that include perceived expectations of consumers and, 
in some cases, guidance provided by a trade association or the relevant NCA. 

Some NCAs provide interpretative guidance of date marks based on the FIC 
Regulation. There is variation among Member States in what this guidance entails.  
Most guidance cited by interviewees relates simply to interpreting the meaning of the 
date marks, but some guidance is more prescriptive, specifying which type of products 
should display what kind of date mark. There are also examples of NCAs working to 
harmonise practices across countries (e.g. among Nordic countries).  

There is some evidence that “use by” and “best before” are used interchangeably to 
communicate product safety in some markets. Poor consumer knowledge was 
sometimes cited as a reason for applying a “use by” date, or for taking a cautious 
approach to date marking.  

Lastly, date marks sometimes have other uses, such as helping with stock rotation or 
traceability. This may play a role in producers not taking advantage of the possibility 
offered in the FIC Regulation to mark longer life foods with just the month and the 
year, which in turn may contribute to consumers’ perceptions of the definitive nature 
of “best before” dates. 

5.4  Product shelf life/ setting of expiry date 

FBOs are responsible for determination of the shelf life of their products (with the 
notable exceptions of table eggs, which legislation specifies must be sold to the 
consumer within 21 days of laying, and poultry meat). 

The remaining shelf life (as measured by the gap between the date of purchase and 
the “use by” or “best before” date on the product) of products purchased in the 
market research was assessed.  None of the 10 product types showed a statistically 
significant difference between the remaining life of products carrying “use by” and 
those carrying “best before” date marks. This suggests that date marks were being 
used interchangeably as, since “best before” reflects food quality and “use by” reflects 
food safety, for a given product, the “best before” date should expire sooner than a 
“use by” date. 

The interviews with FBOs and NCAs established that the declared shelf life is normally 
determined by safety and quality considerations (as informed by microbiological or 
sensory testing), and previous experience of a product or similar products60.  For some 
FBOs the product life testing, and hence the determination of shelf life, also takes 

60 The variation in the technical aspects that are used to set product life is well evidenced, e.g. Norden (2015). 

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account of the variations among countries in retailers’ storage temperatures. For 
example, a manufacturer will give a product a shorter shelf life when selling it into the 
German market than when selling the same product into the Swedish market because 
German retailers’ chill cabinets tend to be maintained at a higher temperature than 
those of their Swedish counterparts. 

The interviews identified examples of retailers and suppliers working together to 
improve shelf life. Discussions about minimum shelf lives are part of this process. 
FBOs prioritise food safety as they would be expected to do – and tend to act 
cautiously to take account of differences in storage conditions (e.g. temperatures in 
the chilled food chain) and the ‘worst case’ scenarios for consumer or retail behaviour 
(e.g. chilled foods being stored in ambient conditions). This shows that greater 
harmonisation, with respect to setting shelf life for products of the same product type, 
might bring further benefits in terms of allowing FBOs to extend shelf life safely and 
reduce buffers, taking account of varying storage conditions. 

Concern about consumer perceptions of products can prevent firms from exploiting the 
potential for extension of shelf life provided by improved storage technology. For 
example, advances in food processing technology mean that some products that have 
traditionally been sold as chilled products with short lives can now be safely stored at 
ambient temperatures (for example, fruit juice and certain cheeses). However, 
producers are influenced in the setting of product shelf life by public perceptions and 
may resist setting a longer product shelf life in such cases for fear of undermining a 
product’s association with freshness and quality. 

The interviews suggested that NCAs are generally not involved in providing technical 
guidance on product testing or setting shelf lives (though there are a few exceptions 
to this general rule). The main reason given by NCAs for not providing such guidance 
is that setting the date is the producers’ responsibility (because only producers can 
fully understand product formulation and issues of food quality and food safety) and 
so the producers should continue to be accountable for the date setting choices that 
they make.  

5.5  On-pack storage advice and open-life instructions 

The market survey found that: 

  A wide range of storage advice was available for the sampled products, 
particularly in relation to the appropriate storage temperature for chilled 
products (which was expressed either as a maximum temperature or a 
temperature range). In Germany and Netherlands, this temperature-related 
storage advice was directly linked to the date wording. 

  The storage temperatures quoted on products tended to be lower than the 

standard maximum retail temperatures mentioned by interviewees as the norm 
for the relevant market. The storage advice in the same product group was 
often found to vary or even be contradictory across different markets, 
potentially leading to consumer confusion. 

  There was variation across the product types in the prevalence of advice on 
open life.  Such advice was provided on the majority of fresh juice and pre-
prepared chilled pasta products.  It was least commonly found on yoghurt, 
tomato sauce, hard cheese and sliced bread. 

Interviewees acknowledged the lack of consistency in storage advice and open life 
advice.  There was no consensus on what constituted good quality, non-mandatory 
advice on open life for consumers. 

The discussions suggested that FBOs’ concern to avoid customer complaints and 
adjustments for factors such as consumer knowledge, and uncertainty about the 

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conditions in which the product might be stored, led them to use formulations such as 
‘consume immediately’ as a precautionary measure. 

FBOs and NCAs discussed various aspects of consumers’ understanding of “use by”, 
“best before” and storage / open life advice in particular. There were some calls for:  

  clarification of the wording; 

  more guidance from the Commission and national bodies;  

  simplification of the advice provided to consumers (e.g. standardised colour 

coding or pictures to communicate, rather than words); and 

  more innovative or technologically advanced ways of communicating whether a 

product is no longer safe to eat or close to the end of its life. 

5.6  Legibility and layout of date mark and on-pack information 

Fieldworkers reported difficulty in reading date marks and/or the wording on 11% of 
the products sampled. The main problems were that the text was too small, the layout 
was unhelpful and the print quality was poor.  For example, 20% of pre-prepared 
chilled pasta products had a date mark or associated wording that was unclear, as did 
16% of sliced ham products and 13% of sliced bread (Section 3.3.5). No interviewees 
mentioned specific problems with making dates legible, despite the difficulties faced 
during the fieldwork. 

The market research found that the date wording and date mark were alongside one 
another on some packaging and appeared separately on others. In the latter case, the 
FIC Regulation requires the date wording to state where the date mark is displayed on 
the packaging (e.g., “best before: see date on cap” rather than just “best before:”). 
FBOs explained this variation by reference to historic practices in each market that 
governed the location of the date mark for certain product groups. The separation of 
date wording and date marks generally occurs when the date mark is added on to pre-
printed packaging during the latter stages of the production process (e.g. date stamps 
applied to bottle tops and on bread ties). FBOs did not see the separate location of 
date mark and date wording as a problem for consumer understanding; when asked, 
they stated that such layouts were standard and something that consumers were 
accustomed to. 

5.7  Enforcement of compliance with FIC Regulation and guidance 

Most NCAs considered that the choice of date mark is the responsibility of FBOs and so 
not a matter for them to enforce.  One NCA commented that enforcement of the FIC 
Regulation and action by NCAs was generally limited to ensuring that food that has 
passed its “use by” date is not sold to consumers (Section 4.8). However, some NCAs 
and other actors (e.g. trade associations) actively tried to shift date marking practices 
when these have the potential to increase food waste. Examples are: 

  attempts to harmonise storage conditions across the chilled food chain; 

  support for stakeholder or cross-industry dialogue; 

  producing guidance to clarify the interpretation of “best before” or “use by”61; 

  carrying out studies on what consumers would find helpful, or what they find 

difficult to understand in relation to date labelling; 

  supporting FBO initiatives to propose additional date wording to clarify to 

consumers that “best before” is a quality mark and not a safety mark, e.g., 
‘best before but not bad after’; 

61 See, for example “WRAP Whole Chain Resource Efficiency Projects” (WRAP, 2015a)  

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 

investing in smart packaging which can give a more accurate indication of 
durability for the end consumer; and 

  removing legal barriers to food donation as they relate to date marking.  

5.8  Donation of food past the "best before" date 

Interviews revealed a wide range of practices and legal frameworks governing the 
donation of food that has passed its “best before” date. Although allowed under EU 
rules, some Member States discourage or forbid this practice (e.g. Poland) while 
others encourage it (e.g. Italy). The local infrastructure for food distribution, including 
food banks and charity organisations, also influences FBOs’ practices. 

5.9  Possible further exemptions to date marking under FIC 

Regulation Annex X 

Annex X of the FIC Regulation lists food products that are not required to display a 
“best before” date mark. There was no consensus among those consulted as to 
whether adding further products to this list would be helpful in reducing food waste 
(based on evidence of consumer behaviour in relation to date marking).  Consumer 
expectations relating to the presence of information and a date mark played a part in 
this feedback. This suggests that hesitancy about adding further products to the list is 
not misplaced, and any potential additions should be carefully considered. 

Overall conclusions 

Based on the study's findings, the authors conclude that avoidable food waste linked 
to date marking is likely to be reduced where: 

  a date mark is present, its meaning is clear and it is legible; 

  consumers have a good understanding of date labelling (notably the distinction 

between “use by” – as an indicator of safety - and “best before” – as an 
indicator of quality); 

  “use by” dates are used only where there is a safety-based rationale for doing 

so, consistent with the FIC Regulation; 

 

the product life stated on the packaging is consistent with the findings of safety 
and quality tests, and is not shortened unnecessarily by other considerations, 
such as product marketing; 

  storage and open life guidance are consistent with the findings of safety and 

quality tests; 

 

there is a level of consistency in storage of food at retail and guidance for 
consumers regarding the temperatures at which products should be stored in 
the home.   

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6 

Recommendations 

6.1  Introduction 

This section provides recommendations, based on the evidence gathered in the 
research conducted for this study, for future policy on date labelling, looking in 
particular at links to food waste.  

6.2  Technical guidance and support for dialogue within the supply 

chain would help to steer FBOs towards best practice in date 
labelling 

A number of issues identified in the research could be addressed by producing 
technical guidance and by giving support to dialogue within the supply chain. Such 
guidance should be developed by a multi-stakeholder group and could be coordinated 
by the Commission through the EU Platform on Food Losses and Food Waste.  

Issues to be considered are explained below. 

6.2.1  Determination of shelf life and guidance on storage and open life advice 

The research found uncertainty among FBOs as to how best to determine shelf life and 
guidance on storage. This could be addressed by technical guidance that takes into 
account food safety and technology considerations as well as best practice. Member 
State NCAs and scientific bodies, especially those who have developed best practice 
guidance, could be consulted to help manage this. Trade associations could also be 
consulted, especially since guidance is likely to be specific to food product categories.  
Important areas for guidance include the: 

  assessment of possible risk to health (to inform decisions on the type of date 

mark to apply); and 

  determination of product shelf life and open life taking account of safety and 

other factors. 

Information on good/bad practices on presenting open life information should be made 
available. Where there are gaps, support for new research should be considered. 

Any guidance in this area would need, as far as possible, to be ‘future-proofed’ to 
accommodate technical innovations in products (e.g. cases of products shifting from 
chilled to ambient identified in this research and vice versa) and packaging (e.g. smart 
packaging).  

6.2.2  Making a choice between “use by” and “best before” labels 

Marking food with a “use by” date when there are insufficient safety grounds for doing 
so increases the likelihood of that food being discarded when it is still safe to eat. The 
evidence that inappropriate date marking occurs comes from stakeholder interviews as 
well as the market research data. It would be beneficial to provide technical guidance 
on when a “best before” date mark could be used instead of a “use by” date mark 
without compromising product safety and consumer information. At present, local 
market conditions and inertia among FBOs may be limiting the potential for a 
consistent approach across Member States, as evidenced by conflicting information 
given on multilingual labels.  

6.2.3  Management of temperatures of chilled food in the retail supply chain 

Interviewees cited differences in management practices in the supply chain for chilled 
food among Member States that have an effect on producers’ decisions about product 
shelf life. Guidance, or regulations, could be developed to address these 
inconsistencies in management practice. (The negative impact of the extra energy 
demand, if any, to store products at a lower temperature would be offset by the 

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beneficial impact of the reduction in food waste, owing to the large lifecycle impact of 
food production.) 

6.3  FBOs should be encouraged to act to address the problem of 

illegible date marks as a priority 

Many of the products purchased for this study were not legible as a consequence of 
issues with print quality and ink retention, excessively small font size, and colours that 
could not be distinguished against the background packaging. There were also issues 
with layout, notably the separation of date type and date mark.  These problems most 
commonly occurred when date marks were printed onto plastic film and plastic bottles.  
However, they may also occur when an “overlabel” is used (i.e., a label affixed to food 
packaging to display information in an additional language) but is damaged.  

This is a matter that should be addressed by FBOs in partnership with retailers (who 
are in a position to monitor the degradation of print after it leaves the production 
facility and whose staff will have difficulty applying stock control policies if dates 
cannot easily be read), and checked by NCAs as part of their monitoring of compliance 
with the FIC Regulation.  

Supplementary measures targeted at FBOs and the packaging sector that could help 
to address this problem are: 

  an online resource that illustrates best practice for different packaging formats, 

considering layout, legibility and compliance with FIC requirements; 

  consultation with the packaging sector/ trade bodies on minimum ink 

adherence/ chemical compatibility for printing onto glass, PET and HDPE, taking 
into account product life (e.g. requirements would be different for fresh milk 
compared with tomato ketchup). 

6.4  Further steps could be taken to help empower consumers to 

make informed choices 

This study did not involve direct consumer research but evidence and perceptions of 
consumer awareness and behaviours figured prominently in the desk research and in 
the stakeholder consultations. 

6.4.1  Improving coherence and consistency of food information to consumers  

Desk research and stakeholder interviews suggest that there are a number of 
instances where inconsistent guidance from various sources, national laws and local 
practices may be leading to increased food waste in the home or at the point of sale.   

This inconsistency is especially acute on multilingual packaging where contradictory 
storage advice, including maximum and minimum temperatures, open-life guidance, 
and even the date wording may appear in different languages – either all on the same 
label or on a main label and an “over-label”. 

Thus there appears to be a need for stakeholder dialogue or further European 
guidance on this topic in order to explore the potential for a consistent approach 
across Member States. 

6.4.2  Ensure that any new consumer education campaigns are informed by a 
synthesis of existing research evidence on consumer behaviour 

There is evidence that many consumers do not fully understand the distinction 
between “use by” and “best before” labels, and that this can contribute to edible food 
being discarded”; however, stakeholders were divided as to whether there would be 
merit in changing the terminology. 

Many interviewees suggested that the Commission should support consumer education 
campaigns on food waste prevention. However, before responding to calls for 
supporting consumer campaigns, it is recommended that relevant existing research 

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evidence is collated and made available to inform the communication strategy. This 
evidence will include information on:  

  consumers’ actual usage and interpretation of date labels in the home and, if it 

exists, its related impact on food waste (the Norden reports62 are a good 
example of this); 

  case studies of campaigns and related evaluation data (if they exist) that have 
been run in Member States, including campaigns on how to interpret “best 
before” and instructions on open-life practices; 

 

the sources that consumers trust for advice on date labels and avoiding food 
waste, and how such information is disseminated (e.g. via retailers, food 
manufacturers, traditional media, social media, family networks, schools). 

This synthesis could usefully be conducted at an EU level given the variable depth of 
evidence available in individual Member States. 

6.4.3  Research on consumer engagement with date labels and associated 

guidance in the home would help to inform future policy 

The evidence base on how to inform consumers and influence behaviour so as to avoid 
unnecessary food waste through use of “best before” and “use by” dates, storage 
advice and open life advice is comparatively weak.  Support for further research in this 
area would help to inform future policy, including by exploring options to increase the 
impact of communications via simplified messages (see box).   

An expert workshop was convened by the research team to discuss the findings of the 
stakeholder consultations including how consumer research and innovation might 
reduce the amount of information consumers are expected to understand and 
process.  Examples are: 

  The potential for graphic symbols to be used to communicate important 

aspects of on-pack advice to consumers: e.g. on-pack freezing guidance, 
distinction between “best before” and “use by”, open life.  An example is the 
‘period-after-opening’ symbol that is currently required by the European 
Cosmetics Directive on cosmetic products with a shelf life of less than 30 
months.  

  Evidence to inform future guidance and/or regulation on ‘smart’ packaging. 

Smart packaging can provide visual and tactile indications of information about 
date marks / wording, food safety risk levels, product life and storage 
guidance.  It may also contain temperature indicators/ sensors and use 
temperature-sensitive inks. 

6.5  Support efforts to extend product life 

6.5.1  Guidance highlighting measures that increase product life 

There is evidence that discussions about the Minimum Life On Receipt between 
producers and retailers have helped to improve product life and reduce food waste by 
providing an incentive for investing in new technologies, such as innovative packaging 
and “clean rooms”. 

62 Norden 2015, 2016. 

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NCAs and other stakeholders could highlight good practice or use guidance such as 
that developed by WRAP (2016d) to encourage FBOs to consider extension of product 
life as and where appropriate (as well as standard setting which can affect product life 
such as the example of more consistent storage temperatures). 

6.6  Address barriers to safe redistribution of food  

This study did not investigate barriers to food redistribution in-depth but the research 
did suggest scope to clarify the legal position and improve consistency of practice with 
regard to the sale or redistribution of food that has passed its “best before” date. (This 
would need to be specific to food product categories.) 

This recommendation could be considered within the scope of work commissioned by 
DG SANTE to support food redistribution in the EU.  

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HOW TO OBTAIN EU PUBLICATIONS 

Free publications: 

one copy: 

via EU Bookshop (http://bookshop.europa.eu); 

more than one copy or posters/maps: 

from the European Union’s representations 
(http://ec.europa.eu/represent_en.htm); 
from the delegations in non-EU countries 
(http://eeas.europa.eu/delegations/index_en.htm); 
by contacting the Europe Direct service 
(http://europa.eu/europedirect/index_en.htm) or calling 00 800 6 7 8 9 10 11 
(freephone number from anywhere in the EU) (*). 

(*)  The information given is free, as are most calls (though some operators, phone boxes or hotels may 

charge you). 

Priced publications: 

via EU Bookshop (http://bookshop.europa.eu). 

Priced subscriptions: 

via one of the sales agents of the Publications Office of the European Union 

(http://publications.europa.eu/others/agents/index_en.htm). 

January , 2018 

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HOW TO OBTAIN EU PUBLICATIONS 

Free publications: 

  one copy: 

via EU Bookshop (http://bookshop.europa.eu); 

  more than one copy or posters/maps: 

from the European Union’s representations 
(http://ec.europa.eu/represent_en.htm); 
from the delegations in non-EU countries 
(http://eeas.europa.eu/delegations/index_en.htm); 
by contacting the Europe Direct service 
(http://europa.eu/europedirect/index_en.htm) or calling 00 800 6 7 8 9 10 11 
(freephone number from anywhere in the EU) (*). 

(*)  The information given is free, as are most calls (though some operators, phone boxes or hotels 
may charge you). 

Priced publications: 

  via EU Bookshop (http://bookshop.europa.eu). 

Priced subscriptions: 

  via one of the sales agents of the Publications Office of the European Union 

(http://publications.europa.eu/others/agents/index_en.htm). 

 
 
 
 
 
 
 
 
 
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ISBN 978-92-79-73421-2