The FSA last issued labelling guidelines on these marketing terms in 2002, after the Food Advisory Committee (FAC) had found that a lot of them were being misused in some cases, conveying messages that were far-removed from their generally accepted meanings and thus became misleading. "Marketing terms are useful to enable industry to differentiate their products but need to be used in a way that is meaningful to consumers," said Stephen Pugh, head of the Food Labelling Branch at the FSA. "In our guidance, developed with consumer organisations, industry and enforcement bodies, we have suggested the conditions when certain marketing terms can be used. These conditions reflect current consumer understanding and perceptions of these terms." Guideline revisions The definition of the term 'fresh' has become increasingly blurred because modern distribution and storage methods make the legitimacy of the term increasingly confusing. The term is useful to describe, for example, products that have not been processed, to differentiate raw meat from chemically preserved meat, and to show a juice is not made from concentrates. 'Freshly prepared' can be used to imply immediacy, though it should be accompanied with a date or time. However, the FSA recommends against using the word for an emotive appeal, in phrases such as 'garden fresh', 'ocean fresh' and 'kitchen fresh'. In such situations, the FSA suggests 'finest' would make a better alternative. Regarding the term 'natural', the FSA said that it essentially means the products is "comprised of natural ingredients". It is therefore misleading to use the term to describe foods made using chemicals to change their composition or with added colours and flavourings that are chemically formed. For cases where this description does not fit, the FSA has recommended using the term 'seasonal' instead. Other terms reassessed by the FSA were 'original', 'traditional', 'authentic', 'real', 'pure', and 'farmhouse'. Although recommendations were made to change 'homemade' to 'handmade', this was not changed. The FSA guidelines say that, before using any such terms, manufacturers should consider the following points:
- Foods should be sold without deceit and therefore should be labelled and advertised so as to enable consumers to make an informed choice
- A food must be able to fulfil the claim being made for it, and so adequate information must be provided to show the claim is justified
- The 'average' consumer must be considered when a marketing terms is potentially ambiguous
- Claims should allow for fair comparison and competition between products, sectors and companies
The changes to the guidelines are intended to help producers, retailers and caterers, decide when the descriptions should be used or not. They will also help the enforcement authorities, and will ultimately help consumers in their product selection.