Vendre en circuit court :Regulation and Labeling

Technical articles - Diversification

Settling in agriculture Product valorization Short supply chains Diversification Direct sale

Sales in short supply chains are regulated to ensure the sanitary quality of products and transparency for the consumer.

Sanitary regulation

The sanitary regulation of foodstuffs, known as the "Hygiene Package" is based on European regulations. It applies to all professionals in the agri-food sector : from the production of raw materials on the farm to their distribution after possible processing.

Sanitary quality of products

Processed products of animal and plant origin

The Regulation 852/2004, called the "hygiene regulation", applicable to foodstuffs of animal and plant origin, provides for a sanitary control plan, especially in the case of direct sale of processed products. This plan must contain at least :

• A training plan for personnel on hygiene.
• Medical monitoring of personnel and defined rules related to personnel hygiene.
• A cleaning and disinfection plan and monitoring of its implementation and effectiveness.
• A pest control plan.
• A plan for self-monitoring of bacteriological analyses and self-controls related to the different stages of manufacturing.
• Water quality control.
• A maintenance plan for premises and equipment.
• Procedures based on HACCP principles.
• Description of the method implemented for product traceability (upstream, input, downstream).
• Description of the method implemented in case of non-compliance with management of sanitary alerts and batch recall procedure.

Products of animal origin

The Regulation 853/2004 applies specifically to foodstuffs of animal origin. It presents the sanitary approval conditions for establishments (Cerfa n°13983) that prepare, process, or store products of animal origin.

• In direct sales, producers must declare their activity to the DDPP (Cerfa n°13984*03).
• In indirect sales, producers may benefit from a derogation from sanitary approval for processing workshops (Cerfa n°13982-05).
• A derogation from approval is only possible if the following 3 criteria are met :
  • The product is included in the following table.
  • Delivery is made within a radius of less than 80 km.
  • The quantities delivered do not exceed the limits defined in the table below. Beyond these quantities sold, approval is mandatory : contact the DDPP for the conditions of obtaining approval.

Product categories	Maximum quantity that can be sold
	Quantity < 30% of the total production for the considered category	Quantity > 30% of the total production for the considered category
Thermally treated milk	800 L / week	250 L / week
Dairy products	250 kg / week	100 kg / week
Fresh meat, excluding minced meat	800 kg / week	250 kg / week
Meat-based products	250 kg / week	100 kg / week
Products based on shell eggs or raw milk having undergone a sanitizing treatment other than dairy products	250 kg / week	100 kg / week
Unprocessed fishery products	250 kg / week	100 kg / week
Processed fishery products	250 kg / week	100 kg / week
Snails	100 kg / week	30 kg / week
Prepared meals	1000 / week	400 / week

Premises

Sales, storage, and packaging premises must be :

• In good condition.
• Clean.
• Compatible with food products.
• Healthy, without risk of contamination.

Raw materials and finished products must not be mixed. Temperatures must be controlled to respect the cold chain. It is essential to consult the DDPP during the implementation of the marketing project so that they can issue an opinion on the conformity of the buildings and ensure that the forward flow is properly respected.

Transport

Means of transport must be :

• Clean.
• Easy to clean.
• Capable of protecting food from any alteration or contamination.
• Isothermal or refrigerated.
• Reserved for the transport of foodstuffs.

Regular temperature checks must be carried out. Products with different contamination levels must not be mixed to avoid cross-contamination.

Consumption regulation

Price display

It is mandatory to clearly indicate the sale price including all taxes (TTC) per unit, by sign, label, or poster. In some cases, the price per kg or liter must be added to the unit price.

Signage

For farm sales, it is necessary to inform and guide the customer by means of signage panels.

For more information, see this article.

Metrology

Metrology defines the principles and methods to guarantee and maintain confidence in measurements.

In marketing projects in short supply chain, this mainly concerns scales used in commercial transactions. Scales must be installed stably and if intended for direct sale to the consumer, must be positioned so that the customer can easily read the weighing result and price indications.

Verification of weighing instruments must be carried out by an organization approved by the prefecture according to various criteria :

• Every 2 years for instruments with a maximum capacity less than 30 Kg, used for direct sale to the public.
• Every year for other instruments.
• A control of scales must also be carried out after repair.

Labeling

To inform the consumer and guarantee transparency about the products sold, it is essential to label products correctly. Labeling obligations differ depending on the mode of packaging of foodstuffs.

Example of labeling of a prepackaged processed product

Prepackaged foodstuffs

• Labeling must include various information that objectively informs the consumer. They must be written at least in French. This information must include :
  • The name of the product.
  • Origin.
  • The list of ingredients in descending order of importance.
  • Ingredients or technological aids causing certain intolerances or allergies.
  • The net quantity of the product, in volume or mass.
  • The quantity of certain ingredients.
  • The consumption date. For perishable foodstuffs : Use By Date (DLC) "to be consumed until...". For shelf-stable foodstuffs : Minimum Durability Date (DDM, formerly DLUO) "best consumed before/on...". For meat-based products, unprocessed fishery products sold frozen : freezing date.
  • The manufacturer identification : name, company name, postal address. If packaged by a service provider, indicate the packaging center's contact details.
  • The batch number.
  • The instructions for use, if the food requires appropriate use or specific storage.
  • The health mark (or sanitary stamp), which identifies establishments preparing, treating, processing, handling, or storing animal or animal-origin foodstuffs (mark obtained from the DDPP).
  • The physical state of the foodstuff.
  • The nutritional declaration.
• Labeling must be fair and not mislead the consumer.

Example of labels for bulk sales

Bulk food sales

A sign must be placed near what is offered for sale mentioning :

• The name of the product.
• The physical state of the product.
• The sale price.
• The mandatory declared allergens.

Organic products

• Labeling of products may refer to organic agriculture (EU and AB logos) if the product contains more than 95% organic ingredients. If the product contains less than 95% organic ingredients, the word "organic" will only be used in the list of ingredients and there is no possibility to affix the EU and AB logos.
• 
  EU logo
• 
  AB logo

• For products in conversion, only plant-based products may bear the indication "product in conversion to organic farming" provided that a conversion period of at least 12 months before harvest has been respected.

Regulated mentions for product labeling

• Organic : products from Organic farming certified by a control body.
• Pure : term usable only for certain products (pure juice, pure pork).
• Countryside, farm, peasant : beware of the farm character linked to the agricultural operation. Products must mainly come from the farm but also from neighboring farms if the operation retains direct control over the products.
• Artisanal : product that must be made by an artisan registered in the trade register.
• Home-made or homemade : if the product is prepared in a non-industrial way, on the point of sale.
• Traditional or old-fashioned: if products are made according to recorded old practices. No additives.
• Natural : product not transformed, untreated, as found in nature.
• Local : means the use of raw materials obtained by manufacturing processes from a restricted geographical area.

La technique est complémentaire des techniques suivantes

• Install a vending machine
• Selling your products at a market
• Selling your products on the farm