Ingredient shortages due to crisis in Ukraine
The ongoing situation in Ukraine has led to shortages and non-availability of ingredients, notably cereals and sunflower oil/products in both organic and non-organic form. This article summarises the approach we are taking where this impacts product composition and labelling in line with the organic regulations and position of the Food Standards Agency.
Switching from one organic ingredient to another (e.g. substituting organic sunflower oil for organic refined rapeseed oil in a multi-ingredient product), or removing an ingredient altogether
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the list of ingredients and any other references to the ingredient should be amended as soon as possible e.g., by over stickering or re design
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If this is not possible before products are despatched we ask you contact your local Trading Standard Officer to advise them your labels will not be compliant regarding the list of ingredients, and request their confirmation in writing that they have given permission
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If the replacement ingredient is an allergen it must be correctly identified
Switching from organic to non-organic ingredient:
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Unless the replacement ingredient is one permitted as non-organic form in the SA standards (see SA standard 6.6, NB most fats & oils are required to be organic), you must apply for a derogation to Defra (GB) or DAERA (Northern Ireland). In both cases the list of ingredients and any other references to the ingredient on the label must be amended to reflect that it is nonorganic.
If you have any queries please contact us at food.drink@soilassociation.org.