As the Ukraine War impacts key commodity supplies for Europe and the rest of the world, there are questions about reformulation, ingredient substitution, and labeling. Ukraine is one of the largest agribusiness countries in the world and produces significant amounts of wheat, corn, barley, and sunflower oil. Because of the war, Ukrainian authorities have introduced some export quotas which have had an immediate impact for food companies. In the EU, Regulation 1169/2011 (FIC Regulation) on food information sets the general principle of food law and consumer information. The goal of the regulation is to provide food safety and transparency for consumers. Unfortunately, the FIC Regulation does not have emergency provisions or measures to deal with reformulations due to a food crisis. This gap leaves EU food producers in a gray area as to what can be substituted in recipes and whether a label change is needed. Currently, the most notable substitution is for sunflower oil.  Other countries outside of Europe are grappling with similar situations, and this is likely to escalate as the war continues.

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Picture Credit Susanne Kuehne

Posted on 14 June 2022