The European Union (EU) has introduced new olive oil quality and labelling regulations. Introduced in November 2022, and published in the EU’s official journal, the Delegated Regulation 2022/2104 and Implementing Regulation 2022/2105 combine previous regulations to improve efficiency and create a more homogenous EU olive oil market, the 30 November report said.
The European Commission (EC) said a comprehensive update was necessary from “the experience acquired over the last decade which shows that certain aspects of the regulatory framework need to be simplified and clarified.” Olive oil quality – particularly with organoleptic and chemical profiles – set it apart from other vegetable and seed oils, and these qualities increased the importance of fraud prevention in the sector, the EC said.
According to the new regulations, olive oil profiles must be analysed using protocols developed by the International Olive Council (IOC) – of which the EU is a member – which require the use of panels of selected and trained tasters. “To ensure uniformity in… implementation, minimum requirements for the approval of panels should be set out,” the EC wrote. “In view of the difficulties that some member states encounter in setting up tasting panels, the use of panels in other member states should be authorised.”
The EC’s new integrated labelling regulations require highly visible and easy-to-read labels, containing information about the product’s contents. The label should also inform consumers about the product’s storage conditions, as “numerous scientific studies have demonstrated that light and heat adversely affect the quality of olive oil,” the EC said. “The labelling regulations are meant to ensure that adequate and correct information on the product enables the consumer to choose,” Roberta Capecci and Roberto Ciancio, officials at the Italian central inspectorate of quality protection and fraud prevention of agri-food products (ICQRF) said. “Sometimes markers use messages that attract the attention of the consumer, emphasising product characteristics not covered by the rules and which may not comply with EU and national provisions,” they added.
Current European food safety regulations prohibit misleading information on labels regarding quality, production process or food origin. “The EU regulation, implemented in regulation 2022/2014, provides for more specific rules related to olive oil origin, the procedures concerning the supply of certain mandatory details, the rules governing the optional particulars concerning the method of production, such as cold-pressed, extract/first pressing and for the chemical and organoleptic characteristics of the oil and the harvest year,” Capecci and Ciancio added.
Labels should also inform the consumer of the product’s origin, the EC said, including whether it is a blend of olives or olive oils from different regions or countries. “As a result of agricultural traditions and local extraction and blending practices, directly marketable virgin olive oils may be of quite different taste and quality depending on their place of origin,” the EC wrote.
The only specific regional indications allowed on labels relate to PDO (Protected Designation of Origin) and PGI (Protected Geographical Indication) certifications. All other products must be labelled according to the country of origin, not its regions or provinces. Other aspects covered by the new regulations include the “age of the product” declared on the labels. “Operators should be allowed to indicate the harvest year on the label of extra virgin and virgin olive oils but only when 100% of the contents of the container come from a single harvesting year,” the EC wrote.
Guidance
Pure olive oils are regulated by the Olive Oil (Marketing Standards) Regulations 2014.
Pure olive oils are:
- extra virgin olive oil
- virgin olive oil
- olive oil composed of refined olive oils and virgin olive oils
- olive pomace oil
All pure olive oils must have the correct chemical properties, such as their acidity, fatty acid and sterol composition.
Extra virgin olive oil and virgin olive oil must also have the correct organoleptic (sensory) properties, such as their smell or taste.
The requirements for pure olive oils are set out in (REUL) Regulation 2568/91 (as amended) for products sold in Great Britain (England, Scotland and Wales) and Regulation 2568/91 (as amended) for products sold in Northern Ireland
Labelling
The label for pure olive oils must:
- follow the labelling rules for food sold or given to consumers
- match the product inside its packaging
- include an English translation if the product is sold in the UK
- state the type of olive oil in the main field of vision and in the same sized text, font and colour
- state its designation of origin (where it comes from) for extra virgin and virgin olive oils only in the main field of vision and in the same sized text, font and colour
- display storage advice to keep away from heat and light
Labelling requirements for pure olive oils are set out in: (REUL) Regulation 29/2012 (as amended) for products sold in Great Britain and Regulation 29/2012 (as amended) for products sold in Northern Ireland.
Extra virgin olive oil and virgin olive oil labels
Labels for extra virgin olive oil must display:
- the name ‘extra virgin olive oil’
- its designation of origin or its geographical indication – a protected status against imitation
- the words ‘superior category olive oil obtained directly from olives and solely by mechanical means’
Labels for virgin olive oil must display:
- the name ‘virgin olive oil’
- its designation of origin
- the words ‘olive oil obtained directly from olives and solely by mechanical means’
For extra virgin olive oil and virgin olive oils, labels could also display optional details:
- first cold pressing – oils obtained below 27°C by traditional mechanical pressing
- cold extraction – oils obtained below 27°C by percolation or centrifugal extraction from olive paste
- organoleptic properties – based on an assessment of its taste or smell
- acidity or maximum acidity which must include the peroxide value, wax content and ultraviolet absorption
- harvest year – if all the olive oil was harvested in the same year, you can label it with the month it was extracted from olives, and the year
Label descriptions must comply with olive oil production methods and organoleptic assessment as described in the regulations.
Olive oil composed of refined olive oils and virgin olive oils labels
- Labels for olive oil composed of refined olive oils and virgin olive oils must display the:
- name ‘olive oil composed of refined olive oils and virgin olive oils’
- words ‘oil comprising exclusively oils that have undergone refining and oils obtained directly from olives’
You must not add the designation of origin on labels for this category of olive oil.
Olive pomace oil labels
Food labels for olive pomace oil must display the:
- name ‘olive pomace oil’
- words ‘oil comprising exclusively oils obtained by treating the product obtained after the extraction of the olive oil and oils obtained directly from olives’ or ‘oil comprising exclusively oils obtained by processing olive pomace and oils obtained directly from olives’
You must not add the designation of origin for olive pomace oil.
Blended pure olive oil labels
Blended extra virgin olive oil is extra virgin olive oil blended from more than one country. Likewise, blended virgin olive oil is virgin olive oil blended from more than one country. Up to 31 December 2023, blended pure olive oils sold in Great Britain can display ‘Non-EU’ on labels. From 1 January 2024, blended pure olive oil sold in Great Britain must not display ‘non-EU’ on its label, unless the product was already bottled and labelled before this date. It must display one of the following:
- a list of each country of origin the oil is blended from
- a statement about its origin, such as ‘a blend of oils from more than one country’
- a statement about its trading group origin, such as ‘a blend of olive oils of European Union origin’
For blended pure olive oils sold in Northern Ireland only, you can use ‘non-EU’ on the label, if applicable.
Labelling infused olive oil
For olive oil infused (flavoured) with other substances, such as garlic, the label must not display any reference to a pure olive oil. For example, you must not state ‘extra virgin olive oil infused with garlic’ (or any other pure olive oil infused with another flavour) or ‘superior category olive oil obtained directly from olives and solely by mechanical means’. You can add pure olive oil to the product’s list of ingredients.
Labelling other oils and food products containing olive oil
You must list olive oil in the ingredients for products containing pure olive oil, for example:
- focaccia bread or pizza dough
- ready-made sauces, such as pesto
- other oil blended with pure olive oil
If olive oil is mentioned in addition to the product ingredients, such as sunflower oil blended with pure olive oil, the label should display the words ‘blend of sunflower oil and olive oil’, followed by the percentage of olive oil in the blend (required by Article 6 of Regulation 29/2012).
Inspections by the Animal and Plant Health Agency
The Animal and Plant Health Agency (APHA) can inspect olive oil products, their labels or records at the premises of:
- bottlers
- marketers
- retailers
- distributors
The number of inspections depends on risk assessment, based in part on past compliance or volume of olive oil handled by the premises. APHA will not pay for any oil taken for sampling.
An inspector will:
- take samples of extra virgin olive oil and virgin olive oil to test sensory and chemical properties
- take samples of olive oil composed of refined olive oils and virgin olive oils, and olive pomace oil to test just their chemical properties
- check that labels follow the relevant labelling rules
- check your records show when your olive oil arrived and left your premises, and where the olive oil came from
APHA will tell you the inspection results by letter or email. This can take up to 3 months. If you disagree with the sensory or chemical test result, you can ask APHA to re-test your product within 14 days of receiving the result. If both re-tests fail, you will only need to pay for the cost of the sensory re-test. This can vary from £300 to £600.
If you fail an inspection at any stage of olive oil production, including any re-test, APHA may issue you with a compliance notice. The compliance notice will tell you what’s wrong, what you must do to fix the problem, and how long you have to do this. You could be prosecuted if you do not comply with the notice.
You can email APHA oliveoilcompliance@apha.gov.uk to ask them to review their decision if you disagree with it. If you’re not happy with their response, you can appeal against the decision. For appeals in England or Wales, your appeal must arrive within 28 days from the date on the compliance notice. For Scotland or Northern Ireland, your compliance notice will tell you what date you must appeal by.
