Clean Labels and “Self-evident” and “Flagrantly Misleading” “Palm Oil-free” Claims
This report addresses the legal concept of “self-evident” and “flagrantly misleading” advertising established in Article 7(1)(c) of Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers (hereinafter, the Food Information Regulation, FIR). Since 13 December 2014 (since the specific origin of vegetable oils must be declared), “palm oil-free” claims on, e.g., a product containing sunflower oil or any other vegetable oil (and mandatorily indicating it in the list of ingredients) are arguably obvious, unnecessary and irrelevant (and in legal terms “selfevident” and “flagrantlymisleading”). Compared to similar foods that possess the same characteristics, but do not claim to be “palm oil-free”, these products are in no way “special”.