Country of origin requirements (COOL)
In Hungary, as in EU-Member States in general, a number of EU regulations specify the cases where the country or place of origin of food must be indicated on the label. This information is required when:
- It is explicitly required by EU regulation for a category of food (e.g. beef, pork, sheep, goat, kid, poultry, fish, honey, fruit and vegetables), or
- failure to indicate the country of origin is likely to mislead the consumer, taking into account the general impression given by the labelling.
Hungary has adopted a complementary national legislation, the regulation Nr. 74/2012 (VII.25.) on the use of certain voluntary distinctive signs on foodstuffs, which is however considered particularly relevant for “domestic product” or also known as “Hungarian product”. The regulation Nr. 36/2014 (17.XII.) on food information is another important piece of legislation, in the light of which the authorities control the products, but this regulation is also in line with EU regulations an does not set requirements that differ from them.
Definitions of vegetarian and vegan
There is currently no European or Hungarian legal definition and legal concept of what exactly constitutes a vegetarian or vegan product. The European Commission is supposed to adopt such a definition under Article 36(3)(b) of the FIC Regulation, but this is still in progress.
However, pending the adoption of a concrete legal framework, any indication of suitability for vegetarians and vegans on products should be assessed in the light of the general principles of voluntary information to consumers in Regulation (EU) No 1169/2011 on the provision of food information to consumers. In addition, reference is often made to existing private standards (e.g. the V-label developed by the European Vegetarian Union (EVU) or ISO 23662:2021).
Fortification of foods
Fortified foods are products to which nutrients, vitamins or other important substances are added during processing to increase the nutritional or biological value. These foods are used for a variety of purposes, such as replacing lost nutrients, substituting similar foods for nutritional value, or increasing nutrient content. Although a varied diet could be a sufficient source of nutrients, in many cases it does not provide optimal intakes of vitamins and minerals. Fortified foods must meet certain criteria, including the presence of significant amounts of vitamins and minerals and the method of administration. However, it is also important to consider the adverse effects of excessive intake. EU regulations regulate the composition and labelling of fortified foods to inform consumers about the amount of nutrients consumed and the overall nutritional value of the product. The regulations also ensure that other ingredients are used safely and appropriately in foods. Hungary doesn’t specifically regulate fortified foods at national level, but acts in line with EU regulations and transposes them into its own legislation.
Cannabis as an ingredient in food or supplements
In Hungary, cannabis as an ingredient of food and food supplements is not a subject to national legislation, therefore the applicable EU rules and regulations, including Regulation (EU) No 2883/2015 on novel foods and Article 14 of Regulation (EC) No 178/2002 on the general principles and requirements of food law, on food safety requirements are the relevant legislation.
If the CBD-compound can be administered to humans in the form of a food supplement (e.g. a tablet), it is considered a novel food under Regulation (EU) 2015/2283 on novel foods. Its placing on the market is currently classified as risky in the risk assessment of the National Institute for Pharmacy and Food Safety.
As a consequence, its unauthorised production and placing on the market as a food supplement may constitute an offence and may be punishable by a fine and/or community service. Separate food chain supervision fines may also be imposed under regulation Nr. 194/2008 (31 July 2008).