Labelling home-made food in BiH: what must be on the jar or bottle

This article is for households, farms and guesthouses that pack jam, ajvar, juices, cheese or similar products in jars, bottles or bags and sell them to guests, at a market or to a local shop. The rule in force is the Pravilnik o pružanju informacija potrošačima o hrani (Rulebook on providing food information to consumers, "Službeni glasnik BiH" 68/13), applied since 13 December 2014. It replaced the Pravilnik o općem deklariranju ili označavanju upakirane hrane (87/08). If a guide you use still cites 87/08, check it.

In short

• Rulebook 68/13 has no exemption for small producers from the label itself: all food meant for consumers must carry the mandatory food information (Art. 6).
• Small producers have one general exemption: the nutrition declaration is not required for food, including hand-made food, that the producer supplies directly in small quantities to the end consumer or to local shops supplying him (Annex V, point 19). Product-specific exemptions (cheese, alcoholic drinks) are listed below.
• Text must be in one of the official languages of BiH, in Latin or Cyrillic script, and several languages are allowed (Art. 15). The lower-case letter height is at least 1.2 mm (0.9 mm on packs whose largest surface is under 80 cm2), Art. 13(2) and (3).
• The business under whose name or company name the food is placed on the market is responsible.

Who it applies to

Anyone placing packaged food on the market: farms, small companies, guesthouses and restaurants selling their own products in packs. For unpackaged food, the business must make sure the mandatory information is passed on to the business receiving the food, so that it can be shown to the end consumer on request (Art. 8(6)); Art. 12(1) requires mandatory information to be available and easily accessible for all food. Ask the inspection about the exact scope.

What to do

1. Put the mandatory particulars from Art. 9 on the pack or an attached label:
   • name of the food (for example "plum jam", "ajvar", "apple juice"); a brand or made-up name cannot replace it (Art. 17);
   • ingredient list headed "Sastojci" (Ingredients), in descending order by weight;
   • allergens (Annex II, for example milk, eggs, tree nuts, celery, mustard) highlighted in the list by font, style or background colour (Art. 21);
   • net quantity in g, kg, ml, cl or l (Art. 23);
   • date of minimum durability (Art. 24, Annex X): "Najbolje upotrijebiti do" (best before) when the date includes a day, month and preferably the year (day and month suffice for shelf life up to three months); if the date has no day, write "Najbolje upotrijebiti prije isteka" (best before end) with month and year (shelf life of three to 18 months) or the year alone (over 18 months). For quickly perishable food, give a date with the words "upotrebljivo do" (use by), as in Annex X; Art. 9 words it "upotrijebiti do";
   • storage conditions, for example "store in a cool, dark place, refrigerate after opening and consume within ... days" (Art. 25);
   • name or business name and address of the producer (Art. 9(1)(h));
   • actual alcohol strength in % vol. for drinks above 1.2 % vol., for example rakija.
2. Put the name, net quantity and alcohol strength (if any) in the same field of vision (Art. 13(4)).
3. Percentage of an ingredient (Art. 22): if an ingredient is named in the product name or highlighted by words or pictures (for example "ajvar with 60 % pepper"), state its share. State the country or place of origin where leaving it out could mislead the buyer (Art. 26). Some additives require set statements (for example "contains sweetener", Annex III).
4. For jam, jelly, marmalade and pekmez add what the Pravilnik o voćnim džemovima ("Službeni glasnik BiH" 85/12) requires: fruit species in the name in descending order, "proizvedeno od ... g voća na 100 g" (made from ... g fruit per 100 g) and "ukupan sadržaj šećera ... g na 100 g" (total sugar ... g per 100 g) (Art. 7 to 9), all in the same field of vision as the name (Art. 10). You may skip the sugar statement only if you give a nutrition declaration.
5. Cheese: an ingredient list is not required if only milk ingredients, enzymes, cultures and salt were added, but it is required for fresh and processed cheese (Art. 19). Fresh cheese is usually quickly perishable, so it takes "upotrebljivo do".
6. Juice and ajvar need an ingredient list. Rakija needs neither an ingredient list nor a nutrition declaration (Art. 16(4)), and no date for drinks of 10 % vol. or more (Annex X), but it needs the alcohol strength.
7. Do not claim that food treats or prevents disease, and do not suggest a composition the product does not have (Art. 7).

Where to go

• Inspektorat Republike Srpske (Inspectorate of Republika Srpska, Republička uprava za inspekcijske poslove), contact page: Područno odjeljenje Trebinje (regional office), Republike Srpske 33, tel. 059/273-080; Odsjek Bileća, Vladimira Gaćinovića 2, tel. 059/371-880. Ask for the food inspection.
• Agencija za sigurnost hrane Bosne i Hercegovine (Food Safety Agency of BiH) for the legal text and guidance.

What to check with the inspection

Batch or lot marking (letter "L" and a number) was required by the old rule 87/08. We did not find it in the text of 68/13, so check whether it applies to your product. "Small quantities" in Annex V is not defined by a number. Check special rules for juices, dairy products and rakija, and the registration requirements for your premises in Republika Srpska, before you sell. This text describes Rulebooks 68/13 and 85/12 as published on the Food Safety Agency website; ask the inspection about later amendments.

Laws and sources

• Pravilnik o pružanju informacija potrošačima o hrani ("Službeni glasnik BiH", broj 68/13), Art. 1, 6, 8, 9, 10, 12, 13, 15, 16, 17, 19, 21 to 26, Annexes II, III, V, X
• Pravilnik o voćnim džemovima, želeima, marmeladama, pekmezima i zaslađenom kesten pireu ("Službeni glasnik BiH", broj 85/12)
• Food Safety Agency brochure on implementing Rulebook 68/13