A Chinese domestic brand of cooking oil – Lvbao (meaning: emerald) sells a blend of olive oil and sunflower oil. The name of the product is – correctly – “Lvbao blend of olive oil and Sunflower oil” (绿宝食用调和油“橄榄+葵花调和油”).
The ingredient list reads: “squeezed sunflower oil, extra virgin olive oil”.
On this product, the CFDA issued notice n. 90/2018 on 1 February 2018 specifying that for this product – according to article 220.127.116.11 of GB 7718/2011 – it is necessary that the ingredient list specifies the percentage of sunflower oil and olive oil, as this label indeed “gives special emphasis on the presence of one or more valuable and/or characterizing ingredients or components”.
While the notice does not elaborate the specific elements that lead CFDA to identify on this packaging a “special emphasis” given to these ingredients, we believe that the following shall be taken into account:
- On front pack a picture of olives and sunflowers is displayed;
- On the back label the product is described as follows: “A perfect combination of extra virgin olive oil and high quality sunflower oil, which is easily absorbed by the human body”.
How would this be labelled under EU law, see 1169/EU/2011 annex VII