The rules set requirements for the label, not for inspection equipment; none of the documents below requires a camera. A label inspection system is one way to confirm, on every unit, that the label the rules require is on the pack, belongs to the product and can be read.
- R146, regulation 7(2): labels on pre-packaged foodstuffs must be applied so they cannot be separated from the container at the point of sale (R146 gazette copy). Presence and position checks catch missing and visibly loose labels; adhesion itself needs another test.
- R146, regulation 7(1)(b): the required information must be clearly visible, easily legible and indelible (R146 gazette copy). Print quality inspection covers the mandatory text areas.
- R146, regulation 43: common allergens are declared in brackets after the ingredient or in a “Contains:” statement (R146 gazette copy). The station can verify that the expected allergen text is printed for the product being run.
- Draft R3337 (April 2023, not in force): proposes allergens in bold (draft R3337). If it is finalised, whole ranges of artwork change at once, which is exactly when old and new labels get mixed up on the line.
- FSSC 22000 version 6, 2.5.9(c): line start-up and changeover controls (line clearance) must ensure that labels and packaging from the previous run have been removed from the line (FSSC 22000 Version 6).
- BRCGS guidance on online verification (Issue 8 FAQ, clause 6.2.4): a site that uses online label verification should challenge it with incorrect packs and test the detection, the reject or line stop and the no-read alarm (BRCGS Issue 8 FAQ). How we build that test into a station is described in the PLC and reject guide.
A consumer product recall South African suppliers carry out is notified to the National Consumer Commission, and its published recall notices include a case in which a food product was packed into the packaging of a different variant and its allergens were therefore not declared (NCC media statement). That is the fault a wrong-label check is designed to stop.