4. Labeling Requirements

General Foods
United Kingdom (UK)

This section provides information on labeling requirements and the label approval process.

Restrictions for Sale – Pre-Packaged Supplements

A food supplement shall be regarded as prepacked for the purpose of these regulations if:

1. It is ready for sale to the ultimate consumer or to a catering establishment, and
2. It is put into packaging before being offered for sale in such a way that the food supplement cannot be altered without opening or changing the packaging

No person shall sell any food supplement to the ultimate consumer unless it is prepacked.

4.1 Mandatory Labeling Parameters

Indication of the following particulars is mandatory [1]:

A) The name of the food (Art 17)

The name of the supplement should be the name of the category of any vitamin or mineral or other substance with a nutritional or physiological effect that characterizes the product or an indication of the nature of that vitamin or mineral or other substance. This descriptive product name must be provided to qualify the legal name [2].

The name of the supplement must be in the same field of vision as the net quantity.

B) The list of ingredients (Art 18) [1]

The category "Food Supplements" should comply with the mandatory labeling parameters for the list of ingredients explained in Section 4.1 of the "General Foods" guidebook for the UK. Additionally, the below applies:

When listing the permitted vitamins and minerals in the ingredient list, the forms of these micronutrients can be added on a voluntary basis.

C) Allergens (Art 21) [1]

The category "Food Supplements" should comply with the mandatory labeling parameters for allergens explained in Section 4.1 of the "General Foods" guidebook for the UK.

D) The quantity of certain ingredients or categories of ingredients (Art 22) [1]

The category "Food Supplements" should comply with the mandatory labeling parameters for certain ingredients or categories of ingredients explained in Section 4.1 of the "General Foods" guidebook for the UK.

E) The net quantity of the food (Art 23)

The category "Food Supplements" should comply with the mandatory labeling parameters for the net quantity of the food explained in Section 4.1 of the "General Foods" guidebook for the UK.

F) The date of minimum durability or the ‘use by’ date (Art 24)

The category "Food Supplements" should comply with the mandatory labeling parameters for the 'use by date' explained in Section 4.1 of the "General Foods" guidebook for the UK.

G) Any special storage conditions and/or conditions of use (Art 25) where appropriate.

The category "Food Supplements" should comply with the mandatory labeling parameters for any special storage conditions as explained in Section 4.1 of the "General Foods" guidebook for the UK.

H) The name and address of the food business operator

The category "Food Supplements" should comply with the mandatory labeling parameters as explained in Section 4.1 of the "General Foods" guidebook for the UK.

I) The country of origin or place of provenance

The category "Food Supplements" should comply with the mandatory labeling parameters as explained in Section 4.1 of the "General Foods" guidebook for the UK.

J) Instructions for use

The category "Food Supplements" should comply with the mandatory labeling parameters as explained in Section 4.1 of the "General Foods" guidebook for the UK.

K) The actual alcoholic strength by volume for beverages containing more than 1,2% by volume of alcohol (Art 28).

N/A

L) A nutrition declaration

The mandatory nutrition labeling of energy, fat, saturates, carbohydrates, sugars, protein, salt) is not required for supplements (Article 29 FIC 2011). A header is still required (Nutrition Information).

Rounding rules are to be followed for each nutrient declaration [3]:

How to work out significant numbers:

Example:

GMO labeling

The category "Food Supplements" should comply with the mandatory labeling parameters for GMOs as explained in Section 4.1 of the "General Foods" guidebook for the UK.

Plant Sterols and Stanols

The category "Food Supplements" should comply with the mandatory labeling parameters for Plant Sterols and Stanols as explained in Section 4.1 of the "General Foods" guidebook for the UK. 

Characteristics

The category "Food Supplements" should comply with the mandatory labeling parameters for additional characteristics as explained in Section 4.1 of the "General Foods" guidebook for the UK.

Irradiated food/ingredients [4]

The category "Food Supplements" should comply with the mandatory labeling parameters for irradiated food/ingredients as explained in Section 4.1 of the "General Foods" guidebook for the UK.

4.2 Languages

The category "Food Supplements" should comply with the mandatory language labeling requirements as explained in Section 4.2 of the "General Foods" guidebook for the UK.

4.3 Mandatory Information on Stickers

The category "Food Supplements" should comply with the requirements outlined in Section 4.3 of the "General Foods" guidebook for the UK.

4.4 Product Legal Name

The legal product name, the term ‘Food Supplement’, must be declared on the label [2].

4.5 Product-specific Labeling Statements

Other Mandatory Labeling for Food Supplements (The Food Supplements Regulations 2003)[2]

1. The name of the supplement as mentioned above should be the descriptive name of the product. 
2. The portion of the product recommended for daily consumption. This states the frequency of the dose to be taken throughout the day, how often it is to be taken, the method of consumption, and the time of day to take it.
3. A warning statement to not exceed the stated recommended dose. 
4. A statement to the effect that food supplements should not be used as a substitute for a varied diet.
5. A statement to the effect that the product should be stored out of reach of young children.
6. The amount (in numerical form) of any vitamin or mineral or other substance with a nutritional or physiological effect that is present in the product.

Advisory Statements

Excessive intake of vitamins and minerals may result in adverse effects and therefore necessitate the setting of maximum safe levels for them in food supplements, as appropriate. Those levels must ensure that the normal use of the products under the instructions of use provided by the manufacturer will be safe for the consumer [2].

Advisory Statements are available for the following nutrients:

• Vitamin C
• Iron
• Calcium
• Magnesium
• Nickel
• Beta-carotene
• Nicotinic Acid
• Zinc
• Manganese
• Phosphorus
• Vitamin B6
• Vitamin A

The list of advisory statements can be found in the Annex to the document Food Supplements Label advisory statements and suggested reformulations [5].

4.6 Authority Approval

N/A

4.7 Additional Notes on Labeling

Presentation of mandatory particulars [1]

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

Voluntary information [1]

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

Labeling of Organic food 

The category "Food Supplements" should comply with the EU Organic labeling requirements as explained in Section 4.7 of the "General Foods" guidebook for the UK. Additionally, the below applies:

On 1^st January 2022, this was the beginning of the TCA (Trade Cooperation Agreement) Equivalency Terms for:

• EU to GB Imported Products
• GB to EU Exported Products
• GB to EU (NI) Exported Products

On 31^st December 2023, there will be a review of the equivalency terms. If an agreement is not in place, the current terms will be suspended. 

The current TCA Terms: Products that have undergone final processing in the UK/EU and have Organic Certification are accepted for sale in the UK/EU markets as Organic [6].

GB to EU Origin requirements

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

Organic Labeling Requirements for the UK

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

UK Statement of Agricultural Origin (when produced and sold in the UK)

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

Labeling relating to recycling

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

Labeling of Halal, Kosher, Vegan, etc.

Please refer to Section 4.7 of the "General Foods" guidebook for the UK.

4.8 References

1. Regulation 1169/2011 on the provision of food information to consumers

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02011R1169-20180101

2. Directive 2002/46/EC Article 2 / The food supplements (England) Regulations 2003

https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32002L0046

https://www.legislation.gov.uk/uksi/2003/1387/contents/made 

3. Source: Guidance Document for competent authorities for the control of compliance with EU legislation on regulation (EU) 1169/2011

https://food.ec.europa.eu/system/files/2016-10/labelling_nutrition-vitamins_minerals-guidance_tolerances_1212_en.pdf 

4. Consolidated Regulation (EC) No 1830/2003 of the European Parliament and of the Council of 22 September 2003 concerning the traceability and labeling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02003R1830-20190726&from=EN 

5. Department of Health: Label Advisory Statements and suggested reformulations

https://assets.publishing.service.gov.uk/media/5a7c4017ed915d7d70d1d961/Advisory_Statements_DH_FINAL.pdf 

6. Trade and cooperation agreement between UK and EU – CP 426 (publishing.services.gov.uk)

https://assets.publishing.service.gov.uk/media/608ae0c0d3bf7f0136332887/TS_8.2021_UK_EU_EAEC_Trade_and_Cooperation_Agreement.pdf 

https://commission.europa.eu/strategy-and-policy/relations-non-eu-countries/relations-united-kingdom/eu-uk-trade-and-cooperation-agreement_en#:~:text=The%20Trade%20and%20Cooperation%20Agreement%20establishes%20a%20new%20framework%20for,cross%2Dborder%20crime%20and%20terrorism.