4. Labeling Requirements

General Foods
EU

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

4.1 Mandatory Labeling Parameters

Requirements set by Article 7 Regulation EU 1169/2011 [1] fully apply in terms of labeling. Other specific EU and/or national provisions may apply depending on the target food/beverage.

Food sold to consumers

Indication of the following particulars is mandatory [1]:

a) The name of the food (Art 17) - The name of the food shall be its legal name. In the absence of such a name, the name of the food shall be its customary name.

b) The list of ingredients (Art 18) - The list of ingredients shall be headed or preceded by a suitable heading that consists of or includes the word ‘ingredients’. It shall include all the ingredients of the food, in descending order of weight, as recorded at the time of their use in the manufacture of the food. Ingredients shall be designated by their specific name, where applicable, in accordance with the rules laid down in Article 17 and Annex VI (laying down provisions regarding the name of the food and specific accompanying particulars). Specific rules regarding the indication and designation of ingredients are laid down in Anne VII. See also ANNEX VII of the FIC Regulation. Among the exemptions for providing an ingredient list (Article 19): ‘’Cheese’’ made of lactic products, food enzymes, micro-organism cultures, and salt (except fresh cheese and processed cheese) essential to manufacture.

c) Allergens (Art 21) - Any ingredient or processing aid listed in Annex II of the Regulation or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of food and still present in the finished product, even if in an altered form shall be emphasized through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background color. 

ANNEX II - SUBSTANCES OR PRODUCTS CAUSING ALLERGIES OR INTOLERANCES

1. Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof, except:
   1. wheat-based glucose syrups including dextrose*;
   2. wheat-based maltodextrins*;
   3. glucose syrups based on barley;
   4. cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin;
2. Crustaceans and products thereof;
3. Eggs and products thereof;
4. Fish and products thereof, except:
   1. fish gelatine used as a carrier for vitamin or carotenoid preparations;
   2. fish gelatine or Isinglass used as a fining agent in beer and wine;
5. Peanuts and products thereof;
6. Soybeans and products thereof, except:
   1. fully refined soybean oil and fat*;
   2. natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soybean sources;
   3. vegetable oils derived phytosterols and phytosterol esters from soybean sources;
   4. plant stanol ester produced from vegetable oil sterols from soybean sources;
7. Milk and products thereof (including lactose), except:
   1. whey used for making alcoholic distillates including ethyl alcohol of agricultural origin;
   2. lactitol;
8. Nuts, namely: almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoinensis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia), and products thereof, except for nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin;
9. Celery and products thereof
10. Mustard and products thereof;
11. Sesame seeds and products thereof;
12. Sulfur dioxide and sulfites at concentrations of more than 10 mg/kg or 10 mg/liter in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers;
13. Lupin and products thereof;
14. Molluscs and products thereof.

*And the products thereof, in so far as the process that they have undergone is not likely to increase the level of allergenicity assessed by the Authority for the relevant product from which they originated.

d) The quantity of certain ingredients or categories of ingredients (Art 22) shall be required where the ingredient or category of ingredients concerned: appears in the name of the food or is usually associated with that name by the consumer; is emphasized on the labeling in words, pictures or graphics; or is essential to characterize a food and to distinguish it from products with which it might be confused because of its name or appearance. See also Annex VIII.

e) The net quantity of the food (Art 23) shall be expressed using liters, centiliters, milliliters, kilograms, or grams, as appropriate. See also Annex IX.

f) The date of minimum durability or the ‘use by’ date (Art 24). Specificities about how to declare this date are described in Annex X of the Regulation.

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

(h) The name and address of the food business operator, i.e. the operator under whose name or business name the food is marketed or, if that operator is not established in the Union, the importer into the Union market (Art 8).

(i) The country of origin or place of provenance, where failure to indicate this might mislead the consumer as to the true country of origin or place of provenance of the food (Art 26). See also Annex XI. Where the origin of a food is given and is different from the one of its primary ingredient, the origin of the primary ingredient shall be given or at least indicated as being different from the origin of the food.

(j) Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions (Art 27).

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

(l) A nutrition declaration (Art 29 - 36), except for food supplements and mineral waters which gave their own Nutrition declaration provisions. Mandatory nutrition declaration must include all the following particulars (Art 30): energy value and the amounts of fat, saturates, carbohydrates, sugars, protein, and salt. The declaration may be supplemented with an indication of the amount of mono-unsaturated, polyunsaturates, polyols, starch, fiber, or any vitamins or minerals present in significant amounts (as described in points 1 and 2 respectively of Part A of Annex XII of the Regulation).

• The energy value (calculated using the conversion factors listed in Annex XIV) and the amounts of nutrients shall be those of the food as sold. Where appropriate, the information may relate to the food after preparation, provided that sufficiently detailed preparation instructions are given and the information relates to the food as prepared for consumption (Art 31.3).  
• The energy value and the amount of nutrients shall be expressed per 100 g or per 100 ml using the measurement units listed in Annex XV.
• Vitamins and minerals shall be expressed as a percentage of the reference intakes (RI). 
• The energy value and the amounts of fat, saturates, sugars, and salt may be too (RIs are defined in Part A of Annex XIII). In the case of the later, the following additional statement shall be indicated in close proximity to it: ‘Reference intake of an average adult (8 400 kJ/2 000 kcal)’.
• In addition to (in some cases: instead of) the expression per 100g or 100ml, the energy value and the amounts of nutrients may be expressed per portion and/or per consumption unit, easily recognizable by the consumer, provided that the portion or the unit used is quantified on the label and that the number of portions or units contained in the package is stated.

GMO Labeling

Final consumer packaging or pre-packaged products containing GMOs should be labeled: ‘This product contains genetically modified organisms’ or ‘This product contains genetically modified [name of organism(s)]’ [2].

This requirement does not apply to products containing traces of authorized GMOs in a proportion no higher than 0,9% or lower thresholds established under the provisions of Article 30(2), provided that these traces are adventitious or technically unavoidable [3].

In order to establish that the presence of this material is adventitious or technically unavoidable, operators must be in a position to supply evidence to satisfy the competent authorities that they have taken appropriate steps to avoid the presence of such material.

Finally, in addition to the labeling requirements referred to above, the labeling shall also mention any characteristic or property, as specified in the authorization, in the following cases (Article 13.3 of Regulation 1829/2003 [3]):

(a) where a food is different from its conventional counterpart as regards the following characteristics or properties:

1. composition;
2. nutritional value or nutritional effects;
3. intended use of the food;
4. implications for the health of certain sections of the population;

(b) where a food may give rise to ethical or religious concerns.

In addition, the labeling of foods falling within the scope of this Section that do not have a conventional counterpart shall contain appropriate information about the nature and the characteristics of the foods concerned.

Irradiated food/ingredients 

In the case of products intended for the ultimate consumer and mass caterers:

1. if the products are sold as items, the words ‘irradiated’ or ‘treated with ionizing radiation’ shall appear on the label.
2. if an irradiated product is used as an ingredient, the same words shall accompany its designation in the list of ingredients.
3. the same words shall be required in order to indicate the irradiated ingredients used in compound ingredients in foodstuffs, even if these constitute less than 25 % of the finished product.

The indication of treatment shall in all cases be given on the documents which accompany or refer to irradiated foodstuffs.

4.2 Languages

According to Article 15 of Regulation (EU) 1169/2011 [1], mandatory food information shall appear in a language easily understood by the consumers of the Member States where a food is marketed.

Within their own territory, the Member States in which a food is marketed may stipulate that the particulars shall be given in one or more languages from among the official languages of the Union.

4.3 Mandatory Information on Stickers

Mandatory information on stickers is acceptable - Article13 [1]: all mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.

4.4 Product Legal Name

N/A (please refer to Section 4.4 of product-specific guidebooks).

4.5 Product-specific Labeling Statements

N/A (please refer to Section 4.5 of product-specific guidebooks).

4.6 Authority Approval

In general, label approval is not provided at the EU level. For some specific food categories, a registration process may be requested at the national level and it may include a label assessment by the authority.

4.7 Additional Notes on Labeling

Presentation of mandatory particulars [1]

• Mandatory food information shall appear directly on the package or on a label attached thereto. (Art 12.2)
• Mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible, and, where appropriate, indelible. (Art 13.1)
• The mandatory particulars shall be printed on the package or on the label in such a way as to ensure clear legibility, in characters using a font size where the x-height, as defined in Annex IV, is equal to or greater than 1,2 mm. (Art 13.2)

Voluntary information [1]

Business operators can include as much voluntary information as they want, provided it is not false or misleading (Art 36); however, they cannot do so at the expense of mandatory information. 

Labeling of Organic food [4]

Only products satisfying the requirements set out in the Regulation may be labeled as organic or any other term listed in various languages in the Annex such as “bio” or “eco” (Art 23) or use the Community organic production logo (Art 25) [4].

Process foods can be labeled with the term “organic” or a similar term provided they comply with the requirements set out in the Regulation and at least 95% by weight of their ingredients of agricultural origin are organic.

Mandatory indication

1. The label of Organic food must bear:

1. the code number of the control authority or control body to which the operator that carried out the last production or preparation operation is subject; and
2. in the case of prepacked food, the organic production logo of the European Union shall also appear on the packaging (except in cases referred to in Article 30(3) and points (b) and (c) of Article 30(5)).

2. Where the organic production logo of the European Union is used, an indication of the place where the agricultural raw materials of which the product is composed have been farmed shall appear in the same visual field as the logo and shall take one of the following forms, as appropriate:

1. ‘EU Agriculture’, where the agricultural raw material has been farmed in the Union;
2. ‘non-EU Agriculture’, where the agricultural raw material has been farmed in third countries;
3. ‘EU/non-EU Agriculture’, where a part of the agricultural raw materials has been farmed in the Union and a part of it has been farmed in a third country.

For the purposes of the first subparagraph, the word ‘Agriculture’ may be replaced by ‘Aquaculture’ where appropriate, and the words ‘EU’ and ‘non-EU’ may be replaced or supplemented by the name of a country, or by the name of a country and a region, if all of the agricultural raw materials of which the product is composed have been farmed in that country and, if applicable, in that region.

For the indication of the place where the agricultural raw materials of which the product is composed have been farmed, as referred to in the first and third subparagraphs, small quantities by weight of ingredients may be disregarded, provided that the total quantity of the disregarded ingredients does not exceed 5% of the total quantity by weight of agricultural raw materials.

The words ‘EU’ or ‘non-EU’ shall not appear in a color, size, or style of lettering that is more prominent than the name of the product.

Organic production logo of the European Union

1. The organic production logo of the European Union may be used in the labeling, presentation, and advertising of products that comply with this Regulation.

3. The use of the organic production logo of the European Union shall be optional for products imported from third countries.
4. The organic production logo of the European Union shall comply with the model below (may also be used in black and white):

5. National logos and private logos may be used in the labeling, presentation, and advertising of products that comply with this Regulation.

Code numbers: The general format of the code numbers shall be as follows: AB-CDE-999.

Further details on the requirements for the logo and the code are laid down in Annex V of the organic food regulation [4].

Labeling Relating to Recycling

In the EU, the general principles are laid down for recycling. However, each member state will have variations and different logos/messages and names for their recycling schemes. While specific logos may vary, the overarching message of each recycling scheme is to promote sustainable waste management practices and encourage citizens to participate in recycling efforts to protect the environment.  

Labeling of Halal, Kosher, Vegan

No rules are defined in legislation at the EU level for such labeling.

Labeling of products with protected geographical indication 

Geographical indications are regulated and controlled (for legal name, see Section 4.4 above). In addition, to the general labeling rules, some specific labeling requirements apply, including mandatory logos and indications for EU schemes “Protected designation of origin” (PDO) and “Protected geographical indication” (PGI) are established by Regulation (EU) 2024/1143 [5]. Furthermore, additional specific labeling provisions may be set by the related product specifications.  

Note: Non-EU food can have protected geographical indication, such as Scotch Whisky.

4.8 References

1. Regulation 1169/2011 of the European Parliament and of the Council of 25 October 2011

https://eur-lex.europa.eu/eli/reg/2011/1169/oj

2. Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R1308

3. Regulation (EU) 2019/787 of the European Parliament and of the Council of 17 April 2019 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019R0787

4. Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32018R0848

5. Regulation (EU) 2024/1143 of the European Parliament and of The Council of 11 April 2024 

http://data.europa.eu/eli/reg/2024/1143/oj