Food Labels and the Law

The Food Information to Consumers (FIC) Regulation has modified and consolidated existing food label provisions in the EU. It came into force in December 2014 with the exception of the nutritional data provisions which will apply from December 2016.

What information is required on a Food Label

Food label requirements are complex and vary from product to product. In the main, they only apply to pre-packaged foods and not to foods sold loose. There are also exemptions to certain rules if the foods are packed on the same site that they are sold from. There are certain basic requirements required on a food label:

• Food name – this may be one required by law (e.g. jam or butter) or a customary name (e.g. fish fingers or spaghetti). If neither of these apply, the name must be sufficiently precise to distinguish it from products with which it could be confused
• List of ingredients – in descending order, by weight
• Percentage quantity indication – only applies to certain ingredients (QUID declaration)
• Durability date – a ‘use by’, ‘best before’ or ‘best before end’ date
• Any special storage or use conditions – e.g. store refrigerated and use within two days of opening
• Name and address – of the manufacturer, packer or seller
• Place of origin – if its omission could mislead e.g. a French product with a Union Jack on the label
• Any instructions for use – if necessary to use the food e.g. cooking times and temperatures

Manner of food label presentation

This was a brief summary and there are specific rules about the details of each of these indications, and the manner in which they are presented, which also need to be followed. For example:
• Additive names or ‘E’ numbers must be preceded by the category name of the additive e.g. preservative or acidity regulator
• Certain information must be in the same field of vision on a label e.g. food name, quantity declaration and date marking

Product specific food label requirements

Certain products also have specific food label requirements. For example:
• Jam requires a fruit and sugar (soluble solids) content declaration
• Chocolate requires a percentage cocoa solids declaration
• Beef requires specific origin and traceability information

Additional information on food labels Other information is sometimes required. For example:
• EU specified allergenic ingredients must be indicated on the label
• Alcoholic drinks need to declare their strength (percentage – volume)
• Irradiated foods or ingredients must be indicated on the food label
• Genetically modified foods or ingredients must be declared
• Raw milk that has not been heat treated must have a warning on the food label

Food labelling claims
There are specific rules if particular claims are made. For example if foods are labelled as organic, natural or suitable for vegetarians.

Nutritional data on food labels
Unless claims such as slimming, low calorie or low fat are used, there is currently no legal requirement to give nutritional data on the food label.However from December 2016 this will be needed for most packaged foods. If you give nutritional information, either to comply with the regulations, or voluntarily, it must be in one of two prescribed formats.

Quantity marking
In the majority of cases, food must be labelled with a quantity (weight or volume) in metric.

Exemptions
There are special provisions for bread, flour confectionery, edible ices and cows’ milk which allow some labelling provisions to be reduced and/or displayed on notices.

About our food label services

Our experts can advise whether your food labels comply with both existing and planned food labelling regulations. We work with importers, manufacturers and retailers to avoid costly food withdrawals and to prevent legal action caused by food labels not meeting EU and UK laws. We also run food labelling training courses.

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