Every food label sold in the EU has to get a long list of details right at once. We review, correct and build labels that meet Regulation 1169/2011 and the rules layered on top of it.
Regulation (EU) No 1169/2011 on the provision of food information to consumers, generally known as the FIC Regulation, establishes the general principles, requirements and responsibilities governing food information, in particular food labelling, across the European Union. It has been in application since 13 December 2014, replacing and consolidating a number of earlier directives on general labelling, nutrition labelling and allergen declaration into a single framework.
The Regulation applies to food business operators at all stages of the food chain providing food information to consumers, including foods delivered by mass caterers such as restaurants, cafes and canteens, not only pre-packaged retail products. The nutrition declaration obligation has applied since 13 December 2016.
On top of the general FIC framework, several layers of category-specific rules apply: origin labelling for certain meats and other products, Implementing Regulation 2018/775 on primary ingredient origin, and category-specific changes such as Regulation 2021/2117's stricter rules for wine. Getting a label right means working through all of these layers, beyond the core Article 9 list alone.
For businesses operating in Great Britain, a retained version of Regulation 1169/2011 applies under UK law, with the EU version continuing to apply in Northern Ireland. The structure is closely aligned, but businesses trading across both markets need to track both versions separately.
Article 9 of Regulation 1169/2011 sets out the information that must appear on virtually every food label sold in the EU.
The legal or customary name, clear enough that the consumer understands what the product is.
All ingredients listed in descending order of weight at the time of use, including compound ingredients broken down where required.
All 14 substances listed in Annex II that are used or present, emphasised within the ingredient list through bold, underlining or similar.
Where an ingredient is emphasised in the name, on the label, or through images, its quantity must be declared as a percentage.
The net quantity of the food at the time of packaging, in the appropriate units.
The date of minimum durability, "best before", or the "use by" date for foods that are highly perishable from a microbiological point of view.
Any special storage conditions or conditions of use needed to ensure the food is consumed as intended and remains safe.
The name or business name and address of the food business operator responsible for the food information.
Required where its absence might mislead the consumer, and mandatory for certain products such as fresh, chilled and frozen meat of swine, sheep, goats and poultry.
Required where it would be difficult to make appropriate use of the food without them.
For beverages containing more than 1.2% alcohol by volume, the actual alcoholic strength must be declared.
Energy value and amounts of fat, saturates, carbohydrate, sugars, protein and salt, generally per 100g or 100ml, mandatory since December 2016.
All mandatory information must be legible, with a minimum font size of 1.2mm x-height for the smallest packages, in an official language of the country where the product is sold. For non-pre-packed products, such as from a bakery or butcher counter, simplified rules apply, but allergen information must always be available on request.
Under Annex II of Regulation 1169/2011, these 14 substances must be declared whenever present as an ingredient or processing aid, and must be emphasised within the ingredient list.
A 2023 systematic review covering 110 European studies found that roughly 1 in 8 people in Europe self-report a food allergy, which is part of why allergen emphasis within the ingredient list, beyond inclusion alone, is a specific legal requirement and not best practice alone. For non-prepacked foods sold by mass caterers, restaurants and similar businesses, the same 14 substances must be declared, though written allergen information can be provided on request instead of printed directly on a menu, depending on national implementation.
Origin labelling rules go beyond a simple "Product of" statement, and the rules on primary ingredient origin catch out more labels than businesses expect.
Under Article 26 of Regulation 1169/2011, the general rule is that indication of the country of origin or place of provenance is mandatory where its absence might mislead the consumer as to the true origin of the food, particularly where other information on the label, or the label as a whole, would otherwise imply a different origin. The Regulation also requires origin labelling for fresh, chilled and frozen meat of swine, sheep, goats and poultry, with application rules set out in Implementing Regulation 1337/2013.
Beyond these horizontal rules, mandatory origin provisions exist at EU level for specific products through vertical approaches, including honey, fruit and vegetables, fish, beef and beef products, and olive oil, each carrying its own requirements on top of the general FIC framework.
Article 26(3) addresses a more subtle issue: where the origin given for a food differs from the origin of its primary ingredient, the origin of the primary ingredient must be given, or at least indicated as different from the origin of the food. Commission Implementing Regulation 2018/775, applicable since 1 April 2020, clarifies how this information must be displayed. The classic example is a dairy product labelled with the flag or name of one country, where the milk used as the primary ingredient was sourced elsewhere. Without the Regulation 2018/775 clarification, this combination misleads the consumer about the primary ingredient's origin, even if the finished product genuinely was processed where shown.
A broader revision of the FIC Regulation has been in development since the 2020 Farm to Fork Strategy, though it has not yet been adopted.
The Farm to Fork Strategy, adopted in May 2020 as part of the European Green Deal, set out that the Commission would propose harmonised mandatory front-of-pack nutrition labelling to help consumers make informed, health-conscious choices, alongside related measures.
Harmonised mandatory front-of-pack nutrition labelling, with nutrient profiling criteria to restrict nutrition and health claims on foods high in fat, sugar or salt.
Extension of mandatory origin or provenance information to additional products, and revised rules on "use by" and "best before" date marking.
Following the Europe's Beating Cancer Plan, mandatory ingredient lists and nutrition declarations under consideration for all alcoholic beverages, building on the wine-specific changes already made under Regulation 2021/2117.
None of these changes have been adopted as binding law. The current mandatory particulars under Article 9, the allergen rules under Annex II, and the origin rules under Article 26 and Implementing Regulation 2018/775 remain exactly as they are. For businesses planning packaging changes for other reasons, such as a recipe update or rebrand, it can be worth designing labels with some flexibility for these proposed changes in mind, but no label currently needs reworking specifically because of the proposed revision.
Label compliance is a legal requirement for every food business placing product on the EU market, regardless of size.
Businesses needing a full Article 9 label specification built from scratch, including a calculated nutrition declaration.
Operations needing to confirm whether an ingredient or supplier change affects the allergen declaration, ingredient list order, or nutrition declaration.
Businesses bringing products into the EU needing labels reworked from another market's format into full Article 9 compliance, including origin labelling.
Businesses needing to assess whether Implementing Regulation 2018/775 applies where the displayed origin differs from the primary ingredient's origin.
Businesses needing to meet the ingredient list and nutrition declaration requirements introduced for wine under Regulation 2021/2117.
Mass caterers needing to meet allergen declaration obligations for non-prepacked food, even where full Article 9 labelling does not apply.
We cover the full scope of EU food labelling, from a single-product review to a full product-range relaunch.
A review of an existing label against the mandatory particulars required under Article 9 of Regulation 1169/2011, identifying gaps and producing a corrected label specification.
Review of ingredient lists and allergen declarations against the 14 substances in Annex II, including emphasis and presentation requirements.
Review of origin labelling under Article 26, including any vertical product-specific rules, and primary ingredient origin under Implementing Regulation 2018/775.
Calculation or recalculation of nutrition declarations against Articles 30 to 34, ensuring the declaration matches the current product formulation.
Development of a full Article 9 label specification for a new product, ready for handover to your packaging designer or printer.
Implementation of the ingredient list and nutrition declaration requirements introduced for wine under Regulation 2021/2117.
For businesses trading across the EU and Great Britain, management of the EU and UK retained versions of the FIC Regulation as separate but closely aligned tracks.
Development of allergen information systems for restaurants, cafes and caterers meeting non-prepacked food obligations.
Ongoing monitoring of the proposed FIC revision, with practical guidance issued once changes are adopted.
Our 1-on-1, TrustBite-recognised food labelling training courses build internal competency in allergen declaration, nutrition calculation, and how to spot when a recipe or supplier change requires a label review, alongside this consulting programme. Every session is private, customized to your products, and scheduled around your working hours.
Label work follows a defined sequence. Our part of the process typically takes a few days to a couple of weeks depending on scope. Printing and packaging changeover timelines are managed by you and outside our control.
| Stage | What happens | Our role | Duration |
|---|---|---|---|
| 1. Scope confirmation | The product range and applicable layers of regulation, general FIC, allergen, origin, category-specific, are confirmed. | We confirm scope and gather current labels, recipes and supplier information. | 1 day |
| 2. Label compliance review | Existing labels are reviewed against Article 9, Annex II, Article 26 and any category-specific rules. | We conduct the review and produce a findings report. | 2 to 3 days |
| 3. Nutrition declaration | Nutrition declarations are calculated or recalculated against current formulations. | We calculate the declaration based on recipe data you provide. | 1 to 2 days |
| 4. Corrected label specification | A corrected label specification is produced, ready for handover to design or print. | We produce the specification covering all mandatory particulars. | 2 to 3 days |
| 5. Design and print handover | The specification is handed to your designer or printer for implementation. | We remain available to answer questions during this stage. | 1 to 2 weeks |
| 6. Final check before print | The final design is checked against the specification before printing. | We review the final artwork against the specification. | 1 day |
| 7. Packaging changeover | New labels are introduced, with existing stock managed according to your own timeline. | We are available for queries during the changeover. | Managed by you |
Our label compliance review checks every mandatory particular against current product formulation, beyond the label as printed alone.
The review covers Article 9 mandatory particulars, allergen declaration and emphasis under Annex II, origin labelling under Article 26 including any applicable vertical rules, primary ingredient origin under Implementing Regulation 2018/775 where relevant, and the nutrition declaration under Articles 30 to 34.
A key part of the review is checking the label against the current recipe and supplier list, beyond checking it only against itself. Labels are often internally consistent, correct relative to an old recipe, while no longer matching the product following a formulation or supplier change.
We collect current labels alongside current recipes and supplier specifications for comparison.
We check each Article 9 element, allergen emphasis, and origin labelling against the current product.
We verify or recalculate the nutrition declaration against the current formulation.
We produce a findings report and, where needed, a corrected label specification.
For multi-product ranges, we can run this review across the full range in a single engagement, prioritising products with the most significant gaps first.
The same errors appear across EU food labels regardless of category. Knowing where they cluster is the most effective preparation.
A recipe change, supplier substitution, or formulation tweak that is not connected back to the label leaves the ingredient list, allergen declaration, or nutrition declaration out of date, even though the label was correct when first printed.
An allergen correctly listed among the ingredients, but not set apart through bold text, underlining, or a different typeface as Annex II requires, does not meet the emphasis requirement even though the information is technically present.
A nutrition declaration calculated for an earlier formulation, not updated following an ingredient change that alters the nutritional profile, presents inaccurate information even where the rest of the label is correct.
A label that displays one country's origin prominently, where the primary ingredient originates elsewhere, without the clarification required under Implementing Regulation 2018/775, creates a misleading impression even if production did take place where shown.
Net quantity, the food business operator's address, or other Article 9 particulars missing entirely, or printed below the 1.2mm minimum x-height, do not meet legibility requirements regardless of whether the information is technically present somewhere on the packaging.
Products subject to vertical origin rules, such as honey, olive oil, or beef, or category-specific rules such as the wine labelling changes under Regulation 2021/2117, sometimes have labels built against the general FIC framework alone, missing the category-specific layer.
Labelling sits alongside, but is distinct from, hygiene compliance and allergen management within the production process.
| EU food labelling | EU hygiene regulations | Allergen management | |
|---|---|---|---|
| What it covers | What the label says, how it's presented | How food is produced and handled | How allergens are controlled in production |
| Core regulation | 1169/2011 (FIC) | 852/2004, 853/2004 | Annex II of 1169/2011, plus 2021/382 |
| Connection point | Allergen declaration depends on production controls being accurate | Provides the prerequisite programmes allergen controls sit within | Feeds the allergen information that must appear on the label |
| Our consulting | EU Food Labelling | EU Hygiene Regulations | Allergen Management |
What drives the timeline and cost of an EU food labelling project. We provide a written proposal with a fixed fee after the initial consultation.
Timeline
How long our consulting work takes
Cost factors
What drives the consulting fee
A label compliance review for one product against current formulation. Our consulting work typically takes 2 to 3 days.
A full Article 9 specification built from scratch for a new product, including nutrition declaration calculation. Our consulting work typically takes 3 to 5 days.
A review across a multi-product range, identifying which products have the most significant gaps. Our consulting work typically takes 1 to 2 weeks depending on range size.
Where displayed origin and primary ingredient origin may differ, an assessment against Implementing Regulation 2018/775 adds a focused but defined scope.
Products subject to vertical origin rules or category-specific labelling, such as wine under Regulation 2021/2117, require additional review against those specific rules.
Businesses needing labels compliant in both the EU and Great Britain require management of both the EU and UK retained versions of the FIC Regulation.
A single-product review, a full range review, or an ongoing label management retainer each carry different fees. All scopes are defined in writing before work begins.
Design and printing costs for new packaging are separate from our consulting fees and are managed directly between you and your designer or printer.
Answers to the questions we hear most often from manufacturers, importers and caterers operating in the EU.
Regulation (EU) No 1169/2011, known as the Food Information to Consumers Regulation or FIC Regulation, establishes the general principles, requirements and responsibilities governing food information, in particular food labelling, across the European Union. It has been in application since 13 December 2014, with the obligation to provide nutrition information applying since 13 December 2016. It applies to food business operators at all stages of the food chain providing food information to consumers, including foods delivered by mass caterers, and consolidated and replaced a number of earlier directives on labelling, nutrition labelling and allergen declaration.
Article 9 of Regulation 1169/2011 sets out the mandatory particulars, which include the name of the food, the list of ingredients, all allergens used or present, the quantity of certain ingredients or categories of ingredients, the net quantity of the food, the date of minimum durability or use-by date, any special storage conditions or conditions of use, the name and address of the food business operator, the country of origin or place of provenance where required, instructions for use where necessary, the actual alcoholic strength for beverages above 1.2% alcohol by volume, and a nutrition declaration.
Annex II of Regulation 1169/2011 lists 14 substances that must be declared whenever present as an ingredient or processing aid, including cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphur dioxide and sulphites, lupin, and molluscs. These allergens must be emphasised within the ingredient list through means such as bold text, underlining, or a different typeface, so they stand out from the rest of the ingredients. For non-prepacked food, simplified rules apply, but allergen information must always be available to the consumer on request.
Under Article 26 of Regulation 1169/2011, indication of the country of origin or place of provenance is mandatory where failure to indicate this might mislead the consumer as to the true origin of the food, particularly where other information or the label as a whole would otherwise imply a different origin. The Regulation also requires origin labelling for fresh, chilled and frozen meat of swine, sheep, goats and poultry. Additional mandatory origin provisions exist at EU level for specific products including honey, fruit and vegetables, fish, beef and beef products, and olive oil.
Article 26(3) of Regulation 1169/2011 requires that where the origin of a food is given and differs from the origin of its primary ingredient, the origin of the primary ingredient must be given, or at least indicated as different from the origin of the food. Commission Implementing Regulation (EU) 2018/775 clarifies how this information must be displayed on labels, and has applied since 1 April 2020. This typically affects products such as a dairy product labelled with one country's flag or name where the milk used as the primary ingredient originates from a different country.
Following the Farm to Fork Strategy adopted in May 2020 as part of the European Green Deal, the European Commission has been developing a proposed revision of the FIC Regulation. The aims under consideration include harmonised mandatory front-of-pack nutrition labelling, nutrient profiling criteria to restrict nutrition and health claims on foods high in fat, sugar or salt, extension of mandatory origin or provenance information to additional products, revised rules on date marking for use-by and best-before dates, and, following the Europe's Beating Cancer Plan, mandatory ingredient lists and nutrition declarations for all alcoholic beverages. This revision has not yet been adopted, and current labelling requirements under Regulation 1169/2011 remain in force as they are.
Yes. Regulation (EU) 2021/2117 introduced stricter labelling requirements for wine, including mandatory ingredient lists and nutrition declarations, which previously were largely exempt from these Regulation 1169/2011 requirements. This reflects a broader pattern under the proposed FIC revision, which considers extending mandatory ingredient and nutrition labelling to all alcoholic beverages, not only wine.
An EU food labelling review checks an existing or proposed label against the mandatory particulars required under Article 9 of Regulation 1169/2011, including the legibility requirements such as the 1.2mm minimum font size for x-height, allergen declaration and emphasis under Annex II, origin labelling under Article 26 and, where relevant, Implementing Regulation 2018/775, and the nutrition declaration under Articles 30 to 34. It identifies any gaps or inaccuracies and produces a corrected label specification.
The most common EU food labelling errors are: labels not updated after a recipe or supplier change, leaving the ingredient list or allergen declaration out of date. Allergens present in the ingredient list but not emphasised through bold, underlining or a different typeface as required. Nutrition declarations that no longer match the current product formulation. Origin labelling that implies a different origin than the food's primary ingredient, without the clarification required under Implementing Regulation 2018/775. Mandatory particulars, such as net quantity or the food business operator's address, missing or below the minimum legibility requirements.
Our consulting work moves fast. A label compliance review for a single product typically takes a few days, while a full label redesign across a product range, including recalculated nutrition declarations, typically takes 1 to 2 weeks. Printing lead times and the timing of any packaging changeover are managed by you or your packaging supplier and are outside our control.
Yes. Label compliance reviews, allergen declaration checks, origin labelling review and nutrition declaration calculations are all available remotely. We work with clients across EU member states and businesses exporting into the EU from elsewhere.
You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.
To check a label against the information law of each market.
Read about A food label compliance review →For a deeper check of how allergens are declared.
Read about An allergen declaration review →Where claims appear on pack.
Read about A nutrition and claims review →To confirm every substance is permitted in your category.
Read about An ingredient and additive review →Tell us about your products, your current labels and your target markets. We will tell you exactly what Regulation 1169/2011 requires.