Food labelling and packaging for export and import
Food labelling in Northern Ireland and European Union
The EU law that continues to apply to Northern Ireland after 1 January 2021 is specified in Annex II to the Northern Ireland Protocol. Food and feed products produced in NI or placed on the NI market need to comply with EU food law.
Food labelling requirements are set out by law. Food destined for Northern Ireland must comply with national regulations as well as the EU regulations that apply to general and product-specific labelling. In Northern Ireland (NI), district councils enforce both national and international rules.
Goods imported into Northern Ireland from outside the European Union (EU) may be checked by the district council. Certain products are subject to specific checks at import.
Once your goods are on sale in shops or supermarkets, environmental health or trading standards officers are also likely to check them. If your imported products are in breach of labelling and packaging requirements, they may take action against you.
While the list below is compulsory for most imported foods, many types of food have extra requirements. For instance, traders must comply with the extra food labelling systems, such as health marks for meat.
Traders must also check additional requirements for their type of goods.
General labelling standards for NI and EU
Food labelling requirements for NI and EU fall under the EU Food Information to Consumers Regulation. Food sold to consumers or used in catering establishments must be marked with the following information:
- The name of the food. The law prescribes certain 'legal names', which must be used according to regulations, such as 'burger', 'sausage', 'jam', 'butter' and others. Otherwise, you may use a customary name, or one that consumers generally accept, such as 'Bakewell tart'. If no legal or customary name exists, you can use a descriptive name that clearly explains what the product is. Consideration must be given to any additional mandatory particulars which must accompany the name of the food, for example an indication of physical condition ie 'quick frozen', 'freeze dried', 'concentrated' and 'smoked'. You can find more details in Food Standards Agency's (FSA) guidance on the Food information Regulations 2014.
- A list of ingredients, usually in descending order of their weight at the time they were used to prepare the product. Ingredients should be listed using the same name as if they were sold as foods themselves. There are special rules for flavourings and functional additives such as preservatives and colours. Some foods, such as unprepared fresh fruit and vegetables, do not need to be listed as ingredients.
- The quantity of certain ingredients or categories of ingredients, usually the main ones or those used in the name. See below for details of the Quantitative Ingredient Declaration (QUID) rules that state the requirement to indicate the quantities of the main or key ingredients on the labels of food products sold in NI and the EU.
- The appropriate durability indication - the 'use by' date for highly perishable foods and the 'best before' date for other foods. 'Use by' dates are given in either day/month or day/month/year formats and indicate the date until which the food, if properly stored, is recommended for use. 'Best before' dates indicate the date until which the food will keep its properties if properly stored. Either give the date directly or indicate where it can be found, for example - 'Best before: see date on lid'. Some products, including fresh fruit and vegetables, and alcoholic drinks with an alcohol by volume (abv) strength above 10 per cent do not need to be labelled with a durability indication.
- Any special storage conditions and/or conditions of use. Special storage conditions might include, for example, 'store in a cool dry place', 'keep refrigerated', 'once opened, keep refrigerated and consume within 3 days'. Conditions of use might include, for example, 'not suitable for frying' or 'shake well before use'. The label should also indicate whether the food is suitable for home freezing and give instructions where required, such as 'freeze on day of purchase'.
- The name or business name and address of the food business operator.
- The place or country of origin (if failure to provide it might mislead the purchaser). Country of origin rules already exist in specific EU legislation for products such as pork, honey, fish.
- Additional requirements where applicable, including the abv of alcoholic drinks, an indication that packaging gases have been used (eg 'packaged in a protective atmosphere'), a warning of high caffeine content, labelling of sweeteners and glycyrrhizinic acid (a flavouring that masks bitterness) as well as lot or batch marking and weights and measures.
- Whether the food contains any of the following allergens - cereals containing gluten (including wheat, rye, barley and oats), crustaceans, molluscs, eggs, fish, peanuts, soybeans, lupin, milk, nuts, celery, mustard, sesame seeds, or sulphur dioxide and sulphites at more than 10 milligrams per kilogram or 10 milligrams per litre. The rules state that the allergen information must be emphasised in the ingredients list where one is used.
- Indication if the food is specially prepared for people with gluten intolerance. The claims 'gluten free' or 'very low gluten' have very specific meanings and can be used only on certain foods. 'Gluten free' means that the product contains 20 parts of gluten per million or less. 'Very low gluten' may be used only on those products which are manufactured using a special type of starch that has been treated to take out almost all of the gluten (products in this category will have a higher level of gluten in them of up to 100 parts per million).
- Whether it contains or consists of genetically modified organisms (GMOs), or contains ingredients produced from GMOs. However, you do not have to label foods with GM labelling if the food contains an accidental presence of GM material from sources authorised for use in the EU of 0.9 per cent or less.
- Whether it has or contains ingredients that have been irradiated.
- Instructions for use or cooking - these should be included whenever the consumer needs them in order to use the product as intended.
- The general labelling rules also outline requirements that labels on all food are indelible, clear and easy to read, as well as being easily understood by consumers.
Rules for specific foods
As well as wine and spirits, specific labelling rules apply to these other foods, for example:
- bread and flour
- cocoa and chocolate
- instant coffee
- evaporated and dried milk
- fruit juice
- infant formula
- meat products: sausages, burgers and pies
- natural mineral waters
- spreadable fats
- food for specific groups/specific medical purposes (FSMPs), such as infant formula, baby foods, foods suitable for coeliacs (eg gluten-free and very low gluten)
QUID rules refer to Quantitative Ingredient Declarations - the labelling requirement to indicate the quantities of principal or main ingredients for food products sold in the EU. Declarations are required for:
- Ingredients that form part of the name of the food, or that are usually associated with the food by consumers. For example, a product called 'steak and kidney pie' would need to indicate how much steak and kidney was in the product, while a 'fish pie' would need to indicate how much fish was included.
- Ingredients that are emphasised on the labelling, whether in words or with pictures. For example, a product label that stated 'made with real cream' would require a QUID declaration for the cream.
- Some products of animal origin, including meat content for meat products sold loose and not pre-packed (such as butcher's sausages). For example, pork sausages would require a QUID declaration of the percentage of pork content.
You do not need a QUID declaration if the quantity of the ingredient has to be listed anyway under EU legislation, or if the ingredient is used in a small quantity, for example as a flavouring. For example, 'garlic bread' does not need to state the quantity of garlic.
QUID declarations are given as percentages, rounded to the nearest whole number, or to the nearest 0.5 if the proportion is below 5 per cent. The percentage is calculated by dividing the weight of the ingredient by the weight of all the ingredients included in the product. As far as possible, the declaration should reflect the amount of the ingredient at the time the food is prepared by the purchaser of the product.
The declaration should appear either next to the name of the food product, or in the list of ingredients at the relevant point.
Mandatory nutrition declarations
Mandatory nutrition declarations (back of pack labelling) apply to most prepacked foods. This means that if you sell prepacked foods then you must provide nutrition information on the package or label. This relates to the mandatory nutrition panel on food packaging, which requires:
- the energy value (displayed as kJ/kcal)
- amounts of fat, saturates, carbohydrate, sugars, protein and salt provided per 100g or per 100ml.
Organic products have specific marking rules.
European Community general marketing standard require most fruit and vegetables to be labelled with their country of origin. European Community specific marketing standards requires the following products to be labelled with country of origin, packer name and address, quality class and in some instances size/count and variety:
- fruits - apples, citrus fruit, kiwi fruit, peaches and nectarines, pears, strawberries, and table grapes
- vegetables and salads - lettuces, curly and broad-leaved endives, sweet peppers and tomatoes
Specific EC marketing and labelling standards also apply to:
- canned sardines and tuna
- olive oil
- eggs in their shell
- foods with protected names, such as Yorkshire Forced Rhubarb and West Country Cheddar
Materials and articles in contact with food need to be marked 'Not suitable for food use' if they are not meant for human consumption. Find out more about food packaging safety regulations.
Food colouring warnings
If you are still using one or more of six food colourings being voluntarily phased out, you must, with a few exceptions, include a warning on products. In addition to the standard required information, labels must also have a warning using the following wording: 'the name or E number of the colour(s)' may have an adverse effect on activity and attention in children'. The colours are:
- sunset yellow (E 110)
- quinoline yellow (E 104)
- carmoisine (E 122)
- allura red (E 129)
- tartrazine (E 102)
- ponceau 4R (E 124)
Read about the rules regarding food additives.