Food labelling and packaging for export and import
Food labelling standards 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.
Although weight is not part of food labelling law, most food labels are required to indicate the weight of the product inside the package. Restrictions limiting the range of sizes that all pre-packaged goods could be packed in (with the exception of wines and spirits) no longer apply. Although goods can now be packed in any size, producers may choose to continue using traditional standard pack sizes.
There are a number of regulations covering food claims:
- All claims made such as 'low fat' and 'helps maintain supple joints', must comply with European Commission (EC) Regulation No 1924/2006 on nutrition and health claims rules and be supported by scientific evidence. Claims must be on a permitted list and the product must meet set criteria. The Regulation also makes prescribed nutrition labelling compulsory on any product for which claims are made.
- You cannot claim food is 'healthy' or 'good for you' unless you can support it with approved evidence. If you add nutrition labelling you must use the prescribed format.
- Fortified food needs to comply with specific labelling requirements for foods with added vitamins or minerals.
- Fibre has specific definitions with which you must comply.
- Energy conversion factors apply when food manufacturers calculate values of fibre and erythritol (sweetener) for their products' energy declarations.
- There is legislation on the addition of vitamins and minerals and certain other substances to food. There are classifications for classifying herbal medicines, supplements, tonics for import and export.
- Claims for foods for specific groups and those with a specific nutritional function, including infant formula, follow-on formula and baby foods - must comply with special regulations.
- Medicinal claims for food are illegal - you must not claim that food can treat, prevent or cure any disease or medical condition.
Requirements around nutritional and health claims have changed from 1 January 2021.
Containers of raw milk should be marked 'This milk has not been heat-treated and may therefore contain organisms harmful to health'. Foods that consist of skimmed milk together with non-milk fat, or that can be used as milk substitutes, but are not intended for infants, should be prominently marked with a warning that they are not suitable for babies.
There are laws that indicate that food labelling should not mislead people about any aspect of a food product. This includes making false claims about its properties or suggesting that it has special characteristics when, in fact, all similar foods have those characteristics.
Fruit and vegetables
For fresh fruit and vegetables specific EC marketing and labelling standards now cover only these products:
- 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
Labelling required includes country of origin, packer name and address, quality class and for some products a size/count and/or a variety/type.
Many other fresh fruit and vegetables are covered by the EC general marketing standard and require country of origin labelling.
If you produce or sell fruit and vegetables which are subject to marketing standards, there may be changes to some of the processes you follow. Read about fresh fruit and vegetable marketing standards from 1 January 2021.
Format and placing of labelling information
Mandatory food information must be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It must not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material. Voluntary food information must not be displayed to the detriment of the space available for mandatory food information.
This information must be printed on the package or label legibly, in characters using a font size where the x-height is equal to or greater than 1.2mm.
In the case of packaging or containers, the largest surface of which has an area of less than 80cm2, the x-height of the font size must be equal to or greater than 0.9mm.
If food products are sold or transported in outer packaging, it should include the name of the food, its durability indication, storage conditions and details of the food business operator.
Labelling standards outside the EU
If you are exporting food outside the EU and intend to make it available for sale, you can contact the country's embassy (specifically the Commercial Attaché) in the UK for help with checking if there are export restrictions, and any special labelling or packaging requirements. There are restrictions on food exports to the USA. Traders must register with the US Food and Drug Administration and must operate through a US-registered agent.
Rules of origin for imported and exported goods are used to determine the national or territorial provenance of goods for trade purposes.