Labelling food products
An introduction for food businesses to the UK and European Union regulations on food labelling
Food labels provide useful information to inform and protect consumers. The Food Standards Agency's (FSA) work on labelling helps ensure that consumers get the information they need in a way they understand.
There are various UK and European Union regulations on food labelling.
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. See the latest EU Exit guidance for the food and drink sector.
Dishonest labelling and misdescription
Legislation and regulations to prevent mislabelling or misdescription of foods, and examples of misdescription
Consumers have a right to expect that food matches the description on the label. Deliberate mislabelling is fraud and a criminal offence.
There are several laws to prevent dishonest labelling and misdescription, including:
- Food Safety Order
- Consumer Protection from Unfair Trading Regulations
- General Food Regulations
- Food Information Regulations
The description of food includes any of the following information:
- its name
- its ingredients
- its origin
- the processes it has undergone
The misdescription of food deceives consumers. It can trick people into buying something they would not otherwise buy. It poses serious risks to people intolerant or allergic to certain foods. It also leads to unfair competition.
Examples of food misdescription
Some examples of food misdescription include:
- Using a legal name for a food without the correct composition. For example, food sold as chocolate must have a certain amount of cocoa solids. Even if there are no composition rules for a food, such as fish fingers, it still must be described accurately.
- Extending a food - eg, adding offal to meat products without declaring it.
- Incorrectly labelling the true origin of a food or its ingredients in terms of animal species, plant variety, geographical origin or country.
- Incorrectly describing, or failing to describe, a process or treatment - such as not declaring irradiated food.
- Incorrectly stating the amount of an ingredient.
Read more about preventing and reporting food crime.
Suspicions or information about food crime in Northern Ireland should be reported to FSA by emailing firstname.lastname@example.org or by contacting FSA on 028 9041 7700 and asking to speak with the Food Fraud Liaison Officer.
Legal requirements for food labels
An overview of the rules that apply to food labelling
For most prepacked foods, you must provide on their label the following details:
- the name of the food
- an ingredients list
- information on certain foods causing allergies or intolerances that were used in the manufacture or preparation of a food
- the quantity of certain ingredients
- the net quantity of the food
- a date of minimum durability or 'use by' date
- any special storage conditions and/or conditions of use
- the name or business name and address of the food business operator under whose name the food is being marketed (or the importer in some cases)
- the country of origin or place of provenance of the food (if required)
- instructions for use
- the alcoholic strength by volume
- a nutrition declaration - see more on nutrition labelling
From 1 October 2021, the way food businesses must provide allergen labelling information for prepacked for direct sale (PPDS) food will change. For more information, see new allergen labelling rules and read the updated food allergen labelling and information: technical guidance.
Read also about food allergen labelling.
What is prepacked food?
'Prepacked' means any food put into packaging before being offered for sale. For example a bar of chocolate, a sealed packed of crisps, a jar of sauce or a can of soup. All the following must apply:
- the packaging fully or partly encloses the food
- the food cannot be altered without opening or changing the packaging
- the product is ready for sale to the final customer or mass caterer
Find out more about the prepacked for direct sale food.
Food allergen labelling
Important allergens to consider when labelling food, and what to do if cross-contamination is unavoidable
The Food Information for Consumers Regulation names 14 substances or products which you must emphasise in ingredients lists. This is because these substances can cause allergic or intolerance responses. The rules apply to anything made from the 14 allergens (except in the case of sulphur dioxide and sulphites).
The 14 allergens are:
- cereals containing gluten (namely: wheat, rye, barley, oats, spelt, kamut or their hybridised strains)
- tree nuts (namely: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts)
- sesame seeds
- sulphur dioxide and sulphites when the concentration of total sulphur dioxide in the whole prepared food is above 10mg/kg or 10mg/litre
You must include and emphasise the names of any of the above allergens in the ingredients list. You can do this by using bold text or by making the allergen stand out from the other ingredients in some way.
If there is no ingredients list, you should include a 'contains...' statement. You don't need to include additional information if you have referred to the allergen in the name of the food.
If you want to include an allergy advice box, you can refer the consumers to the ingredients list, but you must not repeat the allergens.
If an allergen is not intentionally used, but there is a risk of cross-contamination (eg if the product is made in a factory that processes peanuts), you may include a 'may contain...' statement. However this is not a legal requirement. You should only use precautionary allergen labelling when you have determined the risk of allergen cross-contamination is real and you cannot remove it.
The rules do not apply to some allergen derivatives, such as wheat-based glucose syrups and fully refined soybean oil. Otherwise there are no exemptions.
There are specific laws about claims that a food is 'gluten-free' or 'very low gluten'. Gluten-free foods can have no more than 20ppm gluten.
You may label foods containing ingredients that have been processed to reduce their gluten content as 'very low gluten' when they contain no more than 100ppm gluten.
Allergen information on loose foods
Loose foods include everything that is not prepacked, for example from a delicatessen counter, fresh pizza, fish, salad bars and bread in bakery shops. In a catering environment, this applies to ready-to-eat foods such as meals in a restaurant, café or takeaway.
Rules for declaring allergens in loose foods:
- You must provide information about the allergens used in these foods.
- You must make allergen information available in writing or by speaking to staff. If you are not providing this information in writing, clearly signpost to where consumers can find this information.
- You can use logos or symbols when accompanied by words and numbers on menus
For loose foods allergen information has to be:
- easily accessible to all consumers
- accurate, consistent and verifiable
For more information, download allergen information for loose foods - advice on the food information regulations (PDF, 1.87 MB).
Allergen information on Prepacked for Direct Sale (PPDS) food
From 1 October 2021, the way food businesses must provide allergen labelling information for PPDS food will change. PPDS food is considered food that has been packed on the same premises from which they are being sold. Examples of PPDS food include meat pies made on site and sandwiches made and sold from the premises in which they are made.
Currently, the law does not require PPDS food to carry allergen information on the packaging. From 1 October 2021, PPDS food will need to have a label with a full ingredients list with allergenic ingredients emphasised within it.
According to the new rules, PPDS food will have to clearly display the following information on the packaging:
- name of the food
- full ingredients list
- allergenic ingredients emphasised (for example in bold, italics or a different colour)
For more information, see new allergen labelling rules and read the updated food allergen labelling and information: technical guidance.
What to consider when putting nutritional information on food labels
You must provide a mandatory nutrition declaration for most prepacked foods. This is commonly known as 'back of pack' nutrition labelling. You must give the declaration in the following order:
You may also include certain additional 'supplementary' nutrients in the nutrition declaration. You may only include the following additional nutrients:
- monounsaturated fat
- polyunsaturated fat
- certain vitamins or minerals present in significant amounts as outlined in relevant regulations
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, including the law on food labelling. See the latest EU Exit guidance for the food and drink sector and read about nutrition-related labelling, composition and standards from 1 January 2021.
Claims about nutritional and health content
The rules that you must follow when making nutritional or health claims for food and where to find further guidance
Nutritional claims suggest that food products have beneficial nutritional properties. They include statements such as:
- low fat
- source of calcium
- high fibre
- reduced salt
- no added sugar
Health claims suggest a connection between food and health. They include statements like:
- good for you
- calcium helps maintain normal bones
- keeps you feeling fuller for longer
- helps improve concentration
Rules for nutritional and health claims
If you want to make nutrition or health claims for your foods you there is specific legislation you must comply with. This legislation requires claims to be authorised. This makes it easier to identify nutrition and health claims that you can justifiably use on a specific product. It is designed to:
- protect consumers from misleading or false claims
- harmonise rules across the different countries making it easier to trade
The regulation lists the claims that you can make for foods and the criteria your product must meet before you can make them.
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, including the law on nutritional and health claims. See the latest EU Exit guidance for the food and drink sector and read about nutrition-related labelling, composition and standards from 1 January 2021.
Front of pack labelling
Voluntary front-of-pack signposting and criteria for deciding on the appropriate colour 'traffic light' for foods
You may voluntarily repeat certain nutrition information on your 'front of pack' (FoP) label.
FoP nutrition labelling systems should be based on the following principles:
- information on the amount of energy in kilojoules (kJ) and kilocalories (kcal) alone; or energy plus fat, saturated fat (saturates), total sugars and salt in grams, in a specified portion of the product
- portion size information expressed in an way that is meaningful to the consumer e.g. ¼ of a pie, 1 burger
- percentage Reference Intake (%RI) information based on the amount of each nutrient and energy, in a portion of the food
- colour coding of the nutrient content of the food
- you may additionally include the descriptors 'high', 'medium' and 'low' alongside the colours red, amber or green respectively to further describe their meaning
Front of pack labelling criteria
In order to use additional forms of expression, such as colour coding, you must meet certain criteria. Read technical guidance on nutrition labelling and FSA guidance on front of pack nutrition labelling.
Labelling law for specific food products
Other labelling legislation to consider when labelling food
As well as general legal requirements for food labels, there are numerous other pieces of legislation that you may need to consider when developing and labelling your food products.
Some food products are have specific labelling legislation including:
- organic food
- genetically modified (GM) food
- bread and flour
- fruit juices and nectars
- jams and preserves
- meat products - eg pies and sausages
- quick frozen food
- medical foods
- infant formula and follow-on formula
- baby foods
You can only label food products can as 'organic' if they meet certain requirements. Labels on food sold as organic must indicate the certification body that the processor or packer is registered with.
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, including the law on organic food. See the latest EU Exit guidance for the food and drink sector and read about trading and labelling organic food from 1 January 2021.
The use of the organic production logo of the EU is mandatory for all prepacked organic products produced in any EU Member States.
There are special rules for labelling genetically modified food products.
Changes to rules and processes apply from 1 January 2021 for those businesses trading in genetically modified (GM) food or feed. Read about exporting GM food and animal feed from 1 January 2021.
Bread and flour
The Bread and Flour Regulations lay down labelling and compositional standards for the products they apply to.
The Honey Regulations determine when you can label a product as 'honey'. They lay down additional labelling requirements for honey products.
Fruit juices and nectars
The Fruit Juices and Fruit Nectars Regulations include requirements for labelling covering matters like the use of the terms 'fruit juice' and 'fruit juice from concentrate'.
Jams and preserves
The Jam and Similar Products Regulations require residual sulphur dioxide to be declared in the list of ingredients if it is present at levels greater than 10 milligrams per kilogram.
Meat and meat products
There are special labelling requirements for meat and meat products under the Products Containing Meat etc. Regulations. The requirements include meat ingredient declarations and information about added ingredients.
Quick frozen foods
The Quick Frozen Foodstuffs Regulations include special labelling requirements for quick frozen foods. Certain information must always appear on the label.
Medical foods, formula milk and baby foods
There are special rules on the composition, labelling and advertising for each of the four specific food categories:
- infant and follow-on formula
- processed cereal-based food and baby food
- medical foods (foods necessary for the dietary management of particular medical conditions)
- total diet replacement for use in energy restricted diets for weight reduction
Labelling food as organic
Requirements for labelling pre-packaged organic food products
If you produce or sell organic food in the UK and you want to label it as organic, you must register with one of the organic control bodies.
The following symbols might be commonly found on the labels of organic food in Northern Ireland:
- Soil Association
- Biodynamic / Demeter
- Organic Farmers and Growers
- Irish Organic Farmers and Growers Association
- Organic Trust
- Organic Food Federation
You can decide which body to register with based on your location and needs. See a list of approved UK organic control bodies.
Organic food labels
You can only label prepacked foods 'organic' if at least 95 per cent of the ingredients are organic.
Your food label must state:
- where any of the product's farmed ingredients were produced
- the control body's code number - for UK-origin produce for code number format is GB-ORG-XX (produce from non-English countries usually have a 3-letter code, such as 'bio', 'öko' or 'eko' instead of 'org')
If you're a retailer, you can label products 'organic' as long as:
- at least 95 per cent of the product's farmed ingredients are organic
- you sell direct to customers in your shop - this applies to all retailers from farm shops to supermarkets
Using EU organic production logo
From 1 January 2021, certain requirements around trading and labelling organic food have changed. However, under the terms of the Northern Ireland Protocol, EU Organic Regulations continue to apply in Northern Ireland.
You must continue to include the EU logo and statement of agriculture for organic products produced in Northern Ireland. Read more on trading and labelling organic food after 1 January 2021.
Contact your control body to stay up to date.
Labelling genetically modified food products
How to label food containing genetically modified ingredients, and the foods you don't have to label
Specific labelling is required for food that:
- is made entirely of genetically modified (GM) material
- contains GM material
- includes ingredients made from GM material
If you sell foods like these 'loose' - ie not in packaging - then you must display information next to the food to tell the consumer that it contains GM material.
Mandatory GM labelling
Under the GM food and feed regulations, if you use any GM ingredients intentionally, you must label them. Products such as flours, oils and glucose syrups made from a GM source must be labelled as GM. This is the case regardless of the amount of GM material present in the final product.
When labelling is not required
The regulations allow non-GM foods to contain a small amount of GM material without requiring GM labelling. However, this is allowed only if the GM material:
- was not added intentionally
- makes up no more than 0.9 per cent of the relevant ingredient
- is authorised by the relevant authority
Labelling is also not required for:
- products made with GM technology - for example, cheese made with GM enzymes
- products such as meat, milk and eggs from animals fed with GM feed
The relevant regulations in Northern Ireland are the Genetically Modified Food Regulations (Northern Ireland) 2004.
Many of the rules that cover GM material in food for human consumption also apply to animal feed. This means that:
- only authorised GM material can be added to animal feed marketed in the EU
- animal feed containing intentionally-added GM or GM-derived material must be properly labelled
- non-GM feed containing up to 0.9 per cent of GM material doesn't need to have GM labelling as long as the material was not added intentionally
Changes to certain rules and processes apply from 1 January 2021 for those businesses trading in genetically modified (GM) food or feed. Read about exporting GM food and animal feed from 1 January 2021.