Food labeling requirements in Europe: a guide to compliance testing

Published December 21, 2023

Food and beverages sold in the EU must contain essential information so that consumers can make safe and informed choices. Among other things, labels for prepackaged food must include a list of ingredients and additives, allergen information, the date of minimum durability, alcoholic strength (when appropriate), and a nutrition declaration.1 In addition to mandatory information, labels can contain voluntary data, such as claims on health effects, but only when these can be scientifically justified.

For companies that market food and beverages in Europe, it is recommended to have products tested to ensure the accuracy of the displayed information. This will help ensure compliance with Regulation (EU) No 1169/2011, known as the Regulation on Food Information to Consumers (FIC).

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Nutrition declaration

The FIC Regulation requires food labels to include the following mandatory nutrition information:

  • Energy value (kJ, kcal)

  • Fat

  • Saturates

  • Carbohydrates

  • Sugars

  • Protein

  • Salt

The mandatory nutrition declaration may be supplemented with details on mono-unsaturates, polyunsaturates, polyols, starch, fiber, and vitamins and minerals.2 The values may be obtained through laboratory analysis or a calculation based on the used ingredients.

Nutrition information must be displayed in a standardized format, generally per 100 g or 100 ml of the product. The energy value and amounts of nutrients may additionally be expressed per portion and relative to daily reference intake values, where appropriate.3

Vitamins and minerals must be expressed as a percentage of the daily reference intake value and should only be displayed when present in significant amounts. Generally, the concentration of a vitamin or mineral per 100 g or 100 ml should be at least 7.5 % in beverages or 15 % in other products.

Some food and beverage products are exempted from mandatory nutrition labeling or have reduced requirements. These include single-ingredient unprocessed products, food supplements, herbs and spices, sweeteners, vinegar, tea and coffee, salt, mineral water, and chewing gum.

Alcoholic beverage labeling

If beverages contain more than 1.2 % alcohol by volume, they must be labeled with the actual alcoholic strength by volume but are exempt from the FIC Regulation mandatory listing of ingredients and nutrition declaration.

Despite the exemption, European alcoholic beverage industries have self-regulated to provide energy, nutrition, and ingredient information on their products. Self-regulation efforts have been most successful in the beer industry, with spirits and wines lagging behind.4

This voluntary measure may soon become compulsory, as in February 2021 the European Commission announced that they intended to make ingredient lists and nutrition declarations mandatory on all alcoholic beverages. The Commission is currently gathering more input from industry, the public, scientists, and experts.5

Allergen labeling

If a food or beverage contains a substance that causes allergies or intolerances, the label must state this either explicitly or by emphasizing the substance in the list of ingredients, such as by using a bold font or different color text. Allergens subject to labeling requirements include:6

  • Cereals containing gluten

  • Crustaceans

  • Eggs

  • Fish

  • Peanuts

  • Soybeans

  • Milk

  • Nuts, including almonds, hazelnuts, walnuts, pecans, brazil nuts, pistachios, macadamia, and cashews

  • Celery

  • Mustard

  • Sesame seeds

  • Sulfur dioxide and sulfites (in concentrations >10 mg/kg or 10 mg/liter)

  • Lupin

  • Mollusks

The EU has also issued comments on precautionary allergen labeling (PAL) to warn consumers of the possibility of the unintentional presence of allergens in a food or beverage. This is not formally regulated in the EU at present, but the general principles of food safety law apply.7

Minimum durability and use-by dates

Food packaging must generally contain either a best-before or a use-by date, as well as information on the appropriate storage conditions.8 The use-by date applies to highly perishable products that are not safe to use after the specified date, while best-before refers to the date after which the product’s quality may degrade, even though it remains safe to consume. Both dates can be determined through shelf-life testing.

Voluntary food information, nutrition claims, and health claims

Voluntary food information specified in the FIC Regulation includes extended nutrition data, precautionary allergen labeling, information on the absence or reduced presence of gluten, and statements about the suitability of a product for vegetarians or vegans.9

Food labels may also contain nutrition and health claims compliant with Commission Regulations (EC) No 1924/2006 and (EU) No 432/2012.10 Regulation 1924/2006 primarily focuses on concise nutritional claims, such as 'low energy', 'saturated fat-free', 'source of fiber', and 'low sugars'. Examples of health claims covered by Regulation 432/2012 include melatonin reducing the time to fall asleep, meal replacements contributing to weight loss or maintenance, and specific vitamins and minerals contributing to a range of normal physiological processes.

To justify nutrition and health claims, companies must show that the relevant conditions outlined in EU regulations are met. Often, this includes proving that a food product contains or does not contain certain nutrients, substances, vitamins, or minerals in specified amounts.

Food testing to comply with labeling requirements

Measurlabs can help companies comply with EU regulations on food labeling, nutrition, and health claims. Examples of analysis options include the following:

Do not hesitate to contact us through the form below to discuss your company’s food testing needs. One of our experts will get back to you in one business day.

References:

1 The list of mandatory particulars can be found in Chapter IV, Section 1, Article 9 of Regulation (EU) No 1169/2011.

2 The details of mandatory and voluntary declarations can be found in Article 30 while the list of vitamins and minerals can be found in Annex XIII of Regulation (EU) No 1169/2011.

3 How the nutrition data is expressed can be found in Articles 32 and 33 of Regulation (EU) No 1169/2011.

4 Evidence on food information – Empowering consumers to make healthy and sustainable choices on the EU Science Hub website

5 See the 3 February 2021 press release Europe’s Beating Cancer Plan: A new EU approach to prevention, treatment and care. The proposed changes to the FIC Regulation go beyond alcoholic beverage labeling and include new ideas for origin labeling and changing the “best before date” rules to fight food waste. See Proposal for a revision of the Regulation on Food Information to Consumers for an up-to-date summary.

6 The list of substances causing allergies or intolerances which must be listed is found in Annex II of Regulation (EU) No 1169/2011.

7 Chapter V, Article 36, Item 3 of Regulation (EU) No 1169/2011 places PAL under voluntary food information. General principles can be seen in the EU Comments on Food Allergen Labelling.

8 Annex X of Regulation (EU) No 1169/2011

9 Chapter V, Article 36, Item 2(c) of Regulation (EU) No 1169/2011.

10 See Regulation (EC) No 1924/2006 on nutrition and health claims made on foods & Regulation (EU) No 432/2012 establishing a list of permitted health claims made on foods.

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