Food label requirements in the EU: a practical guide

Article 9(1) lists the core mandatory particulars.

Mandatory information must be visible, legible and indelible. It must not be hidden or interrupted by other material, under Article 13(1).

The food business operator under whose name the food is marketed is responsible for the food information under Article 8(1). If the product carries your brand, your business remains responsible even when a co-packer drafts and applies the label.

The brand must provide accurate recipes, supplier specifications and product data. The final artwork should be approved before printing.

Mandatory food information must appear in a language easily understood by consumers in the Member State where the food is marketed. Article 15 allows Member States to require one or more official EU languages. Plan the language set for every destination country before approving the artwork.

Annex II allergens must be named and distinguished from the rest of the ingredient list by typeface, style or background colour. Bold type is one option if the result remains legible. A “may contain” statement does not replace allergen controls or the declaration of an intentionally used ingredient. Assess precautionary wording against the actual process and supplier records.

The x-height must normally be at least 1.2 mm. It may be 0.9 mm where the largest surface is below 80 cm². Articles 13(2) and 13(3), with Annex IV, refer to the measured x-height rather than a point size.

A nutrition declaration is generally mandatory, but Annex V contains exemptions. These may cover certain single-ingredient unprocessed foods, herbs and spices, coffee, and specified teas or infusions. Added sugar, fruit or another ingredient can change the assessment. Confirm the exemption against the final recipe and sales route.

Annex X governs date wording and format. The responsible operator determines durability from the food, packaging and storage conditions. Agree it for the actual product before print.

Directive 2011/91/EU governs lot identification. Use “L” where the lot code is not clearly distinguishable from other information. A minimum durability date can serve as a lot indication only under the conditions in Article 5(1)(a). The code must connect to traceability records.

Origin is required where omitting it could mislead consumers, particularly where the packaging suggests a different origin. Article 26(3) may apply when the stated origin of the food differs from that of its primary ingredient. Review flags, maps and place names as part of the claim.

Article 19(1)(e) provides an ingredient-list exemption for some single-ingredient foods. The word “blend” does not create an exemption.

Food information must not mislead consumers about composition, quantity, durability, origin or method of production. Ordinary food must not be presented as treating or preventing disease. Article 7(4) applies these rules to advertising and presentation as well as labels.

The terms “organic” and their EU-language equivalents must comply with Regulation (EU) 2018/848. General environmental claims need adequate support under Directive (EU) 2024/825.

These mistakes keep appearing in Polish food-safety warnings and inspections:

• The allergen is listed but not emphasised. Listing it is not enough. In July 2026 the Polish Chief Sanitary Inspectorate (GIS) issued a public warning about a product whose label did not emphasise sulphites (GIS notice of 20 July 2026).
• A spice sachet under 5 g without a net quantity. The exemption for packs under 5 g does not cover spices and herbs (Annex IX, point 1(c)). This also applies to samples and campaign sachets.
• A batch identified only by the date. The rules allow it, but a recall then covers everything with that date. A separate lot code narrows it to one delivery (Directive 2011/91/EU, Article 5).
• A herbal infusion sold as “tea”. In a 2024 inspection by the Polish agricultural quality inspectorate (IJHARS), 167 of 325 batches of coffee and tea were labelled incorrectly. Findings included herbal infusions named tea and “100% robusta” containing arabica (report on the inspection results, in Polish).
• “Superfood” or “detox” on the front. These are general health claims. They may only appear next to a specific claim from the EU register (Article 10(3) of Regulation (EC) No 1924/2006).
• A four-language label on a small pouch. Each market needs a language its consumers understand (Article 15). With several language versions, the 1.2 mm minimum is what most often breaks.

Scoop & Pack weighs and packs dry food under client brands and applies labels. It can prepare label content covering ingredients, allergens and nutrition, or print a compliant client file. Work is carried out under HACCP. Support is scoped during the individual quote.

Production artwork should be PDF in CMYK, with images at least 200 ppi and preferably 300 ppi, 2 mm bleed, a 2 mm safe zone, CutContour on a separate layer and White_Ink where required. Do not include printer’s marks.