General labelling requirements for packaged food products

Although the United Kingdom left the European Union (EU) in 2021, certain pieces of legislation (known as 'assimilated law') continue to apply until such time as they are replaced by new UK legislation, revoked or permitted to expire. This means that our guidance still contains references to legislation that originated from the EU.

To fully understand this guidance, it is important to note the difference between the United Kingdom and Great Britain:

• UK: England, Scotland, Wales and Northern Ireland
• GB: England, Scotland and Wales

This guidance is for England and Wales

This guidance relates to prepacked food only.

'Prepacked food' is defined in assimilated Regulation (EU) No 1169/2011 on the provision of food information to consumers as "… food and the packaging into which it was put before being offered for sale, whether such packaging encloses the food completely or only partially, but in any event in such a way that the contents cannot be altered without opening or changing the packaging …".

The definition of prepacked does not cover food packed on the sales premises at the consumer's request; nor does it cover food that is sold from the premises on which it was packed, or from a mobile stall or vehicle used by the packer (referred to as 'prepacked for direct sale'). For more information see 'Labelling of non-prepacked foods' and 'Labelling of prepacked-for-direct-sale foods'.

MANDATORY INFORMATION

The following information is mandatory on prepacked foods:

• the name of the food
• an ingredients list
• information relating to allergenic ingredients
• quantitative ingredient declarations (QUID)
• a nutritional declaration
• durability date marking
• a net quantity declaration
• the name and address of the manufacturer
• storage instructions (where required)
• instructions for use (where required)
• origin marking
• alcoholic strength (for beverages containing more than 1.2% by volume)

Some of these requirements have been covered in detail in separate guides:

• 'Labelling of prepacked foods: ingredients list'
• 'Labelling of prepacked foods: nutrition declaration'
• 'Labelling of prepacked foods: product name'
• 'Labelling of prepacked foods: QUID'

In addition to this there is a general requirement that the labelling is accurate, clear and not misleading. Claims, especially those in relation to nutrition and health, are strictly controlled; please refer to 'Nutrition and health claims' for further information.

PRESENTATION

Mandatory information must be clear, legible and indelible. It must be presented on the packaging, on a label attached to the packaging or on a label visible through the packaging.

In the majority of circumstances, mandatory information must not be hidden in any way. Therefore, it is not permitted to have the mandatory information on parts of the packaging that need to be peeled up, unfolded, are only visible when the product is open, etc. You can still use these types of packaging but none of the mandatory information can be on them.

In certain circumstances (very small products with a large number of ingredients, for example) it may not be possible for all mandatory information to appear on the label; in such circumstances the information could be presented on a peel-and-read label. The decision to present mandatory information in this way must be made on a case-by-case basis and only considered where it would not otherwise be possible to provide the mandatory information on the label. For more information on the use of peel-and-read labels, please refer to Background and Guidelines for the use of 'Peel and Read' (Peelable) Labels on Foods, Including Food Supplements, which was produced by a working group of the Office for Product Safety and Standards (OPSS) Business Expert (Food Standards and Labelling) Group.

Mandatory information must be large enough to be legible, so there is a minimum font size of an x-height of 1.2 mm, which means that the lower-case x for whatever font size you are using cannot be smaller than 1.2 mm. This is approximately font size 8 in Times New Roman, but will differ from font to font.

In the case of very small products (those whose largest surface is less than 80 cm²) the x-height is reduced to 0.9 mm (approximately font size 6 in Times New Roman).

Mandatory information must be indelible, so you must use ink that will not run or rub off. This is especially important when you are writing use-by and best-before dates by hand; choose a pen that will not run.

All mandatory information must be in English, although you can include labelling in other languages in addition to English labelling. For full details please refer to 'Language requirements for food labelling'.

VOLUNTARY INFORMATION

It is common for manufacturers to include large amounts of information that is not required by law (descriptions of the taste, for example); this is referred to as 'voluntary information'.

You may include as much voluntary information as you please, provided it is not false or misleading; however, you cannot do so at the expense of mandatory information. If you find that you have no room for mandatory information (or would have to use a font size that is too small, or not use the required format) because you have given label space over to voluntary information, then you will need to either remove or reduce the voluntary information.

ALLERGENIC INGREDIENTS

You must draw the consumer's attention to any allergenic ingredients that are present in the food. For full details please refer to 'Food allergens and intolerance'.

DURABILITY DATE

Most prepacked food will require a durability date; this is either a use-by or a best-before date, depending on the nature of the food and how long it can be expected to stay edible.

For more details please see 'Date and lot marking of prepacked food'.

NAME AND ADDRESS

Prepacked food must bear the name and address of a food business operator (FBO) that takes responsibility for the food.

Since 1 January 2024, all prepacked food sold in GB must include a 'British Islands' (UK, Channel Islands or Isle of Man) address for the FBO. The appropriate name and address is normally that of the manufacturer / own brander - for example, a supermarket that sells products manufactured by another business under its own name. However, in the case of imported food, it is the importer who takes responsibility for the food and, therefore, the importer's name and address (in the UK, Channel Islands or the Isle of Man) must be declared.

If the product is marketed under the name of a food business other than the manufacturer, then the name and address of that business must appear on the product. Therefore, if you manufacture goods for another business to sell under their name, you must put their details on the label.

The food business under whose name the food is marketed is the business that is ultimately responsible for the food.

The name must be that of the appropriate legal entity (sole trader, limited company, etc) and the address must be a postal address in GB that is sufficiently detailed for legal documents to reach the business.

Depending on the size or location of the business (on an industrial estate, for example) it may be sufficient to have just a postcode, though a full address is typically required.

You may provide a supplementary email address / web address / telephone number, but these must be in addition to a postal address.

If you do not wish to use your trading / home address you may alternatively use:

• a post office box (PO box)
• the address of a legal professional in your employ (solicitor, accountant, etc) with their permission, best practice is to state the name of the food business followed by the address in question

FOOD EXPORTED TO EUROPE OR NORTHERN IRELAND

If you are exporting food to the EU or NI, the food must bear the postal address of an FBO that is established in the EU or NI.

The word 'established' is not defined in legislation but is more than a PO box or mail forwarding service; therefore, if you wish to put your own address within the EU / NI on the product you will need to conduct business from that address. If you are not established within the EU / NI, the address on the product must be that of the importer into the EU / NI (the first business to make the food available / place it on the market within the EU / NI).

The importer whose name and address appears on your product accepts legal responsibility for the food; best practice, therefore, is to have a formal relationship with, and consent from, the importer before putting their name and address on the packaging.

Your GB postal address can appear on the product in addition to this address.

The food must be labelled in the official language of the EU Member State in which it will be first placed on the European market (German, Belgian, etc; English in the case of food exported to NI) but may be labelled in additional languages if you wish.

NET QUANTITY

All prepacked foods (other than a few exemptions covered below) must have a net quantity indication.

'Net quantity' means the weight of food (or volume in the case of liquids), minus the weight of the packaging.

The indication must be given in kilograms or grams for solids, and in litres, centilitres or millilitres for liquids (metric indication). You may provide a supplementary net quantity in imperial measurements (pounds, ounces, fluid ounces, etc), but the indication must not be given greater prominence than the metric net quantity.

The net quantity must be in the same field of vision as the name of the product and the alcoholic strength where appropriate (this means the consumer can hold the product so that all the information is visible at the same time).

MULTIPACKS

If a prepacked product contains multiple identical prepacked products (a multipack of crisps, for example) you must state the net quantity of the individual product and how many products the pack contains - for example, 'Ready salted crisps' '6 x 25 g'.

If the number of products and the net quantity printed on the individual product is visible through the packaging then this does not apply.

PRODUCTS CONTAINING MULTIPLE DIFFERENT ITEMS

If a product contains multiple items, none of which are intended to be sold separately, you must declare the combined net weight and state how many individual packages are in the product - for example, a home baking kit: '300 g product contains: sponge mix, icing mix, six cupcake wrappers'.

PRODUCTS IN LIQUID

If the product is in a liquid medium (fruit juice, water, brine, etc) that needs to be removed prior to consuming the food, you must also state the drained weight of the product.

For example:

• 'Tuna chunks in brine' '160 g / 120 g'
• 'Tuna chunks in brine' '160 g - drained weight 120 g'

GLAZED PRODUCTS

If the product is in a glaze (ice, sugar, salt, etc) then the net quantity is the weight without the glaze.

EXEMPTIONS

The following do not need a net quantity declaration:

• goods that are subject to considerable losses in their volume or mass and are sold by number or weighed in the presence of the purchaser
• products with a net quantity of less than 5 g or 5 ml (although herbs and spices do require a net quantity declaration)
• goods normally sold by number and the number can be seen and counted from the outside, or the number is printed on the outside

STORAGE INSTRUCTIONS

You only need to include storage instructions if they are necessary to ensure that the food continues to be edible and maintains its quality until the durability date that you have put on the food - for example, 'Keep refrigerated', 'Store in a cool dry place', 'Refrigerate after opening'.

Best practice is for storage instructions to be close to either the durability date or information indicating where the durability date can be found - for example, 'For best-before date see base of pack - refrigerate after opening'.

INSTRUCTIONS FOR USE

You only need to include instructions for use if the consumer would find it difficult to use the product correctly without them; examples include cooking times for ready meals that need to be cooked in a microwave and mixing instructions for powdered products.

There are no specific requirements but instructions for use must be clear and not misleading.

COUNTRY OR PLACE OF ORIGIN

Origin labelling will only be required in the following circumstances.

Consumers might be misled if you don't state the origin.
The whole product must be considered when deciding whether the label is misleading. Examples include:

• descriptions - for example, 'Traditional Italian recipe' may mislead consumers into thinking the product originated in Italy
• designs - for example, a Union Flag may mislead consumers into thinking the product originated in the UK
• colours - for example, red white and blue stripes may mislead consumers into thinking the product originated in France

If the label is potentially misleading, you must state the country or place of origin of the product - for example, 'Product of Wales'.

Where a country or place of origin has been named but the primary ingredient is from somewhere else.
'Primary ingredient' means an ingredient that makes up 50% or more of the product or is usually associated with the product by the consumer - for example, 'Swedish meatballs made with British pork and beef'; in this case the description 'Swedish' relates to the recipe rather than the origin of the meat.

In cases such as this, you must either:

• state the country or place of origin of the primary ingredient
  or
• state that the country or place or origin of the primary ingredient is different to the origin of the product

For example:

• 'Swedish meatballs' 'Made using UK pork and beef'
• 'Swedish meatballs' 'Meat produced in the EU'
• 'Swedish meatballs' 'Using meat produced in countries other than Sweden'

Where the primary ingredient is sourced from multiple countries, you do not need to list them all; however, any statement you make must not be misleading - for example, 'Product of various countries' or 'Product of meat from EU countries'.

There are specific origin labelling requirements for beef. For more information please see 'Labelling of beef'.

UK products must no longer be labelled as 'Product of the EU', 'Produced in the EU', etc.

OTHER SPECIFIC LABELLING REQUIREMENTS

Specific information must be given for any product:

• packaged in a protective atmosphere
• containing glycyrrhizinic acid or its ammonium salt (products containing liquorice)
• with a high caffeine content
• containing added phytosterols, phytosterol esters, phytostanols or phytostanol esters

For more information please refer to Annex III to assimilated Regulation (EU) 1169/2011 (see link in 'Key legislation' below).

SELLING FOOD OVER THE INTERNET

If you sell food over the internet, you must provide full prepacked labelling information on both the website and the product.

It is best practice for the information to be presented on the same page as the product, but however it is provided, it must be available to the consumer before they make a purchase.

You do not have to include the durability date.

TRADING STANDARDS

For more information on the work of Trading Standards services - and the possible consequences of not abiding by the law - please see 'Trading Standards: powers, enforcement and penalties'.

IN THIS UPDATE

Clarification about the address that must appear on all prepacked food sold in GB.

Last reviewed / updated: April 2024

Key legislation

• Food Safety Act 1990
• assimilated Regulation (EU) No 1169/2011 on the provision of food information to consumers
• Food Information Regulations 2014
• Food Information (Wales) Regulations 2014

Please note

This information is intended for guidance; only the courts can give an authoritative interpretation of the law.

The guide's 'Key legislation' links may only show the original version of the legislation, although some amending legislation is linked to separately where it is directly related to the content of a guide. Information on changes to legislation can be found on each link's 'More Resources' tab.

© 2024 itsa Ltd.