Labelling is where a sourcing decision becomes a legal statement. Everything upstream, the specification, the audit, the analysis, is evidence held in a file. The label is a representation made to a consumer in a Member State, and it is the point at which a competent authority can act without asking anyone for anything.
Regulation (EU) No 1169/2011 on the provision of food information to consumers is the instrument. It is directly applicable across the Union, it consolidated the old labelling and nutrition labelling directives, and it is amended and supplemented often enough that the consolidated text rather than the original publication is the thing to read.
This guide covers what has to appear, who is responsible for it, what language it has to be in, and the two places where importers most often get it wrong: private label responsibility and the treatment of business-to-business consignments.
Article 8: who is responsible
This is the part to settle before artwork is drawn, because it determines who signs off and who carries the exposure.
The food business operator responsible for the food information is the operator under whose name or business name the food is marketed. If that operator is not established in the Union, it is the importer into the Union market.
Three consequences follow.
On a private label programme, the responsible operator is the retailer or brand owner whose name is on the pack, not the Ukrainian, Polish or Serbian plant that filled it. The plant supplies data. It does not supply legal cover. A supply agreement that says the supplier warrants the label complies is a contractual allocation of loss between the parties; it does not move the regulatory responsibility, and an authority will not accept it as an answer.
On an own-brand import, the importer is responsible even where the artwork arrived finished from the third-country producer. Reviewing incoming artwork against the mandatory particulars is therefore an import control, and it belongs in the incoming goods inspection procedure rather than in marketing.
Operators who do not affect the food information, a warehouse keeper or a road carrier, must not supply food they know or presume to be non-compliant, but they do not carry the primary duty.
The mandatory particulars
Article 9 lists what must appear on prepacked food. In summary form, with the practical trap next to each.
| Particular | Where it goes wrong |
|---|---|
| Name of the food | A trade or fancy name substituted for the legal or customary name |
| List of ingredients | Descending order by weight at the time of manufacture, and compound ingredients broken out |
| Allergens from Annex II | Emphasis required in the ingredient list, not a separate box instead of it |
| Quantity of certain ingredients (QUID) | Triggered by the name, a picture, or emphasis, and routinely missed when driven by an image |
| Net quantity | Drained weight also required for solid food in a liquid medium |
| Date of minimum durability or use-by date | The wrong one chosen for the product’s microbiological profile |
| Special storage or conditions of use | Frozen products need the storage temperature and the after-thawing instruction |
| Name and address of the responsible operator | The plant address used instead of the responsible operator’s |
| Country of origin or place of provenance | Required where its omission would mislead, and by specific rules for some categories |
| Instructions for use | Where the food could not properly be used without them |
| Nutrition declaration | With defined exemptions, including some short-ingredient-list products |
Alcoholic strength applies above the defined threshold and is not relevant to this catalogue.
Three of these repay a closer look for frozen and dried goods.
Net quantity. Net quantity is the quantity of food, and for a product packed in a liquid medium the drained net weight is also required. For a glazed frozen product the net weight must exclude the glaze, and the specification and the label have to agree on that, which is exactly the number a quality tolerance argument runs on later.
Date marking. Date marking is either a date of minimum durability or a use-by date, and the choice is not stylistic. A use-by date is for foods that are microbiologically highly perishable and after which the food is deemed unsafe. Frozen fruit and dried goods carry a date of minimum durability, and the shelf life behind it has to be established by the operator rather than copied from a competitor. How that number is arrived at for dry products is a matter of water activity and storage trials rather than convention.
Date of freezing. Annex III requires the date of freezing, or the date of first freezing where the product has been frozen more than once, for frozen meat, frozen meat preparations and frozen unprocessed fishery products. It does not apply to frozen fruit and vegetables. Buyers coming from a meat background frequently add it out of habit, and a voluntary particular still has to be accurate and not misleading.
Allergens
Substances and products listed in Annex II must be declared where they are used as an ingredient or processing aid and remain present in the finished product, even in altered form. Article 21 requires that they be emphasised within the ingredient list through a typeset that distinguishes them, by font, style or background colour.
The two persistent errors are structural rather than typographical.
The first is replacing the emphasis with a separate “contains” box. The emphasis in the list is the requirement; a summary box is additional and cannot substitute.
The second is treating precautionary allergen labelling as a free option. The Union sets no threshold for the unintended presence of an allergen, and a “may contain” applied by reflex to every line devalues the statement and can itself mislead. A quantified cross-contact assessment against a documented hazard analysis is a materially better position than an untested precaution.
Note also that allergen labelling interacts with the packaging decision: a shared line that runs a nut product and a berry product needs the changeover evidence, not the label, to carry the argument.
Language, legibility and field of vision
Article 15 requires mandatory particulars to be in a language easily understood by consumers in the Member States where the food is marketed, and permits Member States to require one or more official Union languages. In practice that means a pack sold in Germany, France and Poland needs those languages present, and a single multilingual artwork is usually cheaper than three national versions once the plate change is counted.
Legibility is not left to judgement. Article 13 and Annex IV set a minimum x-height for mandatory particulars, with a reduced minimum for small packages below a defined largest surface area. Artwork that meets the x-height at design size and then gets scaled down for a smaller format has stopped complying.
Field of vision is a separate requirement: the name of the food, the net quantity and, where applicable, the alcoholic strength must appear in the same field of vision, meaning visible without turning the pack. A name on the front and a net quantity on the back is a non-compliance that survives many artwork reviews because each element on its own is correct.
Business-to-business consignments
Most of what Vorezan’s readers buy is not prepacked for the final consumer. A twenty-kilogramme carton of IQF raspberry going to a processor is a business-to-business supply, and the regime is different.
Where food is supplied to a food business operator rather than to a final consumer, and is not prepacked for the final consumer, the mandatory particulars may be provided on the commercial documents accompanying or sent before the consignment, provided that the name of the food, the date of minimum durability or use-by date, any special storage conditions and the responsible operator’s details appear on the outer packaging or on a label attached to it.
Two things follow. The commercial document route is legitimate and widely used, but it has to actually happen: a delivery note that omits the allergen and ingredient information is a gap, not a simplification. And the reduced set on the carton is a minimum, not a ceiling. Adding lot marking, the certificate of analysis reference and the plant approval number to the carton costs nothing at print time and saves a great deal at batch recall.
Lot identification is required under a separate instrument and is what makes a withdrawal targeted rather than total. It is the single label element with the highest ratio of value to cost.
Category-specific rules sit on top
Regulation (EU) No 1169/2011 is the horizontal rule. Vertical rules add to it and sometimes override it.
- Organic products carry the labelling requirements of Regulation (EU) 2018/848, including the control body code and the origin statement for the agricultural ingredients.
- Nutrition and health claims are governed by their own regulation, and a claim that is not authorised cannot be rescued by accurate nutrition labelling.
- Honey carries the particulars of the honey directive, including origin declaration rules that changed with the 2024 amending directive and which national implementations were still bedding in during 2026.
- Quick-frozen foodstuffs intended for the final consumer carry requirements from the quick-frozen foodstuffs directive alongside those in Regulation (EU) No 1169/2011.
Check the vertical rule for the category before signing off horizontal compliance, because the horizontal review will not surface it.
A workable artwork review sequence
- Confirm who the responsible operator is and get that entity to own the sign-off in writing.
- Draft the legal name, then the ingredient list, then the allergen emphasis, in that order, because the name drives QUID.
- Check same-field-of-vision placement for name and net quantity before layout is finalised, not after.
- Check x-height at the final printed size of every format in the range, including the smallest.
- Set the durability date from your own shelf life study and record the storage conditions that go with it.
- Run the vertical category rules as a separate pass.
- Confirm languages against every Member State on the distribution list, including markets added mid-contract.
- Keep the approved artwork, the sign-off and the underlying data in the same file as the specification, so a later change to the product triggers a labelling review automatically.
Vorezan does not approve artwork, does not act as the responsible food business operator and does not provide legal advice. Labelling decisions should be reviewed against the consolidated text of the instruments in force and, where the exposure is material, with counsel qualified in the Member States concerned.
