Food Labelling: All Rules and Mandatory Information Under EU 1169/2011

EU Regulation 1169/2011: The Foundation of Food Labelling

Regulation (EU) No 1169/2011 has been the core legislation for food information to consumers in the European Union since December 2014. The regulation replaced and consolidated earlier directives on labelling, nutrition labelling, and allergen declaration.

The key principles:

• Consumers have the right to clear, understandable, and non-misleading information about the food they buy
• All mandatory information must be legible, with a minimum font size of 1.2 mm (x-height) on the label
• Allergens must be visually emphasised in the ingredient list — for example, through bold text or underlining
• The label language must be an official language of the country where the product is sold

The regulation applies to all pre-packed foods. For non-pre-packed products (such as from a bakery or butcher), simplified rules apply, but allergen information must always be available to the consumer.

All Mandatory Information on a Food Label

EU 1169/2011 prescribes twelve categories of mandatory information. Below you'll find each element explained.

1. Name of the Food

The legal or customary name of the product. Not the brand name or fantasy name, but a description that makes clear to the consumer what the product is. Examples: "semi-skimmed milk", "chicken fillet in marinade", or "butter biscuits".

If no legal or customary name exists, a descriptive name must be used that unambiguously describes the product.

2. Ingredient Declaration

The list of all ingredients in descending order of weight at the time of processing. This is one of the most error-prone parts of the label, with detailed rules on compound ingredients, QUID declarations (quantitative ingredient declaration), and exemptions.

Read the full rules in our article on ingredient declaration.

3. Allergen Information

The fourteen EU allergens must be declared and visually emphasised in the ingredient list. These are: gluten, crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), tree nuts, celery, mustard, sesame seeds, sulphur dioxide/sulphites, lupin, and molluscs.

Correct allergen labelling goes beyond just bolding words. It requires proper allergen management in your specifications: for every raw material and every product, you need to know which allergens are present, which may occur through cross-contamination, and whether precautionary allergen labelling (PAL) is necessary.

Read more in our articles on allergen labelling and the guidelines for allergen management and PAL.

4. Nutrition Declaration

Since December 2016, the nutrition declaration has been mandatory on virtually all pre-packed foods. The so-called "Big 7" must be declared per 100 g or 100 ml:

1. Energy (kJ and kcal)
2. Fat
3. Of which saturates
4. Carbohydrate
5. Of which sugars
6. Protein
7. Salt

Additional nutrients may be declared voluntarily: fibre, vitamins, minerals, polyunsaturated fatty acids, and others. Values may also be expressed per portion, provided the portion size is stated on the label.

Nutritional values must be based on the actual composition of the product. For composite products (recipes), they are calculated from the recipe and the nutritional values of the individual ingredients, accounting for process losses. Read more about the calculation, rounding rules, and process loss in our article on nutrition declaration.

5. Net Quantity

The net weight or volume of the product. For products in a liquid medium (such as olives in brine), both the net quantity and the drained weight must be stated.

6. Date of Minimum Durability

Two variants:

• "Best before": for products that remain safe after the date but may lose quality
• "Use by": for microbiologically perishable products where a food safety risk arises after the date

Correctly determining the shelf life is part of your HACCP system and is linked to the microbiological specifications and storage conditions in your product specification.

7. Storage Conditions and Instructions for Use

If the product requires specific storage conditions (e.g. "store at 2-7 °C" or "consume within 3 days of opening"), these must appear on the label. The same applies to preparation instructions if needed for correct use.

8. Name and Address of the Food Business Operator

The name and address of the responsible food business operator within the EU. This is the company marketing the product under its name.

9. Country of Origin or Place of Provenance

Mandatory if omitting it could mislead the consumer. Since April 2020, also mandatory for the primary ingredient when the country of origin of the product is stated and the primary ingredient comes from a different country.

10. Identification Mark

For products of animal origin, an identification mark (the "oval mark") is required. Note: since May 2024, the abbreviation "EC" must be replaced by "EU".

11. Instructions for Use

Mandatory if the product cannot be used correctly without instructions. Think of preparation instructions for semi-finished or frozen products.

12. Alcohol Content

Mandatory for beverages with more than 1.2% ABV.

Specific Product Categories

In addition to the general rules under EU 1169/2011, certain product categories are subject to additional food labelling requirements:

• Wine and aromatised wine products: since December 2023, stricter requirements apply for ingredient and nutrition information, with the option to provide part of this digitally via a QR code. Read more in our article on wine labelling.
• Organic products: specific requirements for the use of the EU organic logo and the control body number
• Food supplements: additional requirements for content per daily dose and warnings
• Products for specific groups: infant formula, medical nutrition, and meal replacements are governed by their own regulations

Minimum Font Size and Legibility

A label that meets all content requirements but is unreadable doesn't comply. EU 1169/2011 requires:

• Minimum x-height of 1.2 mm for mandatory information
• For packaging with the largest surface area smaller than 80 cm², the minimum is 0.9 mm
• Information must be clearly legible: sufficient contrast between text and background
• Mandatory information must not be obscured by drawings, images, or other print

Common Food Labelling Mistakes

Allergens Not Updated After a Recipe Change

The number one cause of labelling-related recalls. A raw material is replaced by an alternative with a different allergen profile, but the label isn't updated. With centralised specification management — where the ingredient declaration and allergen profile are automatically derived from the recipe — this is preventable.

Nutrition Values Not Recalculated

When a recipe or supplier changes, nutritional values change too. If they aren't recalculated, the nutrition declaration no longer matches the actual product. Automatic calculation based on the current recipe prevents this.

Incorrect Ingredient Order

Ingredients must appear in descending order of weight at the time of processing. Recipe changes can shift the order. Maintaining this manually leads to errors. Software that generates the declaration automatically keeps the order correct by definition.

Missing or Incorrect QUID Declaration

When an ingredient is named in the product name or shown in an image, its percentage must be declared. This is regularly forgotten during product name changes.

Unreadable Label

Font too small, insufficient contrast, or information lost in the packaging design. Always verify that mandatory information is legible on the printed label.

Inconsistencies Between Language Versions

Companies selling products in multiple countries must translate their labels. Inconsistencies arise when translations aren't generated from the same source data. With multilingual specification management in a central system, you always work from one source of truth.

From Specification to Label: How to Prevent Errors

Most labelling errors don't originate during label design — they happen in the step before: maintaining accurate product information. If the source data is wrong or outdated, the label can't possibly be correct.

The solution is a workflow where the label is generated from your product specification, not created separately. The chain looks like this:

1. Enter the recipe: ingredients with percentages and supplier information
2. Automatic derivations: nutritional values, allergen profile, and ingredient declaration are calculated from the recipe
3. Complete the specification: add storage conditions, shelf life, packaging details, and preparation instructions
4. Generate label information: mandatory label information is derived directly from the specification

When anything changes in step 1, steps 2 through 4 update automatically. No manual recalculations, no forgotten updates.

This is exactly how Eclarion works. You manage your recipes and product information centrally, and everything derived from it — nutritional values, ingredient declaration, allergen profile, specification sheets, labels — stays automatically up to date. No spreadsheets, no loose documents, no surprises during an audit.

Frequently Asked Questions About Food Labelling

What Must Go on a Food Label?

On a pre-packed food product, EU 1169/2011 requires at minimum: the product name, ingredient declaration, allergens (emphasised), nutrition declaration, net quantity, date of minimum durability, storage conditions, name and address of the food business operator, country of origin (if relevant), and where applicable an identification mark, instructions for use, and alcohol content.

Does EU 1169/2011 Apply to Non-Pre-Packed Food?

The regulation primarily applies to pre-packed foods. For non-pre-packed products (food service, bakeries, butchers, market stalls), simplified rules apply, but allergen information must always be available to the consumer.

What Is the Difference Between "Best Before" and "Use By"?

"Best before" indicates until when the product retains its optimal quality. After that date, the product isn't necessarily unsafe. "Use by" applies to perishable products and indicates the final consumption date. After the use-by date, the product must not be sold or consumed.

Is a Nutrition Declaration Always Required?

Since December 2016, the nutrition declaration has been mandatory on virtually all pre-packed foods. Exemptions include unprocessed single-ingredient products (such as fresh vegetables), herbs and spices, water, coffee and tea, and small packaging with the largest surface area under 25 cm².

How Do I Keep My Label Up to Date When Recipes Change?

By generating your label information from your product specification instead of maintaining the label separately. When the ingredient declaration, nutritional values, and allergen profile are automatically derived from the recipe, every change flows through to the label immediately. This prevents the most common cause of labelling errors and recalls.

What Are the Penalties for Incorrect Food Labelling?

National food safety authorities can impose fines for food labelling violations, varying depending on the severity of the offence. In cases of public health risk (such as missing allergen information), fines can run into tens of thousands of euros. On top of that, authorities can order a recall, which causes reputational damage in addition to the direct costs.

Can I Provide Label Information Digitally via a QR Code?

For most mandatory information, the details must appear physically on the label. An exception has applied since December 2023 for wine and aromatised wine products, where the full ingredient declaration and nutrition declaration may be provided via a QR code. Allergens must still always appear physically on the label, even for wine.

Conclusion

Food labelling is not a standalone activity. It's the end result of good specification management: correct recipes, up-to-date allergen information, accurate nutritional values, and complete product data. When that foundation is solid, the label follows logically from it.

The companies that run into problems are usually not the ones that don't know the food labelling regulations. They're the companies that know the rules perfectly well but work with fragmented systems where changes have to be made manually. One forgotten update and you have a recall.

With Eclarion, you manage your product information centrally and generate label information directly from your specifications. No loose spreadsheets, no manual recalculations, no consultancy project to set it up. Start with a free trial and experience the difference.