Ingredient Declaration: Rules for the Ingredient List on Food Labels

At a Glance: Ingredient Declaration Rules

1. In What Order Must Ingredients Be Listed?

Ingredients must be listed in descending order of weight as used by the manufacturer during production, in accordance with Regulation (EU) 1169/2011, Article 18.

Key Exceptions to the Order

• Added water below 5% may be listed at the end, provided it no longer has a technological effect on the final product.
• Ingredients below 2% may be listed after the main ingredients in any order.
• Mixtures of spices or herbs may be designated as "spices" or "mixed spices" without being broken down, as long as they make up less than 2% of the final product.
  Where the proportion exceeds 2%, the ingredients must be listed individually. If no single component predominates and the listing is not misleading, the order may vary with a note such as "in varying proportions".
• Vegetable oils and fats may be listed as a group, for example "vegetable oils (sunflower, rapeseed)".
  • All oils used must be named individually within the group designation, in order of weight.
  • If an oil or fat is fully hydrogenated or partially hydrogenated, this must be explicitly stated — for example "vegetable oils (partially hydrogenated palm fat, sunflower oil)".
  • Where the proportions of the oils used may vary, the phrase "in varying proportions" may be added, provided all oils are named.

2. How Do You Declare Compound Ingredients?

Compound ingredients are ingredients that themselves consist of multiple components — such as ketchup, margarine or chocolate.

Options for Listing

• Break down all sub-ingredients directly in the main ingredient list, for example:
  tomatoes, vinegar, sugar, salt.
• Or name the compound ingredient followed by the sub-ingredients in brackets, for example:
  ketchup (tomatoes, vinegar, sugar, salt).

Exceptions to Breaking Down

• Spice and herb mixtures below 2% do not need to be broken down. They may be designated as a group — for example "spices" — and you may indicate that they are present in varying proportions.
• Compound ingredients with a legal exemption do not need to be broken down, provided they make up less than 2% of the final product and fall under a legally defined composition, such as margarine, chocolate, butter or cheese.
  (See Annex VII, Part E of Regulation (EU) 1169/2011)

Important: Allergens within compound ingredients must always be explicitly declared, even when breaking down is not required.

3. What Are the Legibility and Technical Requirements?

According to Article 13 of Regulation (EU) 1169/2011, labelling information must be clear and easily legible so that consumers can readily understand it.

• Minimum font size: The x-height of the text must be at least 1.2 mm. For packaging with a largest surface area of less than 80 cm², a minimum height of 0.9 mm may be used.
• Contrast: There must be sufficient difference between the text colour and the background to ensure legibility.
• Language: Mandatory food information must be provided in the official language or languages of the Member State where the product is sold.

4. Which Ingredients Must Be Declared Differently?

For certain groups of ingredients, additional rules apply to how they appear on the label, as laid down in Regulation (EU) 1169/2011.

Category Names

Some ingredients may be designated under a generic name, such as "spices", "vegetable oil" or "milk proteins". Where there is a risk of confusion or misleading, the specific ingredients must still be listed (for example: vegetable oil (contains palm oil, rapeseed oil)).

If an ingredient contains an allergen, this must be explicitly named — for example spices (contains mustard).

Additives

Additives must always be declared with the functional class name (such as preservative, antioxidant) and the specific name or E number (for example preservative (E250)).
Where an additive has multiple functions, the primary function is stated — for example: ascorbic acid as antioxidant (Regulation (EC) 1333/2008).

Flavourings

Use the standard term "flavouring" by default.
Specify further where needed:

• Smoke flavouring must always be declared.
• Natural X flavouring may only be used if at least 95% comes from source X.
• Natural flavouring may be used without naming the source when the origin is natural (Regulation (EC) 1334/2008).

Nano-Ingredients

Ingredients intentionally produced in nano form (100 nm or smaller) must be declared with (nano) after the ingredient name.
Nanoparticles that arise during standard processes such as homogenisation do not need to be declared separately (Regulation (EU) 2015/2283).

Allergens

Allergens must always be explicitly and visually declared, including within compound ingredients. Use a clear distinction such as bold text, underlining or CAPITALS.
Keep in mind the 14 legally defined allergens, including cereals containing gluten, milk, soy, nuts and egg.

5. When Is QUID Required?

According to Article 22 of Regulation (EU) 1169/2011, the percentage of an ingredient must be stated on the label in certain cases. This is known as the Quantitative Ingredient Declaration (QUID).

A percentage is required:

• When an ingredient is mentioned in the name of the product.
  Example: strawberry yoghurt (contains 15% strawberries).
• When an ingredient is essential for characterising the product.
  Example: dark chocolate (min. 45% cocoa solids).

The stated quantity refers to the weight of the ingredient at the time of use during production, unless otherwise indicated.

6. When Is an Ingredient List Not Required?

In a few specific cases, an ingredient list on the label is not required. These exceptions are defined in Regulation (EU) 1169/2011.

An ingredient list is not required for:

• Fresh products that are unprocessed, such as unpeeled and uncut vegetables and fruit.
• Minimally processed products, such as cheese without added ingredients (except salt in the case of non-fresh cheese).
• Alcoholic beverages with an alcohol content above 1.2%.

Although no ingredient list is required for these products, separate requirements for allergen declaration or specific product labelling may still apply.

Note: Additional labelling requirements apply to wine. Read more about the rules for wine labelling.

7. What Voluntary Information May You Put on the Label?

In addition to mandatory information, manufacturers may include voluntary statements on the label, such as certain claims. However, these statements must meet strict requirements to avoid misleading consumers, as set out in Regulation (EU) 1169/2011.

Voluntary statements must not:

• Be misleading with regard to the characteristics of the product (for example composition, properties, origin).
• Create confusion about the nature, identity or composition of the product.
• Take up space needed for mandatory information.

Examples of voluntary statements:

• "No added sugars"
• "Fat-free"
• "High in fibre"

When using voluntary claims, the manufacturer must be able to demonstrate that the statement is factually correct and legally permitted.

8. Who Monitors Compliance With the Ingredient Declaration?

To meet the legal requirements for ingredient declarations, regular monitoring and compliance are essential. Companies must be able to demonstrate that the information on their labels is correct, up to date and complete.

Key points for monitoring:

• Recipe verification: Check that the actual composition of the product matches the declared ingredients.
• Documentation: Keep up-to-date specifications for all raw materials and ingredient blends used.
• Regulatory updates: Track changes in relevant legislation, such as Regulation (EU) 1169/2011, closely.
• Audits: Carry out periodic internal audits of labels, ingredient lists and recipes, in line with HACCP principles.
• Software: Consider using labelling software that tracks updates and ensures consistency.

---

Correct ingredient labelling is not just a legal obligation — it is also a matter of transparency and consumer trust. With the right knowledge of the regulations, a solid process and supporting tools, you can be compliant quickly and accurately.

With Eclarion you automatically generate correct ingredient lists in line with EU legislation. Discover the benefits or get in touch for personal advice.

---

Based on Regulation (EU) 1169/2011 (food information to consumers), Regulation (EC) 1333/2008 (additives), Regulation (EC) 1334/2008 (flavourings) and Regulation (EU) 2015/2283 (nanomaterials).

Note: this guide is for informational purposes and does not replace legal advice. When in doubt, always consult the full legislative texts.