Nutrition Declaration: Calculation, Rules and Label Requirements

Since December 2016, the nutrition declaration has been mandatory on virtually all pre-packed foods in the EU. The rules are laid out in EU Regulation 1169/2011 and specify which nutritional values must appear on the label, how to calculate them and how to present them.

Sounds straightforward. In practice, it isn't. You need to account for processing loss, apply the correct rounding rules per nutrient, use the "<" notation for low values and understand the difference between declaration per 100 grams and per portion. And with every recipe change, all values need to be recalculated.

This article covers exactly what the rules are, how the calculation works and how to make sure your nutrition declaration matches reality.

What Is the Nutrition Declaration?

The nutrition declaration is the mandatory overview of nutritional values on the label of a pre-packed food product. It gives consumers insight into the product's composition: how much energy, fat, carbohydrates, protein and salt the product contains per 100 grams (or 100 ml).

The declaration is derived directly from the recipe. When the product composition changes, the nutritional values change. That makes it one of the most dynamic parts of the label.

The Big 7: Mandatory Nutritional Values

EU 1169/2011 prescribes seven mandatory nutritional values, commonly known as the "Big 7". They must appear on the label in this order:

Nutritional value Unit Reference intake (RI)
Energy kJ and kcal 8400 kJ / 2000 kcal
Fat g 70 g
  of which saturates g 20 g
Carbohydrate g 260 g
  of which sugars g 90 g
Protein g 50 g
Salt g 6 g

Note: "saturates" and "sugars" are mandatory subcategories. They are displayed indented under "fat" and "carbohydrate" respectively.

The reference intake (RI) is the daily reference point for an average adult. You may show the RI percentage per portion on the label, but it is not required.

Voluntary Additional Nutritional Values

In addition to the Big 7, you may voluntarily declare extra nutritional values. The most common:

  • Fibre: not part of the Big 7, but frequently included
  • Mono-unsaturates and polyunsaturates: subcategories of fat
  • Trans fats: relevant for products with hydrogenated fats
  • Polyols and starch: subcategories of carbohydrate
  • Vitamins and minerals: only when present in significant amounts (15% of the RI per 100 g or per portion)
  • Sodium: declared as "salt" on the label (conversion factor: salt = sodium x 2.5)

Per 100 Grams and Per Portion

Nutritional values must always be declared per 100 grams (or 100 ml for liquid products). In addition, you may also declare them per portion, provided the portion size and the number of portions per package appear on the label.

The per-portion calculation is simple: the value per 100 grams x (portion size / 100). It becomes relevant at the rounding stage, because you round the per-portion value — not the per-100-gram value multiplied by the factor.

How to Calculate Nutritional Values

There are three permitted methods for determining nutritional values:

  1. Calculation based on the recipe: the nutritional values of all individual ingredients are weighted according to their proportion in the recipe
  2. Laboratory analysis: direct chemical analysis of the finished product
  3. Calculation based on reference values: using recognised food composition databases (such as McCance & Widdowson in the UK or the USDA database)

In practice, method 1 is the most common for composite products. The calculation works as follows:

Step 1: Nutritional Values per Ingredient

For each ingredient in your recipe, you need the nutritional values per 100 grams. These come from the supplier, from food composition tables or from a raw material database.

Step 2: Weighted Calculation

Multiply the nutritional value of each ingredient by the percentage it represents in the total recipe. Add up all contributions. The result is the nutritional values per 100 grams of unprepared product.

Example: a product consists of 60% ingredient A (with 10 g fat per 100 g) and 40% ingredient B (with 5 g fat per 100 g). The total fat content is: (60% x 10) + (40% x 5) = 8 g fat per 100 g.

Step 3: Correction for Processing Loss

This is where it gets complex. When a product is cooked, baked, dried or otherwise processed, its weight changes. Water evaporates, fat is absorbed or rendered out. The concentration of nutrients per 100 grams changes as a result.

The calculation depends on the type of loss:

Moisture loss only (e.g. drying or boiling): all nutritional values concentrate proportionally. If 100 grams of raw product becomes 80 grams after preparation, all concentrations increase by a factor of 100/80 = 1.25.

Moisture and fat loss (e.g. frying or deep-frying): fat and moisture are lost in different ratios. The energy value must be recalculated separately, because fat provides 37 kJ (9 kcal) per gram. The energy contribution of the lost fat must be subtracted before applying the concentration factor, and then the energy contribution of the remaining fat is added back.

This is a calculation that's no fun in a spreadsheet. An error in the formula affects every product that undergoes the same preparation process. In Eclarion you enter the weight before and after preparation and select the type of loss (moisture, fat or both). The recalculation of all nutritional values including energy happens automatically.

Step 4: Composite Recipes

Many products contain semi-finished goods that are themselves recipes. Think of a meal salad with a separately prepared dressing, or a pizza with a composite sauce. The calculation works hierarchically: first the nutritional values per sub-recipe, then the aggregation to the finished product.

With manual calculation in spreadsheets, this means nested formulas that need to be recalculated by hand every time a sub-recipe changes. In a dedicated system like Eclarion, the entire recipe tree is recalculated automatically with every change.

Rounding Rules Under EU 1169/2011

The EU prescribes specific rounding rules per nutrient type. This is not arbitrary rounding but a detailed schema:

Energy

  • Always in whole numbers (no decimals)
  • Declare in both kJ and kcal

Fat, Carbohydrate, Sugars, Protein and Fibre

  • 10 g or more: round to whole numbers
  • Less than 10 g: round to 1 decimal place (0.1 g)
  • For some values, a threshold applies below which "< 0.1 g" is declared

Saturates

  • 10 g or more: round to whole numbers
  • Less than 10 g: round to 1 decimal place
  • 0.1 g or less: declare as "< 0.1 g"

Salt

  • 1 g or more: round to 1 decimal place
  • Less than 1 g: round to 2 decimal places (0.01 g)
  • 0.0125 g or less: declare as "< 0.01 g"

Vitamins and Minerals

  • Round to 2 or 3 significant figures

The "<" notation ("less than") is important: it prevents declaring "0 g" when a minuscule amount is present, and it complies with the EU guideline for transparent communication.

Exemptions From the Declaration Requirement

Not all pre-packed foods require a nutrition declaration. The main exemptions:

  • Unprocessed products with a single ingredient: fresh fruit, vegetables, meat and fish
  • Herbs and spices: when daily consumption is negligible
  • Water: including carbonated water
  • Coffee and tea: unprocessed, without additions
  • Vinegar: from fermented products
  • Small packages: with the largest surface area less than 25 cm²
  • Artisanal products: sold directly by the manufacturer to consumers in small quantities

Note: if a manufacturer voluntarily makes a nutrition claim ("source of fibre", "low fat"), the nutrition declaration becomes mandatory — even if the product falls under an exemption.

Nutrition Claims and Health Claims

When you make a statement about the nutritional value of your product on the label or in advertising, additional rules from Regulation (EC) No 1924/2006 apply:

  • "Low fat": maximum 3 g fat per 100 g (or 1.5 g per 100 ml)
  • "Sugar-free": maximum 0.5 g sugar per 100 g or 100 ml
  • "Source of fibre": minimum 3 g fibre per 100 g or 1.5 g per 100 kcal
  • "Source of protein": minimum 12% of energy value from protein
  • "Reduced [nutrient]": at least 30% less than comparable products

If you use a nutrition claim, the corresponding nutritional value must appear on the label and be accurate. This makes precise calculation especially important.

Common Mistakes in the Nutrition Declaration

Processing Loss Not Accounted For

The nutritional values on the label must apply to the product as sold. For products sold in a prepared state (ready meals, baked goods, dried products), the values must be calculated after preparation. Forgetting this correction leads to systematically incorrect declarations.

Rounding Rules Not Correctly Applied

Each nutrient type has its own rounding rules. Using a single rounding method for all values is incorrect and can cause problems during inspections.

Sub-recipe Changes Not Recalculated

When the composition of a semi-finished product changes, the nutritional values of every finished product containing it also change. With manual calculation, these knock-on effects are regularly missed.

Salt Instead of Sodium (or Vice Versa)

The label must show "salt", not "sodium". The conversion is: salt = sodium x 2.5. Forgetting to convert is a common mistake, especially when supplier information is expressed in sodium.

Outdated Raw Material Data

If the nutritional values of a raw material change at the supplier (different crop, different season, different supplier) and you don't update your database, your system calculates based on outdated data. Regular validation of raw material information is essential.

Calculating Nutritional Values Automatically

The complexity of nutrition calculation makes it an ideal task for software. The calculation itself is not complicated, but the number of variables and the knock-on effects of changes make manual management impractical once you have more than a handful of products.

In Eclarion the nutrition calculation works like this:

  1. Enter the recipe: add ingredients with weights to the recipe
  2. Automatic calculation: based on the nutritional values per ingredient, the values per 100 grams of finished product are calculated instantly
  3. Apply processing loss: enter weight before and after processing, select the type of loss (moisture, fat or both). The recalculation including energy correction happens automatically
  4. Composite recipes: sub-recipes are calculated hierarchically. Change an ingredient in a semi-finished product and all finished products are updated automatically
  5. EU-compliant rounding: all values are rounded according to the specific rules per nutrient, including the "<" notation where applicable
  6. RI percentages: reference intake percentages per portion are calculated automatically

No spreadsheets with nested formulas. No manual recalculation when a recipe changes. No consultants building a calculation model for you. Just enter your recipe and the nutritional values come out.

Relationship With Other Label Requirements

The nutrition declaration does not stand alone. It is part of the overall label and is connected to:

  • The ingredient declaration: the same recipe that forms the basis for the nutrition calculation also determines the ingredient list
  • The allergen profile: allergens are derived from the same raw materials
  • The product specification: nutritional values are an integral part of your specification dossier

When all these elements are generated from the same source, you avoid inconsistencies. A change in the recipe automatically flows through to the nutritional values, the ingredient list and the allergen profile.

Frequently Asked Questions About the Nutrition Declaration

Must the Nutrition Declaration Always Be per 100 Grams?

Yes, declaration per 100 grams (or 100 ml) is mandatory. In addition, you may also show values per portion. If you declare per portion, the portion size and the number of portions per package must appear on the label.

Can I Determine Nutritional Values With an Online Calculator?

Online calculators can give an indication, but for labelling your products you need a reliable calculation based on your specific recipe and raw materials. Generic tools don't account for your exact ingredients, supplier-specific nutritional values or processing loss. For professional use, you need a system that is linked to your recipe management.

How Often Should Nutritional Values Be Recalculated?

With every recipe change, a change of raw material or supplier, or an adjustment to the preparation process. In practice, this means your nutrition calculation must be linked to your recipe management so that changes flow through automatically.

What Is the Difference Between Sodium and Salt on the Label?

The label must show "salt", not "sodium". The conversion is: salt = sodium x 2.5. If your raw material information is expressed in sodium, it must be converted.

Do Vitamins and Minerals Have to Appear on the Label?

Vitamins and minerals are only mandatory when a nutrition or health claim is made about them. Voluntary declaration is permitted when the product contains at least 15% of the reference intake per 100 grams (or per portion).

What if a Nutritional Value Is Too Low to Declare?

Use the "<" notation, for example "< 0.1 g" for saturates or "< 0.01 g" for salt. Declaring "0 g" is only permitted when the value is actually zero. The EU rounding rules specify the exact thresholds per nutrient.

Conclusion

The nutrition declaration is one of the most technical parts of food labelling. The calculation requires accurate raw material data, correct processing of preparation loss, nutrient-specific rounding rules and recalculation with every recipe change.

That is exactly the type of work software is made for. Not to turn it into a consultancy project, but to build it into your daily workflow. With Eclarion you calculate nutritional values directly from your recipes — including processing loss, EU-compliant rounding and automatic recalculation when things change. Start with a free trial and calculate your first product.