Legal notice: This article is provided for informational purposes only and does not constitute legal advice. Food labeling law is complex and product-specific. Always verify your labels with a qualified food law professional or your national competent authority before placing products on the EU market.

EU food labeling is governed primarily by Regulation (EU) No 1169/2011 on the provision of food information to consumers — commonly known as the FIC Regulation. It entered into application on 13 December 2014, with mandatory nutrition labeling following on 13 December 2016. The consolidated version in force as of 1 April 2025 is available on EUR-Lex.

The FIC Regulation sits within the broader framework of Regulation (EC) No 178/2002 — the General Food Law — which establishes the foundational principle that no unsafe food may be placed on the EU market.

The FIC Regulation applies to all food business operators at all stages of the food chain where their activities concern the provision of food information to consumers. It covers all foods intended for the final consumer, including foods delivered by mass caterers and foods intended for supply to mass caterers.

The Core Principle: Food Information Must Not Mislead

Before getting into specific requirements, Article 7 of the FIC Regulation establishes the overarching rule: food information must be accurate, clear, easy to understand, and not misleading. It must not attribute properties to a food that it does not possess, and must not suggest that any food has special characteristics when in fact all similar foods have such characteristics.

This principle applies equally to labeling, advertising, and presentation — including the shape, appearance, and packaging of a product.

Mandatory Label Elements (Article 9)

Under Article 9(1) of the FIC Regulation, the following particulars are mandatory on the label of any prepacked food sold in the EU:

1. The name of the food The legal name, if one exists, must be used. Where no legal name exists, a customary name or descriptive name must be given.

2. The list of ingredients All ingredients must be listed in descending order of weight as recorded at the time of their use in the manufacture of the food. Each ingredient must be designated by its specific name or, where applicable, by a category name. The list must be preceded by the word "Ingredients:".

3. Allergen information Any substance or product listed in Annex II of the FIC Regulation that is present as an ingredient or processing aid must be clearly emphasized in the list of ingredients — for example by means of font, style, or background colour. The 14 substances covered are listed in full below.

4. The quantity of certain ingredients (QUID) The Quantitative Ingredients Declaration (QUID) requires the quantity of an ingredient to be stated as a percentage when it appears in the name of the food, is usually associated with that name by the consumer, is emphasized on the label, or is essential to characterise the food.

5. The net quantity Expressed in units of volume (litres, centilitres, millilitres) for liquids, and in units of mass (kilograms, grams) for other products.

6. Date marking One of two forms is required: - "Use by" date: used for microbiologically highly perishable foods. After this date, the food is considered unsafe. - "Best before" date: indicates the date until which the food maintains its expected quality when stored correctly. The food may still be safe to eat after this date.

The difference is legally significant. Only "use by" dates are safety-critical.

7. Storage conditions and conditions of use Where required for safe use or to maintain quality after opening, special storage conditions and/or conditions of use must be stated.

8. Name and address of the food business operator The name or business name and address of the operator under whose name the food is marketed must appear on the label. For products imported from outside the EU, the name and address of the importer established within the EU must be given.

9. Country of origin or place of provenance Origin indication is mandatory where its absence might mislead the consumer. It is also specifically required for: - Fresh, chilled, and frozen meat from pigs, sheep, goats, and poultry (since 2015) - Unprocessed beef (since 2000, under separate legislation) - Honey, olive oil, fruit and vegetables, fish — under category-specific regulations - Any product where the primary ingredient has a different origin from the stated origin of the food (under Commission Notice 2020/C 32/01)

10. Instructions for use Where it would be difficult to make appropriate use of the food without such instructions (for example, a product requiring specific cooking conditions), these must be provided.

11. Alcoholic strength For beverages containing more than 1.2% alcohol by volume, the actual alcoholic strength must be declared.

12. Nutrition declaration A mandatory nutrition declaration is required for the majority of prepacked foods sold to consumers in the EU.

The Nutrition Declaration (Articles 30–34)

The mandatory nutrition declaration must include, at minimum, the following seven elements:

Nutrient Unit
Energy value kJ and kcal
Fat g
of which saturates g
Carbohydrate g
of which sugars g
Protein g
Salt g

All values must be expressed per 100g or per 100ml. The declaration must be presented in tabular format with the numbers aligned. Where space does not permit it, linear format may be used.

The declaration may be voluntarily supplemented with: mono-unsaturates, polyunsaturates, polyols, starch, fibre, vitamins and minerals (provided they are present in significant amounts as defined in Annex XIII).

Products Exempt from Mandatory Nutrition Labeling

Article 16 and Annex V of the FIC Regulation exempt certain categories from the mandatory nutrition declaration, including:

  • Unprocessed single-ingredient products
  • Herbs and spices, salt and salt substitutes
  • Vinegar, flavourings
  • Chewing gum
  • Non-alcoholic beverages (tea, coffee, herbal infusions — where no other nutrients are added)
  • Food supplements (governed by Directive 2002/46/EC)
  • Mineral waters

Allergen Labeling (Annex II)

The following 14 substances and products causing allergies or intolerances must be clearly indicated whenever they are used as ingredients in any food:

  1. Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut, or their hybridised strains)
  2. Crustaceans and products thereof
  3. Eggs and products thereof
  4. Fish and products thereof
  5. Peanuts and products thereof
  6. Soybeans and products thereof
  7. Milk and products thereof (including lactose)
  8. Nuts (almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts)
  9. Celery and products thereof
  10. Mustard and products thereof
  11. Sesame seeds and products thereof
  12. Sulphur dioxide and sulphites at concentrations of more than 10mg/kg or 10mg/litre
  13. Lupin and products thereof
  14. Molluscs and products thereof

The allergen emphasis (font, style, or background colour) must be clearly distinguishable from the rest of the ingredients list.

For non-prepacked foods — including those served in restaurants, canteens, and catering operations — allergen information must also be made available, though the format may differ. It can be provided verbally provided a written notice is displayed directing the consumer to where this information can be obtained.

Presentation and Legibility Requirements

Under Article 13 of the FIC Regulation, mandatory information must be:

  • Conspicuous — in a prominent place, easily visible
  • Clearly legible — in a font where the x-height of the lower-case letter is at least 1.2 mm (0.9 mm for packages with a largest surface area of less than 80 cm²)
  • Indelible — not removable through normal handling
  • Not hidden or obscured — mandatory information cannot be covered, separated, or have attention distracted from it by other text or images

Language Requirements

Mandatory food information must appear in a language easily understood by the consumers of the Member States where the food is marketed. Each Member State may require that this be the official language(s) of that Member State. This means a product sold in Poland must have its mandatory information in Polish; one sold in Germany must be in German, and so on.

Alcoholic Beverages: A Special Case

Beverages containing more than 1.2% alcohol by volume are exempt from the mandatory list of ingredients and the nutrition declaration under the current FIC Regulation.

However, a significant exception applies to wine: following Regulation (EU) 2021/2117, a list of ingredients and a nutrition declaration became compulsory for wine placed on the EU market from 8 December 2023. The nutrition declaration on the packaging may be limited to the energy value only, with the full declaration provided electronically (e.g. via QR code) by reference to an external source.

Online and Distance Selling

Article 14 of the FIC Regulation makes clear that the same mandatory information required on a physical label must also be available on the online platform before the purchase is finalised. This applies equally to e-commerce, distance selling, and food delivery platforms operating in the EU.

What Is Changing: The FIC Revision

The European Commission has announced its intention to revise the FIC Regulation as part of the Farm to Fork Strategy under the European Green Deal. Key areas under consideration include:

  • Harmonised mandatory front-of-pack nutrition labeling (FOPNL): Currently voluntary. The Commission had planned to propose a mandatory harmonised scheme, but no legislation has been adopted as of April 2026. Member States currently recommend various national schemes (including France's Nutri-Score), but none is obligatory at EU level.
  • Extended origin labeling: Proposals to extend mandatory origin indication to additional product categories beyond those currently covered.
  • Date marking reform: Revision of "best before" and "use by" rules to address food waste.
  • Alcoholic beverages: Full labeling requirements (ingredients + nutrition) for all alcoholic beverages — not just wine — are under discussion.

These are proposals and impact assessments, not yet binding legislation. Businesses should monitor EUR-Lex and the European Commission's food safety portal for developments.

Enforcement

The FIC Regulation is enforced by national competent authorities in each EU Member State. Penalties for non-compliance vary by country but can include product withdrawal, fines, and — in cases involving food safety — criminal liability.

In Poland, enforcement falls primarily to the Główny Inspektorat Sanitarny (GIS) — Chief Sanitary Inspectorate — and the Inspekcja Handlowa (Trade Inspection).

Practical Checklist for Food Business Operators

Before placing a labeled food product on the EU market, verify that your label includes:

  • [ ] Legal name of the food
  • [ ] Full list of ingredients in descending weight order
  • [ ] All 14 allergens highlighted appropriately
  • [ ] QUID percentages where required
  • [ ] Net quantity in correct units
  • [ ] Date marking (correct type: "use by" or "best before")
  • [ ] Storage and usage conditions
  • [ ] Name and address of the responsible food business operator
  • [ ] Country of origin where required
  • [ ] Instructions for use where required
  • [ ] Mandatory nutrition declaration (per 100g/100ml, tabular format)
  • [ ] Minimum font x-height of 1.2 mm
  • [ ] Label language matches the Member State of sale
  • Regulation (EU) No 1169/2011 — Food Information to Consumers (FIC), consolidated version 01/04/2025, EUR-Lex CELEX:02011R1169-20250401
  • Regulation (EC) No 178/2002 — General Food Law
  • Regulation (EU) 2021/2117 — Wine labeling (ingredients and nutrition)
  • Regulation (EC) No 1924/2006 — Nutrition and Health Claims
  • Commission Notice C/2020/580 — Origin of primary ingredients (Article 26(3) FIC)
  • Commission Notice 2017/C 428/01 — Allergen labeling guidance

Tomasz Szumski Consulting helps regulated businesses verify product labeling for EU market compliance through InspektorAI — our AI-powered label verification platform. For professional compliance review, contact us or visit inspektorai.com.