EU Food Labelling Guide 2026

Getting food labels right is non-negotiable for any brand selling into the European Union. A single missing allergen declaration or an incorrectly formatted nutrition table can trigger product recalls, marketplace delistings, and fines that dwarf the cost of doing it properly from the start.

This guide covers everything you need to know about Regulation (EU) No 1169/2011 on the provision of food information to consumers -- the single most important piece of legislation governing food labelling in the EU. We walk through all 12 mandatory label elements, the 14 declarable allergens, nutrition declaration formatting, Nutri-Score, recent regulatory changes for 2025-2026, and the most common mistakes we see brands make.

Regulation 1169/2011: the legal foundation

Regulation (EU) No 1169/2011 (often abbreviated as FIC -- Food Information to Consumers) entered into force on 13 December 2014, with the mandatory nutrition declaration requirement applying from 13 December 2016. It replaced and consolidated earlier directives 2000/13/EC (general labelling) and 90/496/EEC (nutrition labelling) into a single, directly applicable regulation across all EU Member States.

The regulation applies to food business operators (FBOs) at all stages of the food chain where their activities concern the provision of food information to consumers. This includes manufacturers, importers, distributors, and retailers who place pre-packed food on the EU market. It covers both physical labels and distance selling (e-commerce), where mandatory information must be available before the purchase is concluded.

Key principle: food information shall not be misleading as to the characteristics of the food, its effects or properties, and shall not attribute to the food the property of preventing, treating, or curing a human disease (Article 7).

The 12 mandatory label elements

Article 9 of Regulation 1169/2011 lists the mandatory particulars that must appear on all pre-packed food sold in the EU. Each element has specific requirements regarding placement, format, and language.

1. Name of the food

The name must be the legal name as prescribed by EU or Member State legislation. Where no legal name exists, use the customary name (the name accepted by consumers in the Member State of sale without further explanation), or failing that, a descriptive name that is sufficiently clear for the consumer to know the true nature of the food and distinguish it from similar products. Any physical treatment the food has undergone (e.g., powdered, freeze-dried, smoked, reconstituted, irradiated) must be indicated alongside the name if omission could mislead the consumer.

2. 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. The list must be preceded by the heading "Ingredients" or include the word "Ingredients." Compound ingredients (an ingredient that is itself the product of more than one ingredient) must have their constituent ingredients listed in brackets. Water must be declared when it constitutes more than 5% of the finished product. Certain categories of foods are exempt from the ingredients list, including fresh fruit and vegetables, carbonated water, fermentation vinegars from a single basic product, cheese, butter, and fermented milk and cream where no ingredient other than lactic products, enzymes, and micro-organism cultures has been added.

3. Allergens

Substances or products causing allergies or intolerances (listed in Annex II of the Regulation) must be emphasised in the ingredients list through a typeset that clearly distinguishes them -- typically bold, CAPITALS, or bold italic. If there is no ingredients list, the allergen information must be preceded by the word "Contains." We cover all 14 allergens in detail below.

4. Nutrition declaration

The mandatory nutrition declaration must include energy value (in both kJ and kcal), fat, saturates, carbohydrate, sugars, protein, and salt -- in that order. Values must be expressed per 100 g or per 100 ml. Additionally, the declaration may be expressed per portion or per consumption unit, provided the portion size is quantified on the label. Full formatting rules are covered in the nutrition declaration section below.

5. Net quantity

The net quantity of the food must be expressed in litres, centilitres, or millilitres for liquid products, and in kilograms or grams for other products. Where a food is pre-packed in a liquid medium (e.g., olives in brine), the drained net weight must also be indicated. Products sold by number (e.g., 6 eggs) must state the count. Specific rules apply under the EU Weights and Measures framework (Directive 76/211/EEC) regarding the "e" mark and tolerable negative errors.

6. Date marking

Pre-packed foods require either a "best before" date (indicating quality, not safety) or a "use by" date (indicating safety -- after which the food shall be deemed unsafe under Article 14 of Regulation 178/2002). The format is "best before DD/MM/YYYY" or "best before end MM/YYYY" (where durability exceeds 3 months but is less than 18 months) or "best before end YYYY" (where durability exceeds 18 months). Foods exempt from date marking include fresh fruit and vegetables, wines, beverages containing 10% or more alcohol by volume, baked goods normally consumed within 24 hours, vinegar, cooking salt, solid sugar, and confectionery consisting almost solely of sugar.

7. Storage conditions and conditions of use

Where the food requires special storage conditions (e.g., "Keep refrigerated between 2 and 5 degrees C" or "Store in a cool, dry place"), these must be stated on the label. After opening, the storage conditions or the time within which the food should be consumed must also be indicated where appropriate. This is particularly critical for chilled, frozen, and shelf-stable products that become perishable once opened.

8. Country of origin or place of provenance

Origin labelling is mandatory for specific categories (see the FAQ section below for the full list). For all other foods, it becomes mandatory where failure to indicate origin might mislead the consumer -- for example, where the label or packaging suggests a country of origin different from the actual one (Article 26). The primary ingredient rule (Commission Implementing Regulation 2018/775) requires that where the origin of the primary ingredient differs from the indicated origin of the food, the origin of the primary ingredient must also be stated, or at minimum it must be indicated that the primary ingredient does not originate from the same place as the food.

9. Food business operator details

The name (or business name) and address of the food business operator under whose name or business name the food is marketed must appear on the label. If the FBO is not established in the EU, the name and address of the importer into the EU market must be stated instead. This element establishes traceability and provides consumers with a point of contact for complaints or queries.

10. Alcoholic strength

For beverages containing more than 1.2% alcohol by volume (ABV), the actual alcoholic strength must be indicated on the label. The figure must be expressed to a maximum of one decimal place, followed by "% vol." Tolerances allowed are plus or minus 0.3% vol for beverages not classified as beer or wine, 0.5% vol for beers, and 0.5% vol for wines (with specific exceptions for certain wine categories).

11. Instructions for use

Where it would be difficult to make appropriate use of the food without instructions, these must be provided. This includes cooking instructions (time, temperature, method), dilution instructions for concentrates, and reconstitution instructions for dehydrated products. Instructions must be sufficiently detailed to enable the food to be used appropriately.

12. Lot / batch code

Under Directive 2011/91/EU (the Lot Marking Directive), all foodstuffs marketed in the EU must bear an indication of the lot or batch. This is typically preceded by the letter "L" and enables traceability for product recalls. The lot/batch code may be printed, stamped, or otherwise marked on the packaging and does not have a prescribed format, provided it is intelligible and preceded by "L" where not otherwise clearly distinguishable from other label elements.

The 14 allergens (Annex II)

Annex II of Regulation 1169/2011 lists the substances and products causing allergies or intolerances that must always be declared. These must be emphasised in the ingredients list by means of a typeset that clearly distinguishes them (e.g., bold, underline, or capitals). Here is the full list with their common sub-categories:

"May contain" statements (precautionary allergen labelling or PAL) are not regulated by 1169/2011 and remain voluntary. However, their use must be justified by a documented risk assessment and must not be used as a substitute for good manufacturing practice. The Commission has been working on harmonised PAL rules, with a proposal expected in the 2025-2026 legislative cycle.

Nutrition declaration format

The nutrition declaration is governed by Articles 29-35 and Annex XV of Regulation 1169/2011. Getting the format right is one of the areas where brands most frequently stumble.

Mandatory nutrients (in prescribed order)

1. Energy (kJ / kcal)
2. Fat (g) -- of which saturates (g)
3. Carbohydrate (g) -- of which sugars (g)
4. Protein (g)
5. Salt (g)

These must always appear in this exact order. The declaration may additionally include: mono-unsaturates, polyunsaturates, polyols, starch, fibre, and any vitamins or minerals listed in Annex XIII Part A that are present in significant amounts (i.e., 15% of the nutrient reference value per 100 g or 7.5% per 100 ml).

Expression per 100 g / 100 ml

Values must always be expressed per 100 g (for solids) or per 100 ml (for liquids). The regulation permits additional expression per portion, provided the portion size is clearly stated on the label. Energy must be given in both kilojoules (kJ) and kilocalories (kcal).

Rounding rules (Annex XV guidance)

The EU provides guidance on rounding values to ensure consistency:

Nutrition values must be based on the food as sold, unless the label specifically provides information relating to the food after preparation (in which case sufficiently detailed preparation instructions must be given). Values may be obtained through analysis, calculation from known or actual average values of the ingredients used, or calculation from generally established and accepted data.

Tabular format

The nutrition declaration must be presented in tabular format, with the numbers aligned, if space permits. Only where space does not allow a tabular presentation may it be presented in linear format. The minimum x-height for the font used in the nutrition declaration is 1.2 mm (or 0.9 mm for packages with a largest surface area below 80 cm²).

Nutri-Score: front-of-pack nutrition labelling

Nutri-Score is a front-of-pack nutrition label (FOPNL) that assigns foods a grade from A (most favourable nutritional profile) to E (least favourable), displayed with a colour gradient from dark green (A) to dark red (E). The algorithm was developed by Professor Serge Hercberg and the French nutritional epidemiology research team (EREN).

How the algorithm works

The Nutri-Score is calculated per 100 g or 100 ml using a nutrient profiling system. Points are assigned for "negative" nutrients (energy, sugars, saturated fat, sodium) and subtracted for "positive" components (fibre, protein, and the proportion of fruit, vegetables, pulses, nuts, and rapeseed/walnut/olive oils). The final score places the product on a five-tier scale: A (-15 to -1), B (0 to 2), C (3 to 10), D (11 to 18), E (19 to 40).

In 2023, the Nutri-Score algorithm was updated to better differentiate between food categories. Key changes included: stricter treatment of sugary beverages, better distinction between whole grain and refined cereals, separate scoring for red meat, improved treatment of oils (favouring olive, rapeseed, and walnut oils), and additional points for fibre. The revised algorithm was adopted by all participating countries during 2024.

Adoption status (April 2026)

Nutri-Score remains voluntary at the EU level. However, it has been officially endorsed or adopted by France, Belgium, Germany, Luxembourg, the Netherlands, Spain, and Switzerland. The European Commission proposed a harmonised mandatory FOPNL scheme in December 2022 as part of its Farm to Fork Strategy. As of April 2026, the legislative proposal is still under trilogue discussions between the European Parliament, Council, and Commission. Several Member States, notably Italy (which favours NutrInform Battery) and certain Central European countries, continue to oppose a mandatory Nutri-Score model.

Recent changes: 2025-2026 updates

While the core of Regulation 1169/2011 remains stable, several developments in 2025-2026 are affecting food labelling practice:

Front-of-pack nutrition labelling proposal

The European Commission's proposal for a harmonised mandatory FOPNL (first tabled in late 2022) continues through trilogue. The outcome could mandate a specific FOPNL format across all Member States. Brands should prepare by ensuring their nutrition data is accurate enough to support any scoring system.

Origin labelling expansion

Building on the primary ingredient rule (Implementing Regulation 2018/775), there are ongoing discussions to extend mandatory origin labelling to additional categories including milk used as an ingredient, meat used as an ingredient, and single-ingredient foods. Some Member States (France, Italy, Portugal) have already adopted national measures requiring origin labelling for these categories.

Sustainability labelling

The proposed revision to the FIC Regulation includes provisions for standardised sustainability labelling. The EU's Green Claims Directive (adopted in March 2024) already restricts unsubstantiated environmental claims. From January 2026, any "eco," "green," or "climate-neutral" claim on food packaging requires third-party verified evidence under Directive 2024/825 (the Empowering Consumers Directive, which amended the Unfair Commercial Practices Directive). This means vague environmental claims on food labels are now illegal without substantiation.

Digital labelling

The Commission's revision proposals include provisions for digital labelling, where certain mandatory information (such as the full nutrition declaration) could be provided via QR code rather than on the physical label. This is particularly relevant for small packaging, multi-language markets, and products with frequent formulation changes. The wine sector has been a pioneer here, with Regulation 2021/2117 already permitting wines to provide ingredients and nutrition information via electronic means from December 2023.

Reformulation of salt content calculation

Salt content on labels is calculated as sodium x 2.5. No change has occurred to this formula, but enforcement agencies have increased scrutiny of products where the declared salt value does not align with the sodium content determined by laboratory analysis. Brands should ensure their calculation is based on the total sodium content of the finished product, not just added NaCl.

Common mistakes checklist

After reviewing thousands of product labels, these are the eight most frequent compliance errors we see FMCG brands make when labelling food for the EU market:

1. Allergens not emphasised in the ingredients list. Simply listing the allergen is not enough -- it must be typographically distinguished (bold, capitals, or underlining). This is the single most common cause of product recalls in the EU.
2. Nutrition declaration in the wrong order. The prescribed order (energy, fat, saturates, carbohydrate, sugars, protein, salt) is legally required. Swapping protein and salt, or listing sugars before carbohydrate, is non-compliant.
3. Missing or incorrect "of which" indentation. Saturates must appear as a sub-entry of fat; sugars must appear as a sub-entry of carbohydrate. These are not standalone line items.
4. Font size below the legal minimum. The x-height of 1.2 mm (0.9 mm for small packs) is frequently violated, especially when brands try to squeeze multilingual labels onto limited packaging real estate.
5. Incorrect date format. Using "EXP" or "BB" instead of the full legally mandated wording ("Best before" or "Use by") in the language of the market of sale. Also, using MM/DD/YYYY (US format) rather than DD/MM/YYYY or DD.MM.YYYY (EU format).
6. Missing FBO details. Particularly common for brands importing from outside the EU. The importer's name and EU address must appear on the label if the manufacturer is not established in the Union.
7. Origin/provenance misleading. Using country flags, map imagery, or geographic terms that suggest an origin different from the actual place of manufacture or primary ingredient sourcing without proper clarification.
8. Voluntary nutrition claims without meeting conditions. Using terms like "low fat," "high fibre," or "reduced sugar" without meeting the specific conditions laid out in Regulation (EC) No 1924/2006 on nutrition and health claims. For example, "low fat" requires the product to contain no more than 3 g of fat per 100 g (for solids) or 1.5 g per 100 ml (for liquids).

Language requirements

Article 15 requires that mandatory food information appear in a language easily understood by the consumers of the Member State where the food is marketed. Each Member State may stipulate which language(s) are required. In practice, this means labels must be in the official language(s) of each country of sale. Multi-market distribution typically requires multilingual labels. Countries like Belgium (Dutch, French, German), Finland (Finnish, Swedish), and Ireland (English, Irish) require multiple languages on a single label for domestic sale.

Distance selling (e-commerce)

Under Article 14, for pre-packed food sold via distance selling (online, catalogue, phone), all mandatory particulars except the date of minimum durability and the use-by date must be available to the consumer before the purchase is concluded. This means the information must be present on the product listing page, not merely enclosed in the delivered parcel. The date of minimum durability or use-by date must be provided at the moment of delivery.

Summary

EU food labelling under Regulation 1169/2011 is comprehensive and detailed, but it follows a clear logic: give the consumer the information they need to make safe, informed choices. Brands that invest in getting their labels right from the outset avoid costly recalls, protect their reputation, and build consumer trust. For products with complex formulations or multi-market distribution, consider using a product information management (PIM) system to maintain a single source of truth for all label data -- it pays for itself after the first prevented recall.

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