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Food labelling checklist

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25/11/2014

This checklist sets out the key considerations for food producers and food service companies to ensure compliance with the new food labelling regime, effective from 13 December 2014. The legislation is detailed and contains many exemptions as well as particular requirements for particular foods. This checklist should therefore not be treated as a substitute for legal advice. Please speak to us to discuss your particular concerns.

If you sell loose food (including caterers)

  • The Regulation prescribes 14 allergens that need to be identified if included in a dish. You will need to supply information for every item on your menu that contains any of these allergens as ingredients. An obvious place to do this would be the menu itself. The 14 prescribed allergens are: cereals containing gluten; crustaceans; eggs; fish; peanuts; nuts; soybeans; milk; celery; mustard; sesame seeds; sulphur dioxide; lupin; molluscs.
  • You will need to identify and control the allergens present in the food you supply. You should also undertake a risk assessment of any allergen cross-contamination within your premises as the allergen information provided to the consumer must accurately reflect the final dish served.
  • You must not mislead the consumer as to the ingredients. For example, if a product is usually made from lamb mince but in a particular case is made from beef mince, this should be stated.”Formed products” should be described as such on the menu.

If you sell pre-packed food

  • If the product contains any of the 14 prescribed allergens you must ensure that the allergen is distinguished from other ingredients by means of a different typeset (e.g. bold type). The name of the allergen must follow the ingredient or additive name if its presence might not be obvious to the consumer.
  • The label must state the name and address of the EU manufacturer/brand owner; or the name of the importer into the EU if the manufacturer/brand owner is not established in the EU.
  • Consider whether an indication of country of origin is mandatory or not. It will be mandatory if: its absence is likely to mislead consumers as to the true country of origin; it is mandatory under other EU provisions (e.g. those relating to beef); the product is fresh, chilled or frozen meat of swine, sheep, goat or poultry. You will also need to specify the country of origin of the primary ingredient if this differs from that of the product and the country of origin is given for the product.
  • Nutritional declarations will remain voluntary until 13 December 2016 at which point they will become mandatory. If you do voluntarily choose to provide nutritional information in the meantime, you must do so in a prescribed format.
  • If the food has been defrosted, this needs to be stated (as has been the case before for, e.g.” smoked” or “concentrated” products). The date for first freezing is required on meat and fish products.
  • Ensure that the net quantity appears on the label in the same field of vision as the product name. The field of vision is “all surfaces of a package that can be read from a single viewing point”.
  • List ingredients in descending order of weight. The indication of the quantity of an ingredient should be given if the name of the ingredient appears in the name of the food; is emphasised on the label; or is essential to characterise the food from similar products.
  • Include a lot mark in order to facilitate traceability in case a product recall is needed.
  • Ensure that the product has a durability indication, e.g. a “use by” or “best before” date, unless it is exempted from the requirement to have one. The durability indication need not be in the same field of vision as the product name and other mandatory information.
  • Ensure labelling complies with new minimum font requirements.

If you sell into EU Member States outside the UK, make sure that the mandatory information appears in a language easily understood by consumers in that country.

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