Regulation (EU) No 1169/2011: the mandatory core of the label
Regulation (EU) No 1169/2011 is the EU's core law on food information for consumers. It applies in every EU member state, and a country may add national mandatory particulars only under Article 39 and subject to its conditions. The regulation is binding whether the product is sold in a supermarket, a specialist shop or online.
The mandatory core of the label covers: the name of the food (a description of the product rather than the brand name, Art. 17); the list of ingredients in descending order of weight (Art. 18); the 14 allergens from Annex II, emphasised in the ingredients list by any visual means (Art. 21); the net quantity in grams, kilograms, millilitres or litres (Art. 23); the date of minimum durability, or a use-by date for highly perishable foods (Art. 24); any special storage conditions and conditions of use (Art. 25); the name and address of the food business operator (FBO) responsible for the food information, which for imports is the importer established in the EU (Art. 8(1) and Art. 9(1)(h)); instructions for use where the food would be hard to use properly without them (Art. 9(1)(j)); and the nutrition declaration per 100 g or 100 ml (Art. 9(1)(l) and Art. 30, with exemptions for the foods listed in Annex V).
Conditional requirements: what applies only when triggered
Some requirements of Regulation (EU) No 1169/2011 apply only when a specific trigger is present, so keep them apart from the mandatory core: some products need them and others do not. QUID (Art. 22) requires the percentage of an ingredient when the ingredient appears in the name of the food, is emphasised on the pack with a photo or illustration, or is essential to distinguish the product from similar foods. Country of origin or place of provenance (Art. 26) is mandatory where leaving it out could mislead the consumer, and for certain categories under horizontal or sector rules (some types of meat, honey and olive oil, for example). Alcoholic strength (Art. 28) must be stated for drinks with more than 1.2% vol of alcohol. The "frozen" and "defrosted" indications are required for the foods concerned. Specific EU rules also require the origin of the primary ingredient and certain other special indications.
The lot code, which carries traceability through to the shelf, is governed by a separate act, Directive 2011/91/EU (which repealed Directive 89/396/EEC), and is linked to batch traceability under Article 18 of Regulation (EC) No 178/2002. It also goes on the pack, but legally it sits outside 1169/2011. The section on lot traceability below covers it in more detail.
The 14 EU allergens: how to emphasise them in the ingredients list
The regulation sets a closed list of 14 allergen groups that must stand out in the ingredients list by some visual means: bold, italics, capitals, a different colour or underlining. The list: cereals containing gluten; crustaceans; eggs; fish; peanuts; soybeans; milk; nuts (hazelnuts, almonds, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamias); celery; mustard; sesame seeds; sulphur dioxide and sulphites (at more than 10 mg/kg); lupin; molluscs.
If an allergen is present as a derivative (soya lecithin, for example), it is declared as "lecithin (soya)" with the word "soya" emphasised. Possible traces from cross-contamination (an allergen carried over from other equipment) go on a separate line as "may contain traces of...". That statement is voluntary, though, and the regulation does not prescribe it.
Nutrition declaration: the per 100 g format and portion values
The nutrition declaration is mandatory and follows a standard format. The minimum set is energy (kJ and kcal), fat, of which saturates, carbohydrate, of which sugars, protein and salt, all given per 100 g or 100 ml of the product.
You can add mono-unsaturates, polyunsaturates, polyols, starch, fibre, vitamins and minerals to the minimum set (vitamins and minerals only when present in significant amounts). Alongside the per 100 g figures you can also give values per portion (for example, per 250 g bowl of plov), but they do not replace the main format.
The declaration is laid out either as a table or in linear format. The table has one column for the nutrient and one for the amount per 100 g; it takes more space but is easier to read. The linear format is used when the pack is too small for a table, as on spice sticks or small sachets. Wherever space allows, the table is the default.
QUID: when to state the percentage of an ingredient
The QUID rule (quantitative ingredients declaration) requires the percentage of an ingredient to be stated when the ingredient appears in the name of the food, is emphasised on the pack with a photo or illustration, or is essential to distinguish the product from similar foods. It answers a classic consumer complaint: "There's a chicken on the box and only 5% chicken inside."
For a product called "Plov with lamb", for example, QUID requires the percentage of lamb. For "Dried fruit mix with Surkhandarya dried apricots" it is the percentage of dried apricots, and for "Pumpkin samsa" the percentage of pumpkin. The percentage goes next to the ingredient in the ingredients list or in the name of the food, in one of two forms: "lamb (24%)" or "ingredients: rice, lamb 24%, carrots, onions, spices".
Minimum font size (x-height 1.2 mm) and language requirements
The regulation sets a minimum font size for mandatory information: an x-height of at least 1.2 mm. The x-height is the height of a lowercase x in the typeface, without ascenders or descenders. On packs whose largest surface is under 80 cm², the minimum drops to 0.9 mm. The rule covers all the mandatory information: name, ingredients, allergens, net quantity and the nutrition declaration.
Language requirements are set by each EU country's national law. The basic rule is that mandatory information must appear in the official language (or one of the official languages) of the country where the product is sold. For our target markets, the usual language set looks like this.
- Latvia: Latvian (latviešu); Lithuania: Lithuanian (lietuvių); Estonia: Estonian (eesti).
- Sweden: Swedish (svenska); Finland: Finnish (suomi) and Swedish (svenska), both required.
- Norway (in the EEA, not the EU, but applies 1169/2011): Norwegian (norsk).
- Germany: German (Deutsch); Poland: Polish (polski).
- The languages can share one side of the pack or be split across sides; the x-height requirement applies to each language separately.
Lot traceability: where the lot code goes and how to build it
Batch traceability is required by Article 18 of Regulation (EC) No 178/2002, and lot marking is set by Directive 2011/91/EU. Each batch must carry a unique lot code that lets the product be traced from the raw-material supplier to the retail shelf. The code goes on the pack in a visible place, usually next to the date mark, and must be legible without special equipment.
EU rules do not prescribe a format for the lot code, so each company follows its own internal system. It usually includes the year, the week or day of production, the shift and a series. L25323A, for example, reads as lot (L), 2025, day 323 of the year, series A. The code goes into the production log and onto the shipping documents, and if a complaint comes in, it lets you reconstruct the full history of the batch.
A label passes in the EU when every element on it can be matched to an article of Regulation 1169/2011 and every language of the destination country is covered as national law requires.