Labelling food products
Introduction to food labelling rules that require you to provide certain information to customers, including information relating to allergens and nutrition.
Food labels provide useful information to inform and protect consumers. A food label must be clear and easy to see, read and understand. It must be difficult to remove and must not be misleading. It should show certain basic information and list the ingredients. You might also have to show certain warnings.
This guide explains the legal requirements for food labels. This includes the rules on food allergen and nutritional labelling.
Under the Windsor Framework, EU food law, including marketing standards, continues to apply to all food produced in Northern Ireland.
Legal requirements for food labels
Overview of the food labelling rules that apply to prepacked, prepacked for direct sale and non-prepacked food.
All prepacked food requires a food label that displays certain mandatory information.
What is prepacked food?
Food packed by one business and supplied to another business is considered prepacked. Typically, this is any food put into packaging before the consumer selects or orders it. For example, a bar of chocolate, a sealed packed of crisps, a jar of sauce or a can of soup.
To be considered prepacked, all the following must apply:
- the packaging fully or partly encloses the food
- the food cannot be altered without opening or changing the packaging
- the product is ready for sale to the final customer or mass caterer
Labelling for prepacked food which is not produced on site will usually be produced by the food manufacturer.
Labelling of prepacked food
The following information must appear by law on food labels and packaging:
- name of the food
- list of ingredients
- allergen information - see food allergen labelling
- quantitative declaration of ingredients (QUID)
- net quantity of food - ie the weight or volume of the food
- date labelling - either a 'best before' or 'use by' date
- storage conditions and/or conditions of use
- name and address of manufacturer (or the importer in some cases)
- country of origin or place of provenance (if required)
- preparation instructions
- nutrition declaration - see nutrition labelling
- the alcoholic strength by volume on drinks containing over 1.2% alcohol by volume
Food sold in Northern Ireland must include the name and address of the Northern Ireland or EU business responsible for the information on the food. If the business is not in NI or the EU, you must include the name and address of the importer.
There are for certain food and drink products if your product contains:
- sweeteners or sugars
- aspartame and colourings
- liquorice
- caffeine
- polyols
Read more about and check if there are .
Labelling of prepacked for direct sale food
Food that is packaged at the same place it is offered or sold to consumers, and is in this packaging before it is ordered or selected, is considered prepacked for direct sale (PPDS).
PPDS food can include:
- sandwiches/salads packaged and provided by the food business from the same premises
- fast food wrapped or packaged before a customer selects them
- supermarket products produced and packaged in store
This can be food that customers select themselves or pre-wrapped products kept behind a counter. It can also include some food sold at mobile or temporary outlets.
You can use the Food Standards Agency's to check if your business sells PPDS food.
All PPSD food needs to have a label showing the name of the food and the ingredients list with the 14 allergens required to be declared by law emphasised within it.
Read more about food labelling requirements for the .
Non-prepacked food
Any food that is not in packaging or is packaged after being ordered by the consumer is considered non-prepacked food. As such, it does not require a label with name, ingredients and allergens emphasised. Allergen information must still be provided but this can be done through other means, including orally.
Food allergen labelling
Important allergens to consider when labelling food, and what to do if cross-contamination is unavoidable.
The Food Information for Consumers Regulation names 14 substances or products which you must emphasise in ingredients lists. This is because these substances can cause allergic or intolerance responses. The rules apply to anything made from the 14 allergens (except in the case of sulphur dioxide and sulphites).
The 14 allergens are:
- cereals containing gluten (namely: wheat, rye, barley, oats, spelt, kamut or their hybridised strains)
- crustaceans
- eggs
- fish
- peanuts
- soybeans
- milk
- tree nuts (namely: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts)
- celery
- mustard
- sesame seeds
- sulphur dioxide and sulphites when the concentration of total sulphur dioxide in the whole prepared food is above 10mg/kg or 10mg/litre
- lupin
- molluscs
Declaring allergens
You must include and emphasise the names of any of the above allergens in the ingredients list. You can do this by using bold text or by making the allergen stand out from the other ingredients in some way.
If there is no ingredients list, you should include a 'contains...' statement. You don't need to include additional information if you have referred to the allergen in the name of the food.
If you want to include an allergy advice box, you can refer the consumers to the ingredients list, but you must not repeat the allergens.
If an allergen is not intentionally used, but there is a risk of cross-contamination (eg if the product is made in a factory that processes peanuts), you may include a 'may contain...' statement. However this is not a legal requirement.
You should only use a 'may contain...' statement - also known as precautionary allergen labelling or PAL - when you have determined the risk of allergen cross-contamination is real and you cannot remove it. Read more about this in the FSA's .
Exemptions
The rules on declaring allergens do not apply to some allergen derivatives, such as wheat-based glucose syrups and fully refined soybean oil. Otherwise, there are no exemptions.
Absence-of-gluten claims
There are specific laws about claims that a food is 'gluten-free' or 'very low gluten'. Gluten-free foods can have no more than 20ppm gluten.
You may label foods containing ingredients that have been processed to reduce their gluten content as 'very low gluten' when they contain no more than 100ppm gluten.
Allergen information on loose foods
Loose foods include everything that is not prepacked, for example from a delicatessen counter, fresh pizza, fish, salad bars and bread in bakery shops. In a catering environment, this applies to ready-to-eat foods such as meals in a restaurant, café or takeaway.
Rules for declaring allergens in loose foods:
- You must provide information about the allergens used in these foods.
- You must make allergen information available in writing or by speaking to staff. If you are not providing this information in writing, clearly signpost to where consumers can find this information.
- You can use logos or symbols when accompanied by words and numbers on menus
For loose foods allergen information has to be:
- easily accessible to all consumers
- accurate, consistent and verifiable
Allergen information on Prepacked for Direct Sale (PPDS) food
The way food businesses must provide allergen labelling information for PPDS food has changed. PPDS food is considered food that has been packed on the same premises from which they are being sold. Examples of PPDS food include meat pies made on site and sandwiches made and sold from the premises in which they are made.
PPDS food now must have a label with a full ingredients list with allergenic ingredients emphasised within it.
According to the new rules, PPDS food will have to clearly display the following information on the packaging:
- name of the food
- full ingredients list
- allergenic ingredients emphasised (for example in bold, italics or a different colour)
For more information, see the FSA's .
Nutrition labelling
What to consider when putting nutritional information on food labels.
You must provide a mandatory nutrition declaration for most prepacked foods. This is commonly known as 'back of pack' nutrition labelling. You must give the declaration in the following order:
- energy
- fat
- saturates
- carbohydrate
- sugars
- protein
- salt
Read and Food Standards Agency (FSA) guidance on .
Supplementary nutrients
You may also include certain additional 'supplementary' nutrients in the nutrition declaration. You may only include the following additional nutrients:
- monounsaturated fat
- polyunsaturated fat
- polyols
- starch
- fibre
- certain vitamins or minerals present in significant amounts as outlined in relevant regulations
Under the Windsor Framework, EU food law, including marketing standards, continues to apply to all food produced in Northern Ireland.
Claims about nutritional and health content
The rules that you must follow when making nutritional or health claims for food and where to find further guidance.
Nutritional claims suggest that food products have beneficial nutritional properties. They include statements such as:
- low fat
- source of calcium
- high fibre
- reduced salt
- no added sugar
Health claims suggest a connection between food and health. They include statements like:
- good for you
- calcium helps maintain normal bones
- keeps you feeling fuller for longer
- helps improve concentration
Rules for nutritional and health claims
If you want to make nutrition or health claims for your foods you there is specific legislation you must comply with. This legislation requires claims to be authorised. This makes it easier to identify nutrition and health claims that you can justifiably use on a specific product. It is designed to:
- protect consumers from misleading or false claims
- harmonise rules across the different countries making it easier to trade
The regulation lists the claims that you can make for foods and the criteria your product must meet before you can make them.
Under the Windsor Framework, EU food law, including marketing standards, continues to apply to all food produced in Northern Ireland.
Dishonest labelling and misdescription
Legislation and regulations to prevent mislabelling or misdescription of foods, and examples of misdescription.
Falsely describing, advertising or presenting food is an offence. Many laws help protect consumers against dishonest labelling and misleading descriptions, including:
- Food Safety Order
- Consumer Protection from Unfair Trading Regulations
- General Food Regulations
- Food Information Regulations
The description of food includes any of the following information:
- its name
- its ingredients
- its origin
- the processes it has undergone
The misdescription of food deceives consumers. It can trick people into buying something they would not otherwise buy. It poses serious risks to people intolerant or allergic to certain foods. It also leads to unfair competition.
Examples of food misdescription
Some examples of food misdescription include:
- Using a legal name for a food without the correct composition. For example, food sold as chocolate must have a certain amount of cocoa solids. Even if there are no composition rules for a food, such as fish fingers, it still must be described accurately.
- Extending a food - eg, adding offal to meat products without declaring it.
- Incorrectly labelling the true origin of a food or its ingredients in terms of animal species, plant variety, geographical origin or country.
- Incorrectly describing, or failing to describe, a process or treatment - such as not declaring irradiated food.
- Incorrectly stating the amount of an ingredient.
Read more about preventing and reporting food crime.
Reporting food crime
Members of the public and those working in the food and drink sector can speak up about food crime through .
Suspicions or information about food crime in Northern Ireland should be reported to FSA by emailing incidents.ni@food.gov.uk or by contacting FSA on 028 9041 7700 and asking to speak with the Food Fraud Liaison Officer.
Hygiene concerns should be if there is no direct intention to deceive.
Front of pack labelling
Voluntary front-of-pack signposting and criteria for deciding on the appropriate colour 'traffic light' for foods.
You may voluntarily repeat certain nutrition information on your 'front of pack' (FoP) label.
FoP nutrition labelling systems should be based on the following principles:
- information on the amount of energy in kilojoules (kJ) and kilocalories (kcal) alone; or energy plus fat, saturated fat (saturates), total sugars and salt in grams, in a specified portion of the product
- portion size information expressed in a way that is meaningful to the consumer e.g. ¼ of a pie, 1 burger
- percentage Reference Intake (%RI) information based on the amount of each nutrient and energy, in a portion of the food
- colour coding of the nutrient content of the food
- you may additionally include the descriptors 'high', 'medium' and 'low' alongside the colours red, amber or green respectively to further describe their meaning
Front of pack labelling criteria
In order to use additional forms of expression, such as colour coding, you must meet certain criteria. Read and FSA guidance on .
Labelling law for specific food products
Various labelling legislation you must consider when developing and labelling your food products.
As well as general legal requirements for food labels, there are numerous other pieces of legislation that you may need to consider when developing and labelling your food products.
Some food products have specific labelling legislation that applies to them, including:
- organic food
- genetically modified (GM) food
- bread and flour
- honey
- fruit juices and nectars
- jams and preserves
- meat products - eg pies and sausages
- quick frozen food
- medical foods
- infant formula and follow-on formula
- baby foods
Organic food
You can only label food products can as 'organic' if they meet certain requirements. Labels on food sold as organic must indicate the certification body that the processor or packer is registered with.
Under the Windsor Framework, EU food law, including marketing standards, continues to apply to all food produced in Northern Ireland.
The use of the is mandatory for all prepacked organic products produced in any EU Member States.
GM foods
There are special rules for labelling genetically modified food products.
Bread and flour
The lay down labelling and compositional standards for the products they apply to.
Honey
The determine when you can label a product as 'honey'. They lay down additional labelling requirements for honey products.
Fruit juices and nectars
The include requirements for labelling covering matters like the use of the terms 'fruit juice' and 'fruit juice from concentrate'.
Jams and preserves
The require residual sulphur dioxide to be declared in the list of ingredients if it is present at levels greater than 10 milligrams per kilogram.
Meat and meat products
There are special labelling requirements for meat and meat products under the . The requirements include meat ingredient declarations and information about added ingredients.
Quick frozen foods
The include special labelling requirements for quick frozen foods. Certain information must always appear on the label.
Medical foods, formula milk and baby foods
There are special rules on the composition, labelling and advertising for each of the four specific food categories:
- infant and follow-on formula
- processed cereal-based food and baby food
- medical foods (foods necessary for the dietary management of particular medical conditions)
- total diet replacement for use in energy restricted diets for weight reduction
Labelling food as organic
Overview of the requirements for labelling pre-packaged organic food products.
You must register with one of the operating in Northern Ireland if you produce or sell organic food and you want to label it as organic.
You can decide which body to register with based on your location and needs.
Label food as organic
You can only label pre-packed foods 'organic' if at least 95% of the ingredients are organic.
Your food label must state:
- where the product's agricultural ingredients were produced:
- 'EU Agriculture', where the agricultural raw material has been farmed in the EU;
- 'non-EU Agriculture', where the agricultural raw material has been farmed in third countries;
- 'EU/non-EU Agriculture', where part of the agricultural raw materials has been farmed in the EU and a part of it has been farmed in a third country.
Please note, the above indications 'EU' or 'non-EU' may be replaced or supplemented by a country in the case where all agricultural raw materials of which the product is composed have been farmed in that country. For example, control body code 'GB-ORG-XX'.
If you're a retailer, you can label products 'organic' as long as:
- at least 95% of the product's farmed ingredients are organic
- you sell direct to customers in your shop – this applies to all retailers from farm shops to supermarkets
- you have not imported the organic product
List organic ingredients in non-organic products
You can list ingredients in non-organic food products as organic so long as they meet . For example, your label can say 'organic sugar' on a food package that contains non-organic ingredients. You must also include the control body's code number on the label.
Display the EU logo
You must use the on organic food produced in Northern Ireland.
You can also continue to use your organic control body logo.
Labelling genetically modified food products
How to label food containing genetically modified ingredients, and the foods you don't have to label.
Specific labelling is required for food that:
- is made entirely of genetically modified (GM) material
- contains GM material
- includes ingredients made from GM material
If you sell foods like these 'loose' - ie not in packaging - then you must display information next to the food to tell the consumer that it contains GM material.
Mandatory GM labelling
Under the GM food and feed regulations, if you use any GM ingredients intentionally, you must label them. Products such as flours, oils and glucose syrups made from a GM source must be labelled as GM. This is the case regardless of the amount of GM material present in the final product.
When labelling is not required
The regulations allow non-GM foods to contain a small amount of GM material without requiring GM labelling. However, this is allowed only if the GM material:
- was not added intentionally
- makes up no more than 0.9 per cent of the relevant ingredient
- is authorised by the relevant authority
Labelling is also not required for:
- products made with GM technology - for example, cheese made with GM enzymes
- products such as meat, milk and eggs from animals fed with GM feed
The relevant regulations in Northern Ireland are the .
Animal feed
Many of the rules that cover GM material in food for human consumption also apply to animal feed. This means that:
- only authorised GM material can be added to animal feed marketed in the EU
- animal feed containing intentionally-added GM or GM-derived material must be properly labelled
- non-GM feed containing up to 0.9 per cent of GM material doesn't need to have GM labelling as long as the material was not added intentionally