Regulation (EU) No 1169/2011 on the provision of food information to consumers lists twelve mandatory particulars in Article 9(1). They are the name, ingredients, allergens, quantity of certain ingredients (QUID), net quantity, date mark, storage or use conditions, the responsible operator's name and address, origin where Article 26 requires it, instructions where needed, actual alcoholic strength above 1.2 % vol., and a nutrition declaration.
Where the requirement comes from
Regulation (EU) No 1169/2011, the EU FIC Regulation, has applied since 13 December 2014, and the nutrition declaration since 13 December 2016 (Article 55). It applies directly in every Member State.
Responsibility sits with one operator. Under Article 8(1), that is the operator under whose name or business name the food is marketed or, if that operator is not established in the Union, the importer into the Union market.
Regulation (EU) No 1169/2011
13 Dec 2014
Applies, directly in every Member State
Article 55
13 Dec 2016
Nutrition declaration applies
Article 55
1 Apr 2020
Origin of the primary ingredient
Implementing Regulation (EU) 2018/775, Article 4
1 Apr 2025
Annex II mustard exception: mustard-derived behenic acid of a minimum purity of 85 %, obtained by double distillation and used to make the emulsifiers E 470a, E 471 and E 477
Delegated Regulation (EU) 2024/2512
Wine and aromatised wine products
8 Dec 2023
Must give an ingredient list and a nutrition declaration
Regulation (EU) 2021/2117
From 19 Sept 2027
Wine solely intended for export is exempt from these requirements
Regulation (EU) 2026/471
Spirits and beer remain exempt under Article 16(4).
The twelve mandatory particulars
Article 9(1) has exactly twelve points, (a) to (l), each with its own detailed rule.
| # | Particular | Provision | What the detailed rule requires |
|---|---|---|---|
| (a) | Name of the food | Art. 9(1)(a), Art. 17, Annex VI | Legal name, else customary name, else descriptive name. A brand or fancy name cannot replace it (Art. 17(4)). |
| (b) | List of ingredients | Art. 9(1)(b), Art. 18, Annex VII | Headed "ingredients", in descending order of weight at the time of use; nanomaterials marked "(nano)" (Art. 18(3)). |
| (c) | Allergens | Art. 9(1)(c), Art. 21, Annex II | The 14 Annex II allergens, emphasised in the ingredient list. |
| (d) | Quantity of certain ingredients (QUID) | Art. 9(1)(d), Art. 22, Annex VIII | A percentage for named, emphasised or characterising ingredients. |
| (e) | Net quantity | Art. 9(1)(e), Art. 23, Annex IX | Volume units for liquids; mass units for other products. |
| (f) | Date of minimum durability or "use by" date | Art. 9(1)(f), Art. 24, Annex X | "Best before", or "use by" for highly perishable foods. |
| (g) | Special storage conditions and/or conditions of use | Art. 9(1)(g), Art. 25 | Where the food needs them, including after opening. |
| (h) | Name or business name and address of the food business operator | Art. 9(1)(h), Art. 8(1) | The marketing operator, or the EU importer. |
| (i) | Country of origin or place of provenance | Art. 9(1)(i), Art. 26 | Where Article 26 requires it. |
| (j) | Instructions for use | Art. 9(1)(j), Art. 27 | Where appropriate use would be difficult without them. |
| (k) | Actual alcoholic strength by volume | Art. 9(1)(k), Art. 28, Annex XII | Above 1.2 % vol.: a figure to not more than one decimal place, followed by "% vol." (wine: its own Union rules, Art. 28(1)). |
| (l) | Nutrition declaration | Art. 9(1)(l), Arts. 29–35, Annexes XIII–XV | Energy and six nutrients per 100 g or per 100 ml, unless exempt. |
Article 10 and Annex III add particulars for specific foods, such as "with sweetener(s)" and the high-caffeine warning.
Legibility and the field of vision
Article 13(1) requires mandatory information to be marked in a conspicuous place, easily visible and clearly legible. It must not be obscured or interrupted by other matter. The minimum type size is an x-height, not a point size: Annex IV measures it from the baseline to the mean line.
| Package | Minimum x-height | Provision |
|---|---|---|
| Largest surface 80 cm² or more | 1.2 mm | Art. 13(2) |
| Largest surface less than 80 cm² | 0.9 mm | Art. 13(3) |
Under Article 13(5), the name of the food, the net quantity and, where relevant, the alcoholic strength must appear in the same field of vision. A field of vision is all the surfaces readable from a single viewing point (Article 2(2)(k)), so front and back panels are normally not one. Article 13(6) excludes two cases: glass bottles intended for reuse that are indelibly marked and therefore bear no label, ring or collar, and packages whose largest surface is less than 10 cm² (Article 16(1) and (2)).
An x-height, not a point size
Annex IV measures it from the baseline to the mean line.
Same field of vision
Name of the food
Net quantity
Alcoholic strength, where relevant
Front
Name
Back
250 g
A field of vision is all the surfaces readable from a single viewing point, so front and back panels are normally not one.
Allergens: the 14 substances and how to emphasise them
Annex II lists 14 substances or products causing allergies or intolerances:
- cereals containing gluten (wheat, rye, barley, oats and their hybridised strains);
- crustaceans;
- eggs;
- fish;
- peanuts;
- soybeans;
- milk (including lactose);
- nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia or Queensland nuts);
- celery;
- mustard;
- sesame seeds;
- sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre, as total SO₂;
- lupin;
- molluscs.
Every entry except sulphites covers products thereof, and several list exceptions. Examples are fully refined soybean oil and, since 1 April 2025, mustard-derived behenic acid of a minimum purity of 85 %, obtained by double distillation and used to make the emulsifiers E 470a, E 471 and E 477 (Delegated Regulation (EU) 2024/2512).
Under Article 21(1), the allergen is named in the ingredient list with a clear reference to its Annex II name, and emphasised through a typeset that sets it apart, for example by font, style or background colour. A "Contains" statement is the method only where there is no ingredient list. No indication is needed where the name of the food clearly refers to the allergen.
QUID: quantitative ingredient declaration
Article 22(1) requires the quantity of an ingredient or category of ingredients to be stated where it:
- appears in the name of the food or is usually associated with that name by the consumer;
- is emphasised on the labelling in words, pictures or graphics; or
- is essential to characterise the food and distinguish it from foods it might be confused with.
Under Annex VIII point 3, the quantity is a percentage at the time of use, in or next to the name of the food or in the ingredient list. Point 4 adjusts this for foods that lose moisture and for volatile or reconstituted ingredients. Point 1 lists exemptions, such as small quantities used for flavouring. A picture that singles out an ingredient, such as fruit on a yoghurt pot, triggers Article 22(1)(b). A picture clearly marked "serving suggestion" does not, provided its nature is clear and it does not otherwise emphasise the food or its ingredients (Commission Notice 2017/C 393/05, points 11–12).
Date marking: "best before" or "use by"
Article 24(1) reserves "use by" for microbiologically highly perishable foods likely to become an immediate danger to health; after that date the food is deemed unsafe. Other foods carry a date of minimum durability.
| Element | Date of minimum durability | "Use by" date |
|---|---|---|
| Wording | "Best before …" with a day; "Best before end …" otherwise (Annex X 1(a)) | "Use by …" (Annex X 2(a)) |
| Form of the date | Uncoded; day and month suffice up to 3 months, month and year up to 18 months, year beyond (Annex X 1(c)) | Day, month and possibly year, uncoded (Annex X 2(c)) |
| Storage conditions | Added "if need be" (Annex X 1(b)) | Always added (Annex X 2(b)) |
| Other | Not required for some foods, e.g. fresh fruit and vegetables that have not been peeled or cut, vinegar, cooking salt, drinks of 10 % vol. or more (excerpt; Annex X 1(d) has all 9 items) | Shown on each individual prepacked portion (Annex X 2(d)) |
Origin and the primary-ingredient rule
Article 26(2)(a) makes origin mandatory where its absence could mislead. Point (b) covers the meats in Annex XI: swine, sheep and goat, and poultry meat. Beef is not included; it falls under Regulation (EC) No 1760/2000. Once origin is given, in words, flags or symbols, Article 26(3) applies: if the primary ingredient comes from elsewhere, the label must give its origin or say it differs. A primary ingredient makes up more than 50 % of the food or is usually associated with its name (Article 2(2)(q)).
Implementing Regulation (EU) 2018/775 has applied this since 1 April 2020 (Article 4):
- How (Article 2): a geographical area, from "EU", "non-EU" or "EU and non-EU" down to a country or region, or "(primary ingredient) does not originate from (country)".
- Presentation (Article 3): in the same field of vision as the food's origin, and where that is in words, at an x-height of at least 75 % of it.
- Excluded (Article 1): protected geographical indications, registered trade marks that constitute an origin indication, and geographic terms in customary or generic names that consumers do not read as origin.
The nutrition declaration
Article 30(1) sets the mandatory content. Annex XV sets the order and units.
| Order (Annex XV) | Unit | Mandatory? |
|---|---|---|
| Energy | kJ and kcal | Yes (Art. 30(1)(a)) |
| Fat | g | Yes |
| of which saturates | g | Yes |
| of which mono-unsaturates, polyunsaturates | g | Voluntary (Art. 30(2)) |
| Carbohydrate | g | Yes |
| of which sugars | g | Yes |
| of which polyols, starch | g | Voluntary |
| Fibre | g | Voluntary |
| Protein | g | Yes |
| Salt | g | Yes |
| Vitamins and minerals | Annex XIII units | Voluntary, if present in significant amounts |
- Basis: per 100 g or per 100 ml (Art. 32(2)). Per-portion values may be added if the portion and the number of portions are stated (Art. 33(1)).
- Calculation: Annex XIV conversion factors (Art. 31(1)); salt = sodium × 2.5 (Annex I, point 11).
- Format: all in one field of vision (Art. 34(1)); a table with aligned numbers if space permits, otherwise linear (Art. 34(2)).
- Reference intakes: optional; if used, add "Reference intake of an average adult (8 400 kJ/2 000 kcal)" (Art. 32(4)–(5)).
- Front-of-pack repeat: energy alone, or energy with fat, saturates, sugars and salt (Art. 30(3)), in the principal field of vision (Art. 34(3)).
Annex V exemptions. Article 16(3) exempts the 19 Annex V categories, including unprocessed single-ingredient products, waters, herbs and spices, salt, plain coffee and tea, flavourings, additives, chewing gum, packs whose largest surface is under 25 cm², and small-quantity food supplied directly by the manufacturer to consumers or local retail. Drinks above 1.2 % vol. need neither an ingredient list nor a nutrition declaration unless other Union provisions require them (Article 16(4)). Wine and aromatised wine products are such a case: since 8 December 2023 they must give an ingredient list and a nutrition declaration (Regulation (EU) 2021/2117). On the package or on a label attached to it, the nutrition declaration may be limited to the energy value, with the full nutrition declaration provided by electronic means (Regulation (EU) No 1308/2013, Article 119(4)). The ingredient list may also be provided by electronic means. Allergens must still appear directly on the package or on a label attached to it, as "contains" followed by the Annex II name (Article 119(5)(c) of the same Regulation). From 19 September 2027, wine solely intended for export is exempt from these requirements (Regulation (EU) 2026/471). Spirits and beer remain exempt under Article 16(4).
Food supplements are outside it. Article 29(1)(a) excludes foods within Directive 2002/46/EC from the nutrition declaration section. A supplement declares amounts per recommended daily portion (Article 8(2) of that Directive), not per 100 g.
Small packages
Where the largest surface is less than 10 cm², only the name (a), allergens (c), net quantity (e) and date (f) are mandatory on the package; the ingredient list is provided by other means or on request (Article 16(2)).
Largest surface less than 10 cm²
- Mandatory on the package
- Provided by other means or on request
- (a)Name of the food
- (b)List of ingredients
- (c)Allergens
- (d)Quantity of certain ingredients (QUID)
- (e)Net quantity
- (f)Date mark
- (g)Storage or use conditions
- (h)The responsible operator’s name and address
- (i)Origin where Article 26 requires it
- (j)Instructions where needed
- (k)Actual alcoholic strength above 1.2 % vol.
- (l)Nutrition declaration
Voluntary information
Voluntary information, such as precautionary "may contain" allergen statements or vegan claims, must not mislead, must not be ambiguous and must where appropriate rest on scientific data (Article 36(2)). Article 36(3)(a) and (b) foresee harmonised rules for "may contain" and vegetarian or vegan statements; none have been adopted yet. Voluntary information must not take space needed for mandatory information (Article 37).
Common mistakes
How RegaaS checks this
RegaaS applies Regulation (EU) No 1169/2011 as set out on Regulations covered: the twelve mandatory particulars, emphasis of the fourteen allergens, the same-field-of-vision rule, the nutrition declaration, QUID, origin including the primary ingredient, the 1.2 mm and 0.9 mm x-heights, and the rules on voluntary information. Claims are checked against Regulation (EC) No 1924/2006 and novel foods against Regulation (EU) 2015/2283.
Each finding cites its provision, is marked on the label image and comes with suggested text. RegaaS does not apply the per-100 g table to a food supplement; supplement rules are reported as out of scope.
Every rule applied gets one of four results: Compliant, Needs review, Potential risk or Not applicable. Where the information provided is not enough to decide, or the case is borderline, RegaaS marks the rule Needs review and refers it to regulatory staff instead of reaching a conclusion. Each Potential risk shows where the issue is on the label, the provision and the version in force, and a suggested revision. Whether a finding stands, and what to do about it, is decided by regulatory staff. When a provision is amended, RegaaS identifies the products already reviewed against it so they can be checked again.
What this guide does not cover
RegaaS reports these as out of scope rather than assessing them against provisions that do not apply:
- EU food supplements: the labelling rules of Directive 2002/46/EC.
- Additives, enzymes and flavourings: how they are designated under their own EU regulations.
- Fortification, gluten and lactose statements, and organic labelling.
- Food contact materials and packaging, and vertical commodity standards.
- Member State language requirements. Article 15 requires a language easily understood by consumers where the food is marketed, and lets each Member State require one or more official EU languages on its territory.
- Great Britain and Switzerland. Northern Ireland in principle continues to apply EU rules, except for retail goods moved from Great Britain and labelled "Not for EU" under the Windsor Framework.
This guide also leaves out non-prepacked food (Article 44) and distance selling (Article 14).
A RegaaS report is a documented review against the provisions listed. It is not legal advice, and does not substitute for sign-off by a qualified regulatory professional.
Frequently asked questions
How many mandatory particulars does Regulation 1169/2011 require? Twelve, listed in Article 9(1)(a) to (l). Some apply only in certain cases: origin where Article 26 requires it, instructions where needed, and alcoholic strength above 1.2 % vol.
What is the minimum font size on an EU food label? An x-height of at least 1.2 mm, or 0.9 mm where the largest surface of the package is less than 80 cm² (Article 13(2)–(3)). The x-height is defined in Annex IV.
Which nutrients must the EU nutrition declaration include? Energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1)), in the Annex XV order. Values are per 100 g or 100 ml, with energy in both kJ and kcal.
Do food supplements need a nutrition declaration? No. Article 29(1)(a) takes foods within Directive 2002/46/EC outside the nutrition declaration section. Supplements declare amounts per daily portion under that Directive.
Is "may contain" allergen labelling mandatory? No. It is voluntary information subject to Article 36(2). Article 36(3)(a) foresees harmonised rules for it, but none have been adopted yet. Article 21 covers allergens used as ingredients or processing aids.
Primary sources
- Regulation (EU) No 1169/2011 on the provision of food information to consumers, consolidated text of 1 April 2025 (EUR-Lex)
- Commission Implementing Regulation (EU) 2018/775 on the origin of the primary ingredient (EUR-Lex)
- Directive 2002/46/EC on food supplements (EUR-Lex)
- Commission Delegated Regulation (EU) 2024/2512, mustard exception in Annex II (EUR-Lex)
- Regulation (EU) 2021/2117, including ingredient and nutrition labelling of wine and aromatised wine products (EUR-Lex)
- Regulation (EU) No 1308/2013, Article 119 (wine labelling) (EUR-Lex)
- Regulation (EU) 2026/471, including the export-only wine exemption (EUR-Lex)
- Commission Notice 2017/C 393/05 on the quantitative ingredients declaration (QUID) (EUR-Lex)
- Commission Notice 2017/C 428/01 on allergen information (EUR-Lex)
- FSAI: The Windsor Framework and the supply of food