Food Packaging Labels: What EU and UK Rules Require on Pre-Packed Food

Which rules apply: pre-packed, PPDS or loose food?

Three situations are treated differently. Pre-packed food carries the full list of mandatory particulars. Food prepacked for direct sale (PPDS) and loose food follow lighter rules, which are set nationally. In the EU, allergen information is mandatory in all three cases, and Member States decide on the rest.

In practice, "prepacked for direct sale" means food that is packaged at the same place it is offered to the consumer, and is in that packaging before the customer orders or selects it, such as sandwiches made in the morning and wrapped for the chiller. Food made and packed after the customer orders is generally not PPDS. The Food Standards Agency (FSA) publishes guidance and a decision tool for working out which category applies; use it for borderline cases. For food sold in Scotland, Food Standards Scotland publishes the equivalent guidance.

What must appear on a pre-packed food label in the EU?

Article 9(1) of Regulation (EU) No 1169/2011 lists the mandatory particulars: the name of the food, the list of ingredients, allergens, the quantity of certain ingredients, net quantity, date of minimum durability or "use by", storage and use conditions, the name and address of the food business operator, country of origin or place of provenance where required, instructions for use where needed, alcoholic strength for beverages above 1.2 % by volume, and a nutrition declaration.

The Regulation applied from 13 December 2014; the nutrition declaration became mandatory on 13 December 2016 (Article 55). Further points matter for label design:

• Same field of vision: the name of the food, net quantity and alcoholic strength (where applicable) must appear in the same field of vision (Article 13(5)).
• Language: mandatory information must appear in a language easily understood by consumers in the Member State where the food is sold, and Member States may require particular official languages (Article 15). Several languages may appear together.
• Small packs: where the largest surface of the packaging is under 10 cm², only the name, allergens, net quantity and date of durability are mandatory on the pack, and the ingredients list must be provided another way or on request (Article 16(2)). The nutrition declaration is also not required on such packs.
• Voluntary information must not mislead and must be clear (Article 36), which matters for any extra wording printed on a label.

Nutrition and health claims on a food label fall under separate rules (Regulation (EC) No 1924/2006) and are outside this guide.

How must allergens appear on a food label?

Allergens must appear in the ingredients list, emphasised so they stand out from the rest of the text. If there is no ingredients list, the label states "contains" followed by the allergen name. Annex II of Regulation (EU) No 1169/2011 lists the 14 substances.

The 14 allergens are: cereals containing gluten (wheat, rye, barley, oats and hybridised strains), crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia), celery, mustard, sesame seeds, sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre, lupin and molluscs. Some derived ingredients are excepted in Annex II.

Article 21 requires the allergen name to be emphasised through a typeset that clearly distinguishes it from the rest of the list, for example by font, style or background colour. Bold type, capitals or a contrasting background are all used. Where several ingredients come from the same allergen, the label must make that clear for each. The same emphasis approach applies to PPDS food in the UK, which is why a label printed for PPDS usually uses the same layout as a pre-packed label, with fewer fields.

Wording such as "may contain" is voluntary and is not governed by a prescribed formula in this Regulation; it should rest on a proper allergen risk assessment and not substitute for allergen controls.

What is the minimum font size on food labels?

Mandatory information must be printed in characters with an x-height of at least 1.2 mm, or at least 0.9 mm where the largest surface of the pack is under 80 cm² (Article 13(2) and (3)). The x-height is the height of a lower-case letter "x", defined in Annex IV, not the point size.

For a label supplier, this means the type size is measured on the printed result, and the same point size in different fonts can give different x-heights. Condensed fonts and small labels are the usual problem. Specify the minimum x-height in the order, ask for a proof, and measure it. Mandatory text must also be clearly legible: not obscured by folds, seams or overlaps, and not interrupted by other printed matter (Article 13(1)). A transparent label on a patterned pack, or a round seal covering part of an ingredients list, can make otherwise compliant text illegible.

What did Natasha's Law change for UK food labels?

Since 1 October 2021, food prepacked for direct sale in the UK must carry the name of the food and a full ingredients list with allergens emphasised, directly on the package or on a label attached to it. In England the change came through the Food Information (Amendment) (England) Regulations 2019 (SI 2019/1218), widely called Natasha's Law; Scotland (SSI 2021/70), Wales and Northern Ireland made equivalent regulations with the same start date.

Points drawn from the instrument and the FSA's guidance:

• The requirement covers PPDS food offered to a final consumer or to a mass caterer. It does not apply to offers made by distance communication, although allergen information must still be available to the buyer.
• An exemption applies where the largest surface of the packaging is under 10 cm² (the Regulation's Article 16(2) route).
• The label can be on the package or a label attached to it, which is why on-site thermal label printers and pre-printed base labels are common.
• Date marks, net quantity and a nutrition declaration are not required on PPDS food by this change, but other requirements may apply to the specific product.
• The FSA's guidance covers England, Northern Ireland and Wales; Food Standards Scotland publishes guidance for Scotland. Check the current version of both at the time you design labels.

How does this affect how labels are specified and printed?

The food business is responsible for the label content; the label manufacturer is responsible for printing the supplied artwork accurately. Specify the content, layout and variable fields clearly, so the printer reproduces them without changing anything.

• Content is supplied and approved by the food business. A printer does not check allergen or ingredient accuracy, and should not be asked to.
• Fixed and variable text: brand, name and static elements printed in advance; dates, weights and recipe-specific text printed on site by a thermal printer or a purpose-built system.
• Recipe changes: every new or changed recipe means a label update. Order roll quantities that match how often recipes change, to avoid obsolete stock.
• Space: allergen emphasis, minimum x-height and several languages take room. Size the label to the content, not the other way round; see roll labels vs sheet stickers.
• Material: labels on bakery bags or sandwich wraps meet grease, condensation and cold, so face stock and adhesive matter; see sticker and label materials.
• Position: do not let seams, seals or closure stickers cover mandatory text, and do not use a decorative sticker as the legal label.

What does a bakery or food-to-go label typically include?

For pre-packed bakery goods, a label usually carries the name of the food, ingredients with allergens emphasised, net quantity, date mark, storage instructions, the operator's name and address and nutrition declaration where required. For PPDS items in the UK, it carries the name and the ingredients list with allergens emphasised; the PPDS rules do not require the other fields, although other rules may apply to the specific product.

A typical decision path:

• Made and wrapped before sale and sold in the same shop: PPDS in the UK; allergens required in the EU, with other particulars depending on national rules.
• Wrapped and sold through another business or a vending machine: generally pre-packed, with full particulars.
• Made after the customer orders: loose, with allergen information available by other means.

Round logo seals on bags are branding and closure; they do not replace a legal label. See tamper-evident takeaway bags where a seal also needs to show opening.

Where do other label rules fit?

Food information labels are separate from other pack labels. The EU's harmonised material sorting label under the PPWR is a different obligation, covered in PPWR labelling requirements. Environmental wording such as "recyclable" or "compostable" is a claim covered in recyclable, compostable and biodegradable packaging. Food-contact status of the pack itself is covered in food-contact packaging compliance in the EU, UK and US. National rules on language and on PPDS food differ between EU countries, so confirm them for each market (in German the topic is searched as Lebensmittelkennzeichnung, in Dutch as etikettering van levensmiddelen).

What to send your label manufacturer

Send the artwork or exact text, the minimum legibility requirement, and the conditions the label will face. A label printer can then size, proof and quote against the same assumptions.

• Final label text and layout, approved by the food business
• Which fields are fixed and which are printed on site, and the on-site printer model
• Minimum x-height or minimum point size and a proof requirement
• Label size and shape, and format (roll with core, unwind direction, or sheets)
• Face material and adhesive for the surface and conditions (grease, cold, damp)
• Languages and markets
• Colour and emphasis requirements for allergens
• Quantity per design and expected change frequency

Send the specification through the contact page. Materials and formats are confirmed at quotation and technical review. For the full request structure see the packaging RFQ guide.

Clothing works differently: fibre and care information follows textile rules, covered in what to print on a clothing hang tag.