Guide · Labelling
Food label size: how big does the label have to be?
Ordering labels means stating a size — so people go looking for the size prescribed by the FIC Regulation. There isn’t one. Something else is regulated, and the size follows from it: the font size. Here is what the text actually requires, which reliefs small packs get, and how to get from font size to label size.
EU law sets no label size
Nowhere in the Regulation is there a minimum size for a label. What is there is a requirement about legibility. Article 13(1) starts generally: mandatory information
“shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.”
Article 13(2) gives the figure everything turns on:
“… the mandatory particulars listed in Article 9(1) shall be printed on the package or on the label in such a way as to ensure clear legibility, in characters using a font size where the x-height, as defined in Annex IV, is equal to or greater than 1,2 mm.”
So the label size is not a requirement but a result: it has to be large enough for every mandatory particular to fit at a 1,2 mm x-height — legible, unobscured and uninterrupted.
What “x-height” means — and what it does not
The x-height is not the font size. Annex IV defines it through five lines: ascender line, cap line, mean line, baseline, descender line. The x-height is the distance from the baseline to the mean line — the height of a lower-case x, without ascenders or descenders. In the same drawing, “font size” is a separate, larger distance.
This is where most mistakes start: 1,2 mm of x-height is not a 1,2 mm font size. A typeface with a large x-height meets the requirement at a smaller point size than one with a small x-height.
Interpretation, not regulatory text: as a rule of thumb, roughly 6 to 8 pt is quoted for a 1,2 mm x-height, depending on the typeface. The Regulation names no point size — what binds is the measured x-height of the typeface actually used. If in doubt, measure it on the printed label.
The thresholds for smaller packs
The Regulation knows three thresholds, and all of them hang on the largest surface of the packaging — not on the label size.
| Surface | What applies | Source |
|---|---|---|
| 80 cm² and above | x-height at least 1,2 mm, all mandatory particulars | Art. 13(2) |
| below 80 cm² | x-height at least 0,9 mm | Art. 13(3) |
| below 25 cm² | no nutrition declaration required | Annex V, 18 |
| below 10 cm² | only name, allergens, net quantity, date of minimum durability; the ingredient list must be provided “through other means” | Art. 16(2) |
The last row deserves the wording, because it is often read too generously:
“In the case of packaging or containers the largest surface of which has an area of less than 10 cm² only the particulars listed in points (a), (c), (e) and (f) of Article 9(1) shall be mandatory on the package or on the label. The particulars referred to in point (b) of Article 9(1) shall be provided through other means or shall be made available at the request of the consumer.”
The list of ingredients does not disappear — it merely moves off the pack. And the four points are: the name of the food (a), allergens (c), the net quantity (e) and the date of minimum durability (f).
The field-of-vision rule that drives the layout
For design, Article 13(5) matters as much as the font size: the particulars in points (a), (e) and (k) of Article 9(1) — name of the food, net quantity and, for drinks above 1,2 % vol., the alcoholic strength — “shall appear in the same field of vision”.
In practice: those three may not be split across front and back. Anyone planning a narrow wrap-around label has to allow for it. Paragraph 6 exempts the cases in Article 16(1) and (2) — among them the very small packs in the table above.
From font size to label size
That finally answers the original question — but backwards. The order that works:
- Collect the mandatory particulars. Name, list of ingredients with emphasised allergens, net quantity, date of minimum durability, name and address, nutrition table, plus storage conditions and country of origin where applicable.
- Measure the largest surface of the packaging — it decides whether 1,2 mm or 0,9 mm applies and whether any relief kicks in.
- Typeset the text at that x-height and measure the area it needs. Only here does a label size appear.
- Check the field of vision: name, net quantity and, where relevant, alcoholic strength together on one side.
Interpretation, not regulatory text: the nutrition table is usually the hungriest block. If space runs out on a small pack, check first whether the largest surface is below 25 cm² — in that case it is not required anyway.
This article is general information and does not replace legal advice. What governs is the regulatory text in force (Art. 13, Art. 16 and Annexes IV and V of Regulation (EU) No 1169/2011, consolidated version of 1 January 2018).