Basics · Labelling
Food labelling — what has to be on the label?
Food labelling is the sum of everything that has to appear on or with a food so that consumers know what they are buying. What exactly belongs on the label is settled in detail — across Europe by Regulation (EU) No 1169/2011 and, in Germany, supplemented by national rules. This overview covers the mandatory particulars, the special rules for allergens, nutrition and additives, the font-size requirements — and what applies to food sold loose and to voluntary statements.
What food labelling is for
Food labelling covers all the mandatory and voluntary information describing a food to the final consumer: the name, the ingredients, allergens, nutrition values, durability, quantity and who is responsible for the product. The aim is a high level of consumer protection — the buyer should be able to make an informed decision without being misled.
It concerns practically all food supplied to final consumers — prepacked on the shelf just as much as loose over the counter, in a restaurant or in mass catering. The responsible party is the food business operator under whose name or business name the product is marketed (Article 8).
Which laws govern food labelling?
Labelling sits on two levels — a European core and national additions. For Germany:
| Rule | What it governs |
|---|---|
| Regulation (EU) No 1169/2011 EU |
The core: mandatory particulars, allergens, the nutrition declaration, legibility — applies directly in every Member State |
| LMIDV Germany |
Supplements it for Germany: language (§ 2), food sold loose (§ 4), the Nutri-Score (§ 4a) |
| Loskennzeichnungs-verordnung Germany |
Lot marking (“L…”) for traceability |
| LFGB Germany |
The framework act; basis for sanctions |
Selling in another Member State? The EU core is the same; the national additions are not. Check the rules of the country you sell in, in particular the language requirement (Article 15 lets each Member State require a language easily understood by its consumers).
The mandatory particulars at a glance
For prepacked food, Article 9(1) names twelve mandatory particulars. They are the skeleton of every label:
| Art. 9(1) | Mandatory particular |
|---|---|
| a | The name of the food |
| b | The list of ingredients |
| c | Allergens (substances from Annex II) |
| d | The quantity of certain ingredients (QUID) |
| e | The net quantity |
| f | The date of minimum durability or the ‘use by’ date |
| g | Special storage or use conditions |
| h | The name or business name and address of the food business operator |
| i | The country of origin or place of provenance, where provided for |
| j | Instructions for use, where needed |
| k | The actual alcoholic strength (beverages above 1.2 % by volume) |
| l | The nutrition declaration |
The list of ingredients and the 14 allergens
The list of ingredients gives all ingredients “in descending order of weight, as recorded at the time of their use” (Article 18(1)), under a heading including the word “ingredients”. The 14 allergens of Annex II have to be emphasised within it (Article 21). All the detail — water, compound ingredients, category names, QUID — is in the list of ingredients and allergen labelling.
The nutrition declaration
Mandatory since 13 December 2016. Article 30(1) prescribes seven values in a fixed order, per 100 g or 100 ml: energy (in kJ and kcal), fat, of which saturates, carbohydrate, of which sugars, protein and salt. The energy value is calculated with the conversion factors of Annex XIV. Details in how to create a food label, the data basis in the German Federal Food Key.
Additives and E numbers
Additives are designated by the name of their category followed by their specific name or E number (Annex VII Part C) — “preservative E 200”. Some carry an additional statement under Annex III, such as “with sweetener(s)”. All 24 categories are in additives and E numbers.
Font size and legibility
Article 13(2) requires the mandatory particulars to be printed “in characters using a font size where the x-height, as defined in Annex IV, is equal to or greater than 1,2 mm”. For packaging whose largest surface is less than 80 cm², Article 13(3) allows 0,9 mm. Article 13(1) adds that the information must be “easily visible, clearly legible and, where appropriate, indelible” and must not be hidden or obscured by anything else.
Language and further mandatory particulars
In Germany the mandatory particulars have to be given in German (§ 2 LMIDV), on the basis of Article 15. Beyond the twelve basics, certain products carry additional particulars:
- “Defrosted” — for food that was frozen and has been thawed.
- “Date of freezing” — for frozen meat, frozen meat preparations and frozen unprocessed fishery products.
- The specific vegetable origin — for refined oils and fats (“sunflower oil”, not just “vegetable oil”).
- “Formed meat” or “formed fish” — for products made from pieces combined together.
- Nano — engineered nanomaterials are marked with “nano” in brackets after the ingredient.
- A caffeine warning — for drinks high in caffeine (a notice for children and for pregnant or breastfeeding women).
Voluntary statements
Beyond the mandatory set, manufacturers may add voluntary information, as long as it is accurate, clear and not misleading (Articles 7 and 36):
- The Nutri-Score — the A-to-E colour scale; in Germany its use is settled by § 4a LMIDV. Details in Nutri-Score explained.
- Per-portion figures in addition to the values per 100 g or ml.
- Origin and regional statements, organic and quality marks.
- “May contain traces of …” — a voluntary statement about possible unintended allergen entry. It does not replace the mandatory declaration of the allergens actually used.
Loose food, food service and direct sales
Not every food needs the full label. For food that is not prepacked — a bakery or meat counter, a restaurant, a canteen, direct sales — Article 44 means not every particular is mandatory. One stays binding: information on the 14 allergens (Article 44(1)(a)).
In Germany § 4 LMIDV sets the means: allergenic ingredients have to be communicated in writing (a notice, an allergen folder, a menu or price list) — or, on conditions, orally, where a written notice points to that possibility and the information is documented and accessible. Worked examples: restaurants and bakeries.
What happens if you get it wrong?
Missing, incorrect or misleading labelling is not a trivial matter. In Germany it is pursued through the LFGB and the LMIDV. Depending on the facts, that ranges from a formal objection by the food inspectorate through an administrative offence with a fine to, in serious cases such as misleading information or a health risk, a criminal offence. The food business operator is and remains responsible (Article 8).
From the law to a finished label
However heavy the rules read, in practice labelling comes down to a clear sequence: record the recipe → calculate the nutrition values → derive the allergens from the ingredients → assemble the mandatory particulars → put them legibly on the label. That is the path Foodlex takes off your hands.
This article is general information and does not replace legal advice. What counts is the wording of the regulation as it applies at the time (Regulation (EU) No 1169/2011 and, for Germany, the LMIDV). The English text of the Regulation is quoted from the consolidated version of 1 January 2018 on EUR-Lex.