Guide · Labelling
The list of ingredients — the rules, with a worked example
Descending order of weight, water, allergens, compound ingredients, additives and percentages — the list of ingredients has more rules than it looks. This guide walks through all of them with a complete example and the exact references in Regulation (EU) No 1169/2011.
An example first
A chocolate and nut muesli made from 1 kg of ingredients: 450 g oat flakes, 200 g spelt flakes, 120 g milk chocolate, 100 g hazelnuts, 80 g cornflakes, 40 g sunflower seeds and 10 g cinnamon. Its list of ingredients looks like this:
Chocolate & nut muesli
Ingredients: oat flakes, spelt flakes, milk chocolate 12 % (sugar, cocoa butter, whole milk powder, cocoa mass, emulsifier: sunflower lecithins), hazelnuts 10 %, cornflakes (maize, sugar, salt), sunflower seeds, cinnamon.
- A heading that includes the word “ingredients” (Art. 18(1)).
- Descending order of weight at the time of manufacture: 450 g oat flakes first, 10 g cinnamon last (Art. 18(1)).
- A compound ingredient with its overall share, immediately followed by its own ingredients in brackets (Annex VII Part E no. 1).
- A percentage, because chocolate and nuts appear in the name of the muesli (Art. 22(1)(a)).
- An additive with its category name and specific name (Annex VII Part C).
- Allergens emphasised — using the Annex II name: oats, spelt (wheat), milk, hazelnuts (Art. 21(1)).
When is a list of ingredients mandatory?
The list of ingredients is one of the mandatory particulars under Article 9(1)(b). That list applies to prepacked food: food packaged before being offered for sale in such a way that the contents cannot be altered without opening or changing the packaging (Art. 2(2)(e)). In outline:
| Situation | List of ingredients? |
|---|---|
| Prepacked food | Yes (Art. 9(1)(b)) |
| Prepacked on the premises for direct sale and offered in self-service | Yes in Germany under § 4(1) LMIDV — except for long-life baked goods and confectionery packed that way in the shop, where customers are informed another way |
| Loose food, packed on request, a counter, a restaurant | No — but the allergen particulars are mandatory (Art. 44(1); in Germany § 4(2) to (4) LMIDV) |
| Beverages containing more than 1.2 % alcohol by volume | Not under the Regulation, unless another Union provision requires one (Art. 16(4)) — but in Germany yes for prepacked beer (§ 3(1) LMIDV) |
| Packaging whose largest surface is under 10 cm² | Not on the pack — the particulars have to be provided by other means or on request (Art. 16(2)) |
Under Article 19(1) these foods need no list of ingredients either:
- “fresh fruit and vegetables, including potatoes, which have not been peeled, cut or similarly treated”,
- carbonated water whose description indicates that it has been carbonated,
- fermentation vinegars derived exclusively from a single basic product, with no other ingredient added,
- cheese, butter, fermented milk and cream, to which no ingredient has been added other than lactic products, food enzymes and micro-organism cultures essential to the manufacture, or the salt needed for cheese other than fresh or processed cheese,
- foods consisting of a single ingredient, where the name of the food is identical to the ingredient name or enables the nature of the ingredient to be determined.
The basic rule: descending order of weight
Under Article 18(1) the list of ingredients “shall include all the ingredients of the food, in descending order of weight, as recorded at the time of their use in the manufacture of the food”. What counts is the weight as weighed in, not in the finished product — the exceptions for water follow below. It has to be headed or preceded by a suitable heading which consists of or includes the word “ingredients”.
Every ingredient appears under its specific name (Art. 18(2)). An ingredient, per Art. 2(2)(f), is any substance used in the manufacture and still present in the finished product, even in an altered form — expressly including flavourings, additives and food enzymes and every constituent of a compound ingredient. Residues are not ingredients. Engineered nanomaterials get the word “nano” in brackets (Art. 18(3)).
Water and the other order rules
Annex VII Part A adjusts the basic rule in a few cases. The important ones:
| Case | Rule |
|---|---|
| Added water and volatile products | Listed in order of their weight in the finished product. The amount of added water is the total amount of the finished product minus the other ingredients. It need not be taken into account if it does not exceed 5 % by weight — the derogation does not apply to meat, meat preparations, unprocessed fishery products and unprocessed bivalve molluscs (no. 1) |
| Ingredients used concentrated or dehydrated and reconstituted during manufacture | May be listed in order of weight as recorded before their concentration or dehydration (no. 2) |
| A dried product to which water has to be added (soup powder) | May be listed in order of proportion in the reconstituted product, with an expression such as “ingredients of the reconstituted product” (no. 3) |
| A mixture of fruit, vegetables or mushrooms with none predominating | May be grouped as “fruit”, “vegetables” or “mushrooms” followed by “in varying proportions”, immediately followed by the list (no. 4) |
| Mixtures of spices or herbs with none predominating | May be listed in a different order with an expression such as “in varying proportions” (no. 5) |
| Ingredients under 2 % of the finished product | May be listed in a different order after the other ingredients (no. 6) |
| Refined vegetable oils or fats | May be grouped as “vegetable oils” or “vegetable fats”, immediately followed by the vegetable origin; hydrogenated ones marked “fully hydrogenated” or “partially hydrogenated” (nos. 8 and 9) |
What does not go in the list
Article 20 takes certain constituents out — expressly without prejudice to Article 21, so allergens still have to be declared. The list need not include:
- constituents temporarily removed during manufacture and later reintroduced without exceeding their original proportions (point a),
- additives and food enzymes present only because they were contained in an ingredient and no longer serve a technological function in the finished product, and those used as processing aids (point b),
- carriers and other substances used in the quantities strictly necessary (point c),
- substances that are not additives but are used in the same way and with the same purpose as processing aids (point d),
- water used to reconstitute a concentrated or dehydrated ingredient, and the liquid medium not normally consumed (point e).
Emphasising allergens
The 14 substances and products of Annex II are listed under their Annex II name and emphasised — “through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour” (Article 21(1)(b)). What is emphasised is that name, not necessarily the whole word: oat flakes, whole milk powder.
- Inside the brackets too: the constituents of a compound ingredient are ingredients in their own right (Art. 2(2)(f)) — an allergen there is emphasised just the same.
- With no list of ingredients, the indication is the word “contains” followed by the Annex II name (Art. 21(1), second subparagraph).
- Not required where “the name of the food clearly refers to the substance or product concerned” (Art. 21(1), last subparagraph).
The complete list is in the 14 allergens, the full set of rules in allergen labelling.
Compound ingredients
A compound ingredient is itself made of more than one ingredient (Art. 2(2)(h)) — chocolate, stock, cornflakes, a filling. Under Annex VII Part E no. 1 it appears under its legal or customary name, by its overall weight, “provided that it is immediately followed by a list of its ingredients” — in the example above, “milk chocolate 12 % (sugar, cocoa butter, …)”.
Under Part E no. 2 that inner list is not required in only three cases:
- (a) the composition of the compound ingredient is defined in current Union provisions and it constitutes less than 2 % of the finished product — additives still have to be given, so far as Art. 20(a) to (d) does not exempt them;
- (b) the compound ingredient is a mixture of spices and/or herbs constituting less than 2 % of the finished product — again with the exception of additives;
- (c) the compound ingredient is a food for which Union provisions do not require a list of ingredients.
Part E no. 2 also applies without prejudice to Article 21: if a spice blend under 2 % contains mustard, the mustard still has to be named and emphasised.
Category names, additives and flavourings
Annex VII Part B allows certain ingredients that are a constituent of another food to be shown by a category name instead of their specific name — again without prejudice to Article 21. A selection:
| Ingredient | Category name |
|---|---|
| All types of sucrose | “sugar” (no. 11) |
| Glucose syrup and dried glucose syrup | “glucose syrup” (no. 13) |
| All starches that have not been chemically modified | “starch” (no. 4) |
| Mixtures of flour from two or more cereal species | “flour”, followed by the cereals in descending order of weight (no. 3) |
| All types of cheese or fish, where the name and presentation do not refer to a specific type | “cheese” or “fish” (nos. 6 and 5) |
| Spices or herbs not exceeding 2 % by weight | “spice(s)” or “mixed spices”, “herb(s)” or “mixed herbs” (nos. 7 and 8) |
| All types of milk protein (caseins, caseinates, whey proteins) | “milk proteins” (no. 14) |
Additives follow Part C: the name of their category, followed by their specific name or E number — “emulsifier: sunflower lecithins”. All 24 categories and the additional statements are in additives and E numbers. Flavourings follow Part D: they are designated as “flavouring(s)” or by a more specific name or description; “natural” may only be used on the conditions of Article 16 of Regulation (EC) No 1334/2008. Quinine and caffeine used as a flavouring are named immediately after the word “flavouring”.
Percentages (QUID)
Under Article 22(1) the quantity of an ingredient or category of ingredients has to be given where it
- “appears in the name of the food or is usually associated with that name by the consumer” (point a),
- “is emphasised on the labelling in words, pictures or graphics” (point b), or
- “is essential to characterise a food and to distinguish it from products with which it might be confused” (point c).
What is given is a percentage of the quantity at the time of use — in or immediately next to the name of the food, or in the list of ingredients beside the ingredient concerned (Annex VIII no. 3). In the example, “chocolate” and “nut” are in the name, so “milk chocolate 12 %” and “hazelnuts 10 %”. Where a food has lost moisture through baking or another treatment, the percentage relates to the finished product; where that would exceed 100 %, the weight of the ingredient used per 100 g of finished product is given instead (no. 4(a)).
No quantity is needed, among other cases, for an ingredient whose drained net weight is given, one used in small quantities for flavouring, or one that, although named in the food’s name, does not govern the consumer’s choice (Annex VIII no. 1).
Common mistakes
- Ordering by the finished product instead of by weight at the time of use — only added water and volatile products go by the finished product.
- Bought-in ingredients with no inner list — chocolate, stock or a filling need their own brackets, unless one of the three Part E no. 2 cases applies.
- Allergens only in a separate list underneath — they belong emphasised in the list of ingredients.
- An additive without its category name (“E 322” alone).
- “Spices” above 2 % — the category name is only allowed up to 2 % by weight.
- A forgotten percentage, although the ingredient is in the name or pictured on the pack.
- No heading — the word “ingredients” has to appear.
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 (Articles 18 to 22 and Annexes VII and VIII of Regulation (EU) No 1169/2011). The English text of the Regulation is quoted from the consolidated version of 1 January 2018 on EUR-Lex.