Guide · Bakery
Nutrition calculation for bakeries — duty, exemption and baking loss
Does a bakery have to show a nutrition table for every roll? The short answer: it depends on how you sell, not on whether the business is a craft bakery. This guide settles the duty, the important craft exemption, and how to calculate the values correctly.
Mandatory or not? It turns on how the food is supplied
- Loose over the counter (fresh rolls, slices of cake, bagged on request) — under Article 44 only the allergen information is mandatory. A nutrition declaration is not required.
- Prepacked goods (packaged bread on the shelf, self-service, mail order) — the full labelling applies in principle, nutrition declaration included … unless an exemption applies.
The craft exemption: Annex V no. 19
This is where an exemption central to bakeries comes in. Annex V no. 19 exempts from the mandatory nutrition declaration:
“Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer.”
The typical craft bakery selling its goods in its own shop or in local branches normally falls under this — and is exempt from the nutrition declaration, prepacked goods included. Three limits are worth knowing:
- “Small quantities” and “local” are not defined in figures in the Regulation — how they are read is for the national enforcement authorities. For nationwide mail order or wholesale, the exemption typically does not apply.
- Anyone who gives nutrition values voluntarily, or makes nutrition or health claims (“high in protein”, “reduced sugar”), loses the exemption for those statements — the full rules then apply.
- The exemption covers only the nutrition declaration. Allergens and the list of ingredients remain mandatory on prepacked goods.
In short: even where there is no duty, a voluntary and correct nutrition statement is often a selling point — for resellers, canteens or health-conscious customers.
How the values are calculated
The seven mandatory values (energy, fat, saturates, carbohydrate, sugars, protein, salt) follow from the ingredients. The energy value is not measured but calculated: Article 31(1) says it “shall be calculated using the conversion factors listed in Annex XIV”:
| Nutrient | Per gram |
|---|---|
| Fat | 37 kJ / 9 kcal |
| Carbohydrate (except polyols) | 17 kJ / 4 kcal |
| Protein | 17 kJ / 4 kcal |
| Fibre | 8 kJ / 2 kcal |
| Polyols | 10 kJ / 2,4 kcal |
| Alcohol (ethanol) | 29 kJ / 7 kcal |
| Organic acid | 13 kJ / 3 kcal |
| Salatrims | 25 kJ / 6 kcal |
| Erythritol | 0 kJ / 0 kcal |
On the label the energy appears in both units (kJ and kcal) — single values convert quickly with the kJ to kcal converter.
For the nutrient contents of the individual ingredients, Germany usually works from the German Federal Food Key (BLS) — the national nutrient database of the Max Rubner-Institut. Version 4.0 (December 2025) covers around 7,000 foods with up to 138 nutrient values each and is free to use for the first time.
The most common mistake: baking loss
A substantial part of the dough water evaporates during baking — in practice often around 10 to 20 % of the weight, depending on the product. The dry matter that carries the energy (flour, fat, sugar) stays almost constant, while the total weight drops noticeably.
Article 31(3) requires the values to be “those of the food as sold”, and Article 32(2) requires them per 100 g. Dividing the recipe’s nutrient totals by the dough weight spreads them over too much weight — the values per 100 g then come out systematically too low. The correct calculation is:
nutrient total of the recipe ÷ weight of the finished, cooled product × 100
In practice: weigh the baking loss of each product once (dough weight minus weight after baking) and carry it into the calculation as a factor.
Five steps to the nutrition table
- Record the recipe — every ingredient with exact quantities.
- Pull the nutrients per ingredient from a reliable database (the BLS).
- Sum across the whole recipe.
- Account for the baking loss and normalise to 100 g of the finished product.
- Calculate the energy value (Annex XIV) and output the table in the prescribed order.
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 31 and 32, Annex V and Annex XIV 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.