Basics · Labelling

UK food labelling regulations — what is the same as the EU, and what is not

· about 8 min read

Brexit did not give the UK a new food labelling law. It kept the old one, gave it a new legal status and changed a handful of lines. We compared the UK text with the current EU text word for word. The nutrition rules, the allergen list, the date marks and the minimum font size came out identical; three points did not.

Which law applies where

  • England, Wales, Scotland — Regulation (EU) No 1169/2011 in its UK version (“assimilated law”), plus national rules: the Food Information Regulations 2014, the Food Information (Wales) Regulations 2014 and the Food Information (Scotland) Regulations 2014.
  • Northern Ireland — Regulation (EU) No 1169/2011 in its EU version, plus the Food Information Regulations (Northern Ireland) 2014.

Northern Ireland is the exception because of the Windsor Framework. Article 5(4) of the Protocol: “The provisions of Union law listed in Annex 2 to this Protocol shall also apply … to and in the United Kingdom in respect of Northern Ireland” — and Regulation 1169/2011 is on that list, under “Food – general”. The Food Standards Agency puts it plainly: in Northern Ireland, “Retained EU law will not apply in these circumstances.”

The national regulations do two jobs: they make breaches enforceable, and they set the rules the EU text leaves to each country — above all for food that is not prepacked. That is where Natasha’s Law lives.

The twelve mandatory particulars

Article 9(1) is unchanged in the UK version. On prepacked food, “indication of the following particulars shall be mandatory”:

  1. the name of the food;
  2. the list of ingredients;
  3. any ingredient or processing aid listed in Annex II causing allergies or intolerances, “still present in the finished product, even if in an altered form”;
  4. the quantity of certain ingredients or categories of ingredients;
  5. the net quantity of the food;
  6. the date of minimum durability or the ‘use by’ date;
  7. any special storage conditions and/or conditions of use;
  8. the name or business name and address of the food business operator referred to in Article 8(1);
  9. the country of origin or place of provenance where provided for in Article 26;
  10. instructions for use where needed;
  11. for drinks over 1.2 % alcohol by volume, the actual alcoholic strength;
  12. a nutrition declaration.

What is word for word the same

We compared the UK version in force from 27 February 2025 with the EU consolidated version of 1 April 2025, after removing footnote markers and line breaks. Identical:

  • The nutrition declaration — energy, fat, saturates, carbohydrate, sugars, protein and salt, per 100 g or 100 ml, in that order (Articles 30 to 35, Annex XV). The energy conversion factors in Annex XIV and the reference intakes in Annex XIII are the same numbers.
  • The exemptions from the nutrition declaration in Annex V, including point 19 for “food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments …”.
  • The minimum font size — an x-height of at least 1.2 mm, or 0.9 mm if the largest surface is under 80 cm² (Article 13, Annex IV). See food label size.
  • Quantities of ingredients (QUID), Article 22 and Annex VIII, and date marking, Article 24 and Annex X.
  • How allergens are shown — emphasised in the ingredients list, Article 21(1). Thirteen of the fourteen Annex II entries read the same.

Where Great Britain differs

1. Mandatory information must be in English

The EU text asks for “a language easily understood by the consumers of the Member States where a food is marketed”. The UK version of Article 15(1):

“Without prejudice to Article 9(3), mandatory food information shall appear in English.”

Article 15(3) still allows the information “in several languages” — a bilingual English and Welsh label, for example, as long as the mandatory information is there in English.

2. Mustard has no behenic acid exception

Since 1 April 2025, EU Delegated Regulation 2024/2512 reads Annex II point 10 as “Mustard and products thereof, except: behenic acid with a minimum of 85 % of purity and obtained after two distillation steps used in the manufacturing of the emulsifiers E 470a, E 471 and E 477”. The UK version still reads:

“10. Mustard and products thereof;”

In practice: an E 471 made from mustard-derived behenic acid needs no mustard declaration in the EU and in Northern Ireland, but still does in Great Britain. If you buy emulsifiers, ask your supplier where the fatty acids come from. The mustard allergen guide describes the EU rule.

3. The responsible business must be in the British Islands

Article 8(1), UK version: the responsible operator is the one under whose name the food is marketed “or, if that operator is not established in the British Islands, the importer into the British Islands”. That operator’s name and address go on the label (Article 9(1)(h)). A business in Germany or France selling into Great Britain therefore needs a UK importer named on the pack.

Smaller differences

  • Customary names are judged by consumers “in the United Kingdom” (Article 2(2)(o)), not in the Member State of sale.
  • Article 17(2) and (3), which let a food keep the name it has in its country of production, are omitted in the UK version.
  • “Not for EU” marking concerns goods moved from Great Britain to Northern Ireland under the Windsor Framework’s retail movement scheme. In Great Britain itself the Marking of Retail Goods Regulations 2025 only require it where the Secretary of State issues a marking notice.

What is planned for 2027

In guidance for food manufacturers last updated on 30 July 2026, Defra writes that under a UK–EU sanitary and phytosanitary agreement Great Britain and Northern Ireland “will apply certain rules in line with the EU”, and:

“It is our intention that the agreement will take effect in mid-2027.”

On labelling, Defra names the behenic acid exception (“emulsifiers such as E 470a, E 471 and E 477 made from behenic acid will no longer require the word mustard to be highlighted”), food business addresses (“a UK or an EU food business operator address should be acceptable”) and origin labelling, where “non-UK” would be replaced by “EU” and “non-EU”. This is an intention, not law — Defra itself says the timing is “subject to negotiations”. Until it changes, the differences above apply.

Frequently asked questions

Does EU food labelling law still apply in the UK?

In Great Britain, Regulation (EU) No 1169/2011 continues as domestic law in a UK version that Parliament and the devolved governments can amend. In Northern Ireland, the EU version applies under the Windsor Framework. For most of the label the two versions are word for word the same.

Do UK labels have to be in English?

Yes. Article 15 of the UK version of Regulation 1169/2011 says that mandatory food information shall appear in English. Other languages may be added alongside.

Is mustard treated differently in the UK?

Yes, in one narrow case. Since 1 April 2025, EU law exempts highly purified behenic acid from mustard seeds used to make the emulsifiers E 470a, E 471 and E 477. The UK version of Annex II still reads simply “Mustard and products thereof”, so in Great Britain those emulsifiers still count as mustard.

Will UK labelling rules change in 2027?

The UK government intends a UK–EU agreement on sanitary and phytosanitary rules to take effect in mid-2027, under which Great Britain would follow EU rules on food labelling. That is a stated intention, not yet law; the exact date and scope are still being negotiated.

This article is general information and does not replace legal advice. Quoted from legislation.gov.uk: Regulation (EU) No 1169/2011 as it applies in Great Britain, revised version in force from 27 February 2025; compared with the EU consolidated version of 1 April 2025 (CELEX 02011R1169-20250401) and Delegated Regulation (EU) 2024/2512. Windsor Framework: Protocol on Ireland/Northern Ireland, OJ L 29, 31.1.2020. The plans for 2027 are quoted from Defra, Food manufacturing, processing and standards: preparing your business, as updated on 30 July 2026.