Food label compliance is a legal obligation, not a suggestion. Every piece of information on your label – from the product name to the fine print allergen declarations – is governed by regulations designed to protect consumers and ensure transparency in the food supply chain.

But understanding food label compliance doesn’t require a law degree. You need to know what information is mandatory, how it must be presented, and how to keep labels accurate as your business evolves. This blog covers all three.

What Regulations Govern Food Labels In The UK?

The primary regulation is the Food Information to Consumers Regulation (FICR), officially Regulation (EU) No 1169/2011, which was retained into UK law following Brexit. Alongside this are the Food Standards Act 1990, specific regulations for Wales, Scotland, and Northern Ireland, and various product-specific regulations (e.g., for meat, fish, dairy).

In practical terms, this means:

For prepacked foods (pre-packaged before sale to the consumer), comprehensive labelling rules apply to all information visible to customers.

For non-prepacked foods (sold loose from a display), fewer formal labelling rules apply but allergen information must still be clearly communicated.

For prepacked for direct sale (PPDS) foods, Natasha’s Law adds the requirement for full ingredient lists and emphasises allergens, even on items made in-house and sold immediately.

Understanding which category your product falls into determines which rules apply. Most labelling mistakes happen because businesses don’t clearly identify their category and apply the wrong rules.

The Mandatory Information: What Must Be On Every Food Label?

Every food label legally must include:

1. Product Name

The product name (or “food name”) must be accurate and not misleading. For example:

“Tuna Salad” is accurate. “Tuna-Style Salad” is required if tuna percentage falls below standards. “Vegetable Mix” is accurate. “Garden Vegetables” is potentially misleading if it contains mostly corn and peas from non-garden sources.

For products with legal names established in law (e.g. chocolate, jam, certain cheeses), you must use the legal name if your product meets the compositional standard. If it falls short, you must use a descriptive name instead. Using a legal name for a product that doesn’t meet the standard is a food labelling breach.

2. Ingredients List

A complete list of all ingredients in descending order by weight. Each ingredient must be named clearly enough that a consumer understands what they’re buying.

Examples of acceptable labels: “wheatflour” or “flour (wheat).” Not acceptable: “flour” without specification if it’s not wheat, or “spices” without listing individual spices (some may be allergens).

Water doesn’t need to be listed unless it represents more than 5% of the final product weight.

3. Allergen Declaration

All 14 regulated allergens – celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, sesame, soya, sulphites, and their derivatives must be clearly identified when present in ingredients.

For prepacked foods, allergens can be listed in the ingredients list (with emphasis). For PPDS foods, they must appear in the ingredients list with clear visual emphasis.

“May contain” warnings for allergens are permitted only where cross-contamination risk has been formally assessed. These are not blanket precautions; they must be based on documented risk.

4. Date Marking

Use-by date: Required for foods that spoil quickly and pose a food safety risk if consumed after the date (chilled meats, fresh dairy, pre-made sandwiches, foods requiring refrigeration). Selling food past its use-by date is a criminal offence.

Best-before date: Used for foods that maintain safety but may decline in quality after the date (shelf-stable products, frozen foods, dried goods). Selling best-before food isn’t illegal, but the product’s quality may be diminished.

Format: Most commonly DD/MM/YYYY or DD/MM (if year is obvious).

Storage instructions: If a best-before date depends on specific storage conditions (e.g. “once opened, consume within 3 days if refrigerated”), these instructions must be clearly visible.

5. Net Quantity

The weight or volume of the product must be clearly stated, for example, “250g” or “500ml.” This must be accurate within defined tolerances (typically ±5% for small packages).

6. Nutrition Declaration

Nutritional information (energy, fat, saturated fat, carbohydrate, sugar, protein, salt per 100g, and sometimes per serving) is now mandatory for most prepacked foods. Exemptions exist for very small businesses and certain products, but these are narrow.

If a claim is made about nutrition or health (“high protein,” “low fat,” “source of fibre”), full nutrition information is required.

7. Name And Address Of The Food Business Operator

The business responsible for the food must be clearly identified with a name and address. This doesn’t have to be the manufacturer, it can be the distributor, packager, or seller, but someone must be named.

Format: “Packed by [Business Name], [Address]” or “Manufactured by…” or similar.

8. Country Of Origin (For Some Products)

For meat products (beef, pork, poultry, sheep), country of origin is mandatory. For other foods, it’s required only if its absence would mislead consumers about origin (e.g. a product labelled to appear British but made elsewhere).

9. Instructions For Use (If Needed)

If a product requires specific preparation or storage instructions to be used safely, these must be clear. Examples: “Heat to 75°C before serving,” “Keep frozen until use,” “Store in a cool, dry place.”

How Information Must Be Presented: The Format Requirements

Beyond what must be included, food labels have specific presentation requirements:

Legibility: All mandatory information must be clear, legible, and permanent. A minimum x-height (letter height) of 1.2mm for most information and 0.9mm for ingredient lists on small labels. Black or dark text on a light background is strongly recommended for contrast.

Language: Labelling must be in English (in Wales, bilingual English/Welsh). Information must not be in language the consumer cannot read unless translation is provided elsewhere.

Prominence: Mandatory information must be equally prominent. You cannot hide allergen information in tiny text while splashing your brand name large.

Spacing: Allergen information must stand out from non-allergenic ingredients through bold text, a different colour, capitals, or clear separation. Emphasis is not optional but the style of emphasis is – and it must be declared.

Durability: Labels must remain legible throughout the food’s shelf life under normal storage conditions. Ink that fades in sunlight or adhesive that fails in chilled cabinets means the label fails compliance.

How To Maintain Compliance: The Operational Reality?

Getting labels compliant initially is step one. Maintaining compliance as your business evolves is ongoing.

When recipes change: Update your ingredient list and allergen information immediately. Don’t use old stock of labels until you’ve confirmed they’re still accurate.

When suppliers change: Request new ingredient declarations from suppliers. Verify allergen status. Update labels.

When storage conditions change: If you move from shelf-stable to chilled display, or vice versa, your date marking and storage instructions may need updating.

When claimed benefits change: If you add a “source of fibre” claim, you must add full nutrition information. If you add a health claim, regulations tighten further.

When you enter new markets: Labels for Scotland, Wales, and Northern Ireland have slightly different regulatory frameworks. Ensure labels meet all requirements for the regions where you sell.

Compliance is not static. It evolves with your business.

Special Cases: When Standard Requirements Change

For Loose (Non-Prepacked) Foods

Foods sold loose from a display case (deli counter meat, fresh bakery items, farmers’ market produce) have fewer formal labelling requirements. However:

Allergen information must still be communicated either on signage, in staff knowledge, or through a menu. A customer with a tree nut allergy must be able to determine if your muffins are safe.

Origin can sometimes be communicated verbally rather than on a label (e.g. “These are locally sourced apples from Kent Farm”).

Ingredient lists are not always required on small labels for loose goods, though it’s becoming common practice.

For Very Small Businesses

An exemption exists for very small food businesses with annual turnover below €1 million (approximately £850,000). However, this exemption:

Does not include allergen information. You must still declare allergens clearly.

Does not include use-by dates for foods requiring them. Use-by marking is never optional.

Can be revoked if a business fails to maintain standards.

Most small food businesses don’t qualify for the exemption because they exceed the turnover threshold or operate in categories (fresh foods, allergen-containing products) where the exemption doesn’t apply.

For Catering Operations

Catering businesses operate under different rules to retail. Allergen information must be available (on menus, in staff knowledge, through signage), but formal labels are less critical. However, if you pre-package food for direct sale, PPDS rules and Natasha’s Law apply.

Common Compliance Gaps

Even conscientious businesses often miss these:

Allergens mentioned in ingredients but not emphasised. The legal requirement is for the allergens to be clearly differentiated

Inconsistent date formats across product range. If some products show DD/MM/YYYY and others show MM/DD/YYYY, this may result in confusion.

Storage instructions missing from best-before dates that depend on storage. If a sauce lasts 6 weeks unopened but only 2 weeks open in the fridge, this must be stated.

Nutrition information missing from products making health claims. If your label says “high protein,” nutrition information becomes mandatory.

Address too small or unclear. The food business address must be legible, not buried in 6pt font. All text must have a minimum text size of 1.2mm for the ‘x’ character height.

Ingredients described vaguely. “Seasonings” instead of individual spices. “Plant-based oil” instead of specifying which oils.

FAQ: Your Food Label Compliance Questions Answered

Q: Do I need a lawyer to check my labels for compliance?
A: No, but trading standards guidance is free and authoritative, and shows willingness for compliance. Most local authorities offer free compliance advice. A label manufacturer experienced in food label compliance like Positive ID Labels can also catch errors. You can find your local trading standards department here: https://www.gov.uk/find-local-trading-standards-office 

Q: What happens if my label is non-compliant?
A: Trading standards can issue an improvement notice (giving you time to fix), an emergency prohibition (removing product from sale immediately), or prosecution. Penalties include fines up to £20,000 and potential criminal record for serious breaches. In our experience, trading standards departments just want to work with you to help you meet your compliance requirements.

Q: Can I use a PDF of a label or must it be printed?
A: Labels must be physically attached to the product or packaging. A PDF is not a label. However, digital menus or downloadable information can supplement physical labels for catering operations – particularly useful if you want to convey more information about your product, or want to have multiple language options for your customers.

Q: Do I need to list flavourings if I don’t know the specific ingredients?
A: You must list “flavourings” or “natural flavourings,” but you should request full ingredient details from your supplier. If those flavourings contain allergens, you must declare them. Some additives require additional declarations e.g. E102 Tartrazine requires a statement ‘may have an adverse effect on activity and attention in children‘.

Q: Can I list “sugar” without specifying the source (sugar cane vs beet)?
A: Yes. The source doesn’t matter for compliance unless the source affects allergen status or you’re making specific claims (e.g. “cane sugar”).

Q: What’s the difference between “contains” and “may contain”?
A: “Contains milk” means milk is a deliberate ingredient. “May contain milk” means cross-contamination is possible but milk isn’t intentionally added. These require different levels of justification and risk assessment. A common practice that covers the entire food business is to add a statement saying something like “Made in a facility that also processes milk, celery, fish”. Those items may not be deliberately in the product but may cross contaminate.

Q: How often do I need to review my label compliance?
A: At minimum you should review everything annually. More realistically, whenever ingredients, suppliers, recipes, or claims change, update your systems immediately. Also when regulations change — trading standards authorities notify businesses of changes.

Q: Can I change label information without notifying customers?
A: You can change recipes and labels as a normal business practice. However, if a change affects allergen status significantly, consider notifying customers already consuming the product (e.g., “We’ve reformulated our chocolate bar; it now contains sesame”).

Q: Is there a grace period for selling old stock when I change labels?
A: No official grace period. Once new labels are required, old labels should not be used. In practice, authorities often allow a reasonable period to sell existing stock (a few weeks), but this is not guaranteed and entirely at the trading standards officer’s discretion.

Q: Who is liable if my food causes an allergic reaction?
A: The food business operator: the person or company whose name appears on the label. This liability exists even if you outsource label printing or manufacturing. You are responsible for the accuracy of information on your label.

Moving Forward: Your Compliance Checklist

Before you print labels:

• Have you listed every ingredient, including water, salt, and spices?
• Are all 14 regulated allergens identified where present?
• Is allergen emphasis clear and immediately obvious?
• Is the product name accurate and not misleading?
• Is date marking correct (use-by vs best-before)?
• Are storage instructions included if they affect shelf life?
• Is the food business address clear and legible?
• Is nutrition information included (if required for your product)?
• Is the country of origin listed (if required)?
• Are all words legible at normal viewing distance?

If you can answer “yes” to all these, your labels are compliant.

Getting Help With Compliance

Your local trading standards authority offers free guidance. The Food Standards Agency (FSA) publishes detailed compliance guidance. Food labelling consultants and experienced label manufacturers can review labels for compliance.

At Positive ID Labels, we work with food businesses to ensure their labels are compliant before they’re printed. We review ingredient lists, check allergen emphasis, verify date marking, and confirm legibility. We also produce labels on materials proven to remain legible throughout shelf life.

Have questions about whether your labels are compliant, or need advice on updating them? Call us on 01332 864895. We’ll review your labelling requirements, identify any gaps, and advise on how to fix them. Or fill out our contact form and we’ll call you back within one working day.

Compliance protects your customers and your business. It’s worth getting right.