Food Fortification with Vitamins and Minerals Labelling Guide

The breakfast cereal aisle is one of the most instructive places in any supermarket. Pick up almost any box and you will find a nutrition panel listing added vitamins and minerals – iron, B vitamins, vitamin D, folic acid – often at levels far above what the base grain would provide naturally. That is food fortification in action, and it is one of the most commercially significant and legally regulated areas of food labelling in the UK.

Whether you are adding vitamin D to a plant-based drink, enriching a sports snack with B vitamins, or navigating the changes to mandatory flour fortification, this guide sets out exactly what the law requires, what it permits, and what it prevents.

What Is Food Fortification?

The deliberate addition of vitamins, minerals, or certain other substances to a food product for nutritional or physiological purposes is defined as food fortification. This includes:

• Restoring nutrients lost during processing (sometimes called restoration or enrichment)
• Adding nutrients that are not naturally present at significant levels
• Standardising nutrient levels across a product range for consistency

Fortification is different from using vitamins or minerals as food additives for technical purposes (such as using ascorbic acid as a preservative). If a vitamin or mineral is added for a technological function rather than a nutritional one, the additives legislation applies instead.

It is also distinct from food supplements, which are concentrated sources of vitamins or minerals sold in dose form. Supplements are governed by the Food Supplements (England) Regulations 2003, not by the fortification rules.

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The Legal Framework for Food Fortification in the UK

The Core Regulation Governing Voluntary Food Fortification

This area of regulation in Great Britain is governed by retained Regulation (EC) 1925/2006, as amended by the Nutrition (Amendment etc.) (EU Exit) Regulations 2019. This sets out which vitamins and minerals may be added to food, in what forms, and subject to what conditions.

The regulation applies to all food businesses that manufacture, process, distribute, sell, or import voluntarily fortified food in England, Scotland, and Wales. It does not apply to:

• Mandatory fortification required by law (such as flour and margarine – covered below)
• Food supplements governed by the Food Supplements Directive
• Foods for specific groups such as infant formula or medical foods
• Vitamins or minerals added for an additive function only

Northern Ireland continues to follow EU rules under the Windsor Framework. Businesses producing fortified food for sale in Northern Ireland, or exporting to the EU, must comply with the EU version of Regulation 1925/2006 and the EU Community Register rather than the GB VMS Register.

The GB VMS Register

On 1 January 2021, the UK government and devolved administrations in Scotland and Wales adopted the Community Register of Vitamins, Minerals, and Certain Other Substances as it stood on 31 December 2020. This is now the GB Vitamins, Minerals and Other Substances Register (GB VMS Register), maintained by DHSC.

The GB VMS Register contains:

• Annex I – the vitamins and minerals that may be added to food
• Annex II – the permitted forms (formulations) of those vitamins and minerals
• Annex III – substances that are prohibited, restricted, or under scrutiny

Any substance not listed in Annex I cannot be added to food as a fortification nutrient. Any form not listed in Annex II cannot be used even if the underlying nutrient is permitted. Both must be checked before any fortification programme is begun.

Why the Permitted Form Matters for Food Fortification

Different chemical forms of the same vitamin or mineral have different bioavailability, stability, and behaviour in food matrices. The regulation requires the form used to be bioavailable – that is, capable of being absorbed and used by the body – and only forms listed in Annex II meet this requirement in law.

For example, if you want to add vitamin C to a food product, you can use L-ascorbic acid, calcium-L-ascorbate, potassium-L-ascorbate, or several other forms, all of which are listed in Annex II. Using a form not on this list is a criminal offence even if the overall vitamin C addition is otherwise compliant.

Keeping Up With Changes to the GB VMS Register for Food Fortification

The GB VMS Register is not static. DHSC publishes bulletins when amendments are made. Businesses should subscribe to or periodically check the register, as new permitted substances and forms are added over time – and the EU Community Register may also diverge from the GB list post-Brexit, creating differences for businesses operating in both markets.

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Foods That Cannot Be Fortified

The regulation prohibits the addition of vitamins and minerals to certain categories of food regardless of which nutrients are being added:

• Unprocessed foods – raw fruits, vegetables, meat, poultry, and fish cannot be fortified
• Alcoholic beverages containing more than 1.2% ABV – with a narrow exception allowing trace quantities of vitamins or minerals as authenticity markers, which are outside the scope of the regulation
• Any food where the fortification would pose a safety risk

These restrictions are absolute. There is no process for obtaining an exemption.

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Mandatory Food Fortification in the UK

Voluntary nutrient enrichment under Regulation 1925/2006 sits alongside a separate and older body of law requiring certain foods to be fortified by default. These mandatory requirements are outside the scope of Regulation 1925/2006 but directly affect businesses in those sectors.

Flour and Bread

The Bread and Flour Regulations 1998 require that non-wholemeal wheat flour must be fortified with specific levels of:

• Calcium carbonate (chalk)
• Iron
• Thiamin (vitamin B1)
• Niacin (vitamin B3)

Wholemeal flour is exempt because it retains the wheat germ, which is naturally rich in these nutrients.

The Folic Acid Requirement: A Major Change for Food Fortification

In December 2024, the Bread and Flour (Amendment) Regulations 2024 added a further mandatory requirement. Non-wholemeal wheat flour must now also be fortified with folic acid at 250 micrograms per 100g of flour, with a transition period of 24 months. UK flour millers began introducing folic acid into flour from September 2025.

The folic acid requirement comes into full effect from 1 October 2026. Any non-wholemeal wheat flour placed on the market from that date must meet the new requirement. The change applies to flour used in bread, pasta, pastry, and any other products where non-wholemeal wheat flour is the primary ingredient.

This is a significant labelling change as well as a compositional one. Folic acid must be declared in the ingredients list for all affected products, and the nutrition table must be updated to reflect the new level. Businesses should liaise with their flour suppliers to confirm when fortified flour will be supplied and plan label updates accordingly.

Food Fortification with Folic Acid: What the Science Says

The decision to mandate folic acid addition was driven by public health evidence. Adequate folic acid intake in early pregnancy substantially reduces the incidence of neural tube defects such as spina bifida. Mandatory enrichment of flour is considered the most cost-effective population-level intervention, given that many pregnancies are unplanned and dietary supplementation alone has proven insufficient to reach the whole population.

Margarine

Margarine and other fat spreads have been subject to mandatory fortification with vitamins A and D since the 1940s under the Spreadable Fats (Marketing Standards) and Related Matters Regulations. This remains in force.

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Voluntary Food Fortification: The Rules in Practice

The Significant Amount Requirement

The central compliance rule for voluntary micronutrient addition is the significant amount requirement. To be classified as a fortified food and to make any related claim, the final product must contain at least 15% of the Nutrient Reference Value (NRV) for the relevant vitamin or mineral per 100g (for solids) or per 100ml (for liquids).

This threshold must be maintained throughout the entire shelf life of the product, not just at the point of manufacture. Because vitamins can degrade during storage, manufacturers typically add an overage – a calculated additional quantity – to ensure the significant amount is still present at best before date.

For single-serve products where the recommended serving is less than 100g or 100ml, the 15% NRV threshold applies to the amount in a typical serving rather than per 100g.

No Maximum Levels

Unlike the EU, which has been working toward establishing maximum levels for voluntary vitamin and mineral addition to food, Great Britain has not yet set maximum amounts under Regulation 1925/2006. This means the 15% NRV minimum is the only compositional floor for voluntary nutrient addition, beyond the general requirement that the food must be safe.

Businesses should nonetheless be guided by safe upper level recommendations published by the Expert Group on Vitamins and Minerals (EVM), and should not add vitamins or minerals at levels that could pose a safety risk to the population. The regulation gives DHSC power to restrict or prohibit specific additions where safety concerns arise.

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Labelling Requirements for Fortified Food

What Must Appear on a Fortified Food Label

When vitamins or minerals have been added to a food, this must be declared on the label. The specific requirements are:

• The names and total amounts of the vitamins and minerals added must appear on the label
• Total amounts include both added nutrients and those naturally present in the food
• Amounts must be declared per 100g or per 100ml, and as a percentage of the NRV
• Added vitamins and minerals must also appear in the ingredients list in descending order of weight

You cannot describe a food as fortified or enriched, or use any claim about a vitamin or mineral, unless the significant amount threshold is met and the declaration is made correctly in the nutrition table.

Making Claims on Fortified Food Labels

Adding vitamins and minerals to a product creates the nutritional basis for making “source of” or “high in” claims under Regulation 1924/2006 on nutrition and health claims. But meeting the fortification threshold does not automatically authorise a claim – the claim must also be on the GB NHC Register and all conditions of use must be met.

In practice, this means a food business adding vitamin D to a plant milk at 15% NRV per 100ml can legitimately claim “source of vitamin D” – provided the claim wording matches the register and the nutrition table correctly declares the vitamin D content. All three elements must be in order: the nutrient level, the label declaration, and the claim wording.

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EU/UK Divergence and the Road to Re-alignment

How Food Fortification Rules Differ Between GB and the EU

Since 1 January 2021, the GB VMS Register and the EU Community Register have been able to develop independently. In practice, divergence has been limited so far – the initial lists were identical – but it is growing over time as each jurisdiction adds new permitted substances and forms.

The key practical implication is that businesses selling fortified food in both Great Britain and the EU (or Northern Ireland) need to check both registers. A form of vitamin or mineral approved after January 2021 in one register is not automatically approved in the other.

The UK-EU SPS Agreement of May 2025 is expected to bring GB rules back into alignment with EU rules by mid-2027. For fortified products, this is likely to include re-alignment of the permitted substances lists and potentially the introduction of EU-style maximum levels if these are established before re-alignment takes effect. Businesses should plan for label reviews ahead of mid-2027.

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Regulatory Sources

• GB VMS Register: gov.uk/government/publications/great-britain-register-on-the-addition-of-vitamins-minerals-and-other-substances
• DHSC Fortified Foods Compliance Guidance: gov.uk/government/publications/fortified-foods-guidance-to-compliance-with-european-regulation-ec-no-1925-2006
• Retained Regulation EC 1925/2006: legislation.gov.uk/eur/2006/1925
• Addition of Vitamins, Minerals and Other Substances (England) Regulations 2007: legislation.gov.uk/uksi/2007/1631
• Bread and Flour (Amendment) Regulations 2024: legislation.gov.uk/uksi/2024/1162
• FSA Nutrition Labelling Guidance: food.gov.uk/business-guidance/nutrition-labelling
• EVM Safe Upper Levels for Vitamins and Minerals (2003): gov.uk/government/publications/safe-upper-levels-for-vitamins-and-minerals
• UK-EU SPS Agreement (May 2025): gov.uk/government/news/uk-eu-sps-agreement-information-for-businesses

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Frequently Asked Questions

Do I need to register or notify anyone before launching a fortified food product?

No. There is no requirement to register or notify any authority before placing a voluntarily fortified food on the market in Great Britain. It is entirely your responsibility as the food business operator to ensure compliance with Regulation 1925/2006 and all other relevant food law. Trading Standards enforces compliance through inspection.

Can I add any vitamin or mineral I choose to my product?

No. Only vitamins and minerals listed in Annex I of the retained Regulation may be added. The form you use must also be listed in Annex II. If a nutrient or form is not on the relevant list in the GB VMS Register, adding it is a criminal offence. Always check the current register before formulating a new fortified product – the lists are updated periodically.

My product will be on shelf for 18 months. How do I ensure the significant amount is still present at best before date?

You need to calculate and add an overage – an additional quantity of the vitamin or mineral above the 15% NRV threshold – to compensate for degradation during storage. The size of the overage depends on the specific nutrient, the food matrix, the packaging, and the storage conditions. Your vitamin or mineral supplier should be able to provide degradation data to support this calculation.

Does mandatory folic acid fortification of flour affect my product labelling?

If your product contains non-wholemeal wheat flour as an ingredient, yes. Folic acid must be declared in your ingredients list and your nutrition table must reflect the folic acid content. The requirement comes into full force from 1 October 2026. Transition planning should begin now, particularly if you have long lead times for label artwork and print runs.

I am adding vitamin C to my product mainly as an antioxidant – does the fortification regulation apply?

Not if the primary purpose is additive (technological). If you are adding ascorbic acid purely as an antioxidant preservative, it falls under additive legislation rather than Regulation 1925/2006. However, if you subsequently want to claim the vitamin C content for nutritional purposes or make a “source of vitamin C” claim, the fortification rules and the nutrition and health claims rules will both become relevant. Keep a clear record of the intended function.

Can I sell my fortified food in Northern Ireland and the EU using the same label as in Great Britain?

Possibly, but with care. Northern Ireland and the EU follow the EU version of Regulation 1925/2006 and the EU Community Register. If you are using forms of vitamins or minerals approved in the GB VMS Register after January 2021, these may not yet be approved in the EU register. Check both registers for every ingredient before producing a single label for multi-market use.

What happens if I add vitamins or minerals at levels above the significant amount but below any known safe upper level?

Currently permissible in Great Britain, as no maximum levels have been set under the regulation. However, DHSC has powers to restrict additions where safety concerns emerge, and the EVM safe upper level guidance represents current best practice. Adding nutrients at very high levels without safety justification is a regulatory and reputational risk, and should be avoided. Post-2027 SPS re-alignment may introduce EU-style maximum levels that would constrain this further.

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How Positive ID Labels Can Help

Adding vitamins and minerals to your product changes what needs to go on your label – and getting it right matters.

Every time a vitamin or mineral is added, the ingredients list changes, the nutrition table changes, and potentially the front-of-pack claims change too. The mandatory folic acid requirement alone will affect every product that contains non-wholemeal wheat flour – that is a significant proportion of ambient bakery, pasta, and processed food labels across the UK. Businesses that have built up stock of pre-printed labels need to plan a print transition carefully.

At Positive ID Labels, we work with food manufacturers across a wide range of sectors on exactly this kind of label update cycle. Our Xeikon digital press at 1200dpi is the right tool for labels where nutrition tables, added vitamin declarations, and front-of-pack claims all need to coexist with precision and legibility at the mandatory minimum 1.2mm x-height. When space is tight and the regulatory content is dense, print quality is not optional.

For products where the label environment is demanding – ambient bakery packaging with condensation risk, chilled or frozen products, beverages – our Screen UV inkjet press produces polypropylene labels with excellent durability and colour stability. Nutrition information that fades or becomes illegible is a compliance failure, not just a cosmetic one.

Short run label trials before committing to volume are available on the Jetrion – useful when you are reformulating or re-labelling ahead of a regulatory deadline and need to verify the layout before the full print run.

Call 01332 864895 for a free quote and specification review. We help food businesses get compliant labels produced accurately and quickly – most digital orders ship within 3 to 5 days. Quality, speed, service, and value from a Derby label manufacturer with over 20 years of experience.

All guides are provided in good faith for information purposes only and do not constitute legal advice. For specific compliance questions about specific labelling laws, contact a specialist or contact your local Trading Standards authority. Read our Regulatory Information Disclaimer

All food labelling guides are provided in good faith for information purposes only and do not constitute legal advice. For specific compliance questions about specific labelling laws, contact a specialist or contact your local Trading Standards authority. Read our Regulatory Information Disclaimer