37 LABELLING – Food and Drink – Good Manufacturing Practice, 7th Edition



The labelling and presentation of the product, which includes any information printed on or implied by the shape or design of the packaging or by the application of labels to the packs, must correctly correspond to the product concerned, and must comply with the legislative requirements of the country in which the product is to be sold.


37.1 In many manufacturing units there will be some combination of different products, different sizes of a given product and different versions of a given product (e.g. variations in composition, branding or language), and it is essential to ensure that the correct supply of packaging and/or label is selected. The correctness of selection should be independently checked by the production management team and quality control before a production run, and any residual material from a previous production run removed from the production area (see 35.12). This should be controlled by formal documented procedures that are verified on a regular basis.

37.2 When a new pack or label design is introduced for a product, residual stocks of the obsolete packaging or label should be destroyed at the designated changeover time. Similarly, where packaging or labels are reference coded or date marked before use, surplus material left from earlier production and bearing a reference or date that is no longer valid should be withdrawn from the production area and destroyed. Redundant packaging can incur significant costs and needs to be effectively managed.

37.3 A particular source of selection error may be the circumstance of material being packed and/or processed in unmarked containers, which are then stored unlabelled for a period of time before being labelled or placed in further containers carrying the required information. All such stored material should be identified with full information to enable it to be correctly labelled in due course, with adequate precautions to ensure that its full identity is not lost (see Chapter 14).

37.4 The task of designing packaging or labels that while fulfilling the presentation wishes of the manufacturer also comply with the requirements of the law of the country for which the product is intended is a complex and difficult one. Legislative requirements governing the labelling of a product are rarely to be found in a single law. In addition to general labelling regulations, the compositional regulations for some products contain some special labelling requirements, which sometimes replace and sometimes add to the provisions in the general labelling regulations. Some aspects of labelling requirements are also governed by weights and measures legislation, and various consumer protection laws, so the manufacturer needs to be familiar with these. In addition to regulations, account needs to be taken of case law on the way in which regulations have been interpreted by courts, guidance from official sources and relevant industry codes of practice.

37.5 For a particular product, account has to be taken of all the different requirements affecting its labelling and packaging, not only in terms of the information included but also in terms of its spatial layout, presentation and design. In many cases, interpretations have to be made of how the relevant provisions apply in the particular combination of circumstances presented by the product. Additionally, changes are continually taking place in labelling legislation and there are usually transitional periods when the old and the new regulations operate side by side, requiring detailed knowledge of the changes and the precise timetable. It must be recognised that ensuring compliance is not a task that can be left to graphic designers, advertising agencies, marketing managers or product managers, but requires a considerable degree of up‐to‐the‐minute technico‐legal expertise. Such expertise is an essential part of food control and is within the role of the quality control manager with such assistance as she/he may require.

37.6 When a new label for a product is being designed, or an existing one is being revised, whether expert help is sought from inside or outside the company or both, that label must comply with the legal requirements of the country in which the product is to be sold. Final adoption of the label should not be made without the approval of the quality control manager.

37.7 In the UK and the other European Union (EU) Member States, most food labels are legally required to carry a durability indication giving ‘the date up to which the food can reasonably be expected to retain its specific properties if properly stored’ plus a statement of ‘any storage conditions which need to be observed if the food is to retain its specific properties until that date’. This necessitates the manufacturer establishing for each product a shelf life, that is, the duration from the date of manufacture that determines the date to be given on the pack.

37.8 Determining the durability indication on labels for a particular product involves considerations of microbiological safety, of retention of acceptable organoleptic properties as assessed by sensory analysis, of chemical, physical and microbiological characteristics, and, in the case of nutrition information including vitamin declaration(s), compliance with the amounts declared. It is not enough to guess at the shelf life or to use what is thought to be (or worse, longer than is thought to be) the shelf life used by another manufacturer for an apparently similar product.

37.9 Proper scientifically based testing should be carried out to establish the shelf life to be used for a product in a specific packed format. For details of the circumstances relating to the use of ‘best before’ and ‘best before end’ dates, and the circumstances that trigger the requirement for a ‘use by’ declaration, see Directive 2000/13/EC as amended, and in the UK the Food Labelling Regulations 1996, SI 1996/1499. These regulations were revoked by the Food Information Regulation 2014, SI 2014 No. 1855 that implements EU Regulation No. 1169/2011 on the provision of food information to consumers and Commission Delegated Regulation (EU) No. 78/2014 amending Annex II of EU food information to consumers listing the 14 allergens. The Food Information Regulation 2014 brings together general labelling, nutrition and allergen labelling in a single framework legislation (see the Food Law Guide, which can be accessed on the Food Standards Agency website). Some of the major requirements in the legislation that affect food manufacturers are as follows:

  • For prepacked foods, allergens must be emphasised in the ingredients list.
  • A minimum font size must be applied to mandatory information.
  • Country of origin (COO) information is required for fresh and chilled meat from swine, sheep, goats and poultry, implementing EU Regulation No. 1337/2013, which lays down rules for this requirement.
  • Added water over 5% must be declared in the name of the food for meat products and meat preparations that have the appearance of a cut, joint, slice, portion or carcase of meat. This also applies to fish products that have the appearance of a cut, joint, slice, portion, fillet or whole fishery product.
  • If a manufacturer produces food for sale at a stage prior to the final consumer, i.e. through a wholesaler or to a caterer or other third party, it is the responsibility of the manufacturer to ensure that information on all the mandatory particulars is provided. Not all the information will be required on a label and some information may be provided on commercial documents either accompanying the food or sent prior to delivery.1 The mandatory particulars outlined in Article 9 of the EU Regulation No. 1169/2011 are as follows:
    1. the name of the food;
    2. the list of ingredients;
    3. any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and 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 in the appropriate unites (e.g. kg/g/mg or l/cl/ml);
    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;
    9. the country of origin or place of provenance where required;
    10. instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions (if food needs to be cooked the label must be clear in this regard, particularly if the food requires the use of a specific technique, e.g. oven or microwave);
    11. with respect to beverages containing more than 1.2 % by volume of alcohol, the actual alcoholic strength by volume;
    12. a nutrition declaration.

37.10 The Quantitative Ingredient Declarations (QUID) labelling requirement applies to the labelling and marking of prepacked food that is sold direct to the consumer/customer in its current packaging. The QUID requirement designates the circumstances in which the percentage(s) of one or more ingredients in a product must be declared in the ingredients list. Regulation EU No. 1169/2011 on the provision of information to consumers was published in October 2011.1 The list of ingredients must be headed or preceded by a suitable heading that consists of or includes the word ‘ingredients’. In general, all ingredients must be listed in descending order of weight as recorded at the time of their use in the manufacture of the food.2

Any engineered nanomaterial used as an ingredient in a food should be clearly indicated and must have ‘nano’ in brackets after its name in the ingredient list.

Additives must be stated in the ingredients list by their functional class, such as antioxidant or preservative, along with either their name as referred to in the additive legislation (see EC Regulation No. 1333/2008) or the E number.1

Allergenic ingredients should be emphasised in the ingredients lists by using a font, style or colour that ensures they are clearly distinguished from the other ingredients present.1

37.11 See Chapter 49 regarding labelling of irradiated foods, Chapter 50 regarding labelling of novel foods and genetically modified foods, and Chapter 8 regarding labelling requirements in respect of the presence of legally specified food allergens.