EU food labelling: the basics
Food labelling legislation in the EU is set under a set of rules, including the Food Information for Consumers Regulation (FIC) (Regulation (EU) No 1169/2011). This outlines that labels must be accurate, clear, easy to understand, and not misleading, and should not be ambiguous or confusing. Legislation is also set under the 2002 General Food Law Regulation.
Food labelling in the EU is also regulated through a set of vertical rules that set requirements for specific food products (wine, eggs, honey).
Where are we now?
Under the Farm to Fork strategy, the Commission announced its intention to revise legislation to ensure better labelling, help consumers to make healthier, more sustainable choices, and tackle food waste. A range of proposals were expected during the previous mandate (2019-2024), but progress was slower than anticipated, leaving many areas unresolved.
A recent European Court of Auditors special report on Food labelling in the EU (November 2024), found that food labelling in the EU can help consumers make better informed decisions when purchasing food. However, there are gaps in the legal framework and several recommendations were made which may inform future EU labelling policy. In addition, the Strategic Dialogue on the future of EU agriculture agreed that the Commission should conduct a review of EU labelling legislation and update this where necessary.
A new College of Commissioners has been in place since 1 December 2024, and they will now decide what the priorities will be for the 2024-2029 mandate. Agriculture and Food Commissioner, Christophe Hansen (LX, EPP) will publish a ‘Vision for Agriculture and Food’, most likely in February, and this may include plans to amend food labelling legislation.
What could we expect?
Whilst we do not, and will not, know what the priorities of the Commission are until the Vision for Agriculture and Food is published, there are a few labelling policies which might re-surface.
Front of pack nutrition labelling (FOPNL)
Under current EU rules, indication of nutritional information on labels is not mandatory but can be included on a voluntary basis. There are several labelling schemes in use throughout the EU, including the French ‘Nutri-score’ system which grades foods from A to E. The Commission was expected to propose legislation to introduce a harmonised, mandatory FOPNL by 2022. However, no proposal was put forward. The Commission’s preferred choice was Nutri-score, but the system received harsh criticism led by Mediterranean countries who deemed the system as simplistic, inaccurate, and discriminatory to their products.
Origin labelling
Under current EU legislation, country of origin labelling is mandatory where its absence could mislead consumers, and is required for certain products including fresh, chilled, or frozen meat from pigs, sheep, goat and poultry. The Commission would like to extend mandatory indication of origin to additional products (e.g. milk, rice and potatoes). A proposal was expected in 2023, but no legislative proposal was published. Seven EU member states (Greece, Spain, France, Italy, Lithuania, Portugal and Finland) have adopted national mandatory labelling schemes for certain food products, causing unequal consumer access to food-related information across the EU, according to the ECA report.
Origin labelling is seen by some as a win for the EU agri-food sector and is being pushed by several farming unions, and a legislative proposal may be expected over the next years. There are concerns that more specific origin labelling could disadvantage products which are traditionally mixed in the supply chain, such as milk and spirit drinks. This issue is particularly relevant for trade in agri-food products in Ireland and Northern Ireland.
Animal welfare labelling
With the exception of eggs and poultry, animal welfare labels are voluntary and there is no harmonised EU system. A legislative proposal is expected over the next years and was agreed to in the Strategic Dialogue on the Future of EU Agriculture. This will likely be harmonised, voluntary and multi-tier label for all EU meat and dairy products.
Sustainability labelling
A broad, sustainability label was being considered by the Commission under the Framework for Sustainable Food Systems (FSFS) – designed to accelerate the transition to a more sustainable food system and part of the Farm to Fork Strategy. This may have displayed a product’s climatic, environmental and social impact (including fair distribution and working conditions), alongside nutritional and animal welfare impact. However, the FSFS was shelved, and it is not certain if it will re-surface.
Date marking
Under the FIC Regulation, there are two types of mandatory date marking:
- “use by” (date by which the product is no longer safe – used for highly perishable foods)
- “best before” (date until which the food retains its optimal quality when properly stored).
A 2018 Commission study found that date markings are not well understood by consumers and the Commission proposed legislation to amend existing rules on date marking (Regulation (EU) No 1169/2011) to amend the wording of ‘use by’ and ‘best before’ dates as follows:
- ‘Best before …’ when the date includes an indication of the day,
- ‘Best before end …’ in other cases, And followed by the words ‘often good after’
However, this proposal was withdrawn. The ECA report outlines that consumers often do not understand date labelling.