Food labels: the mandatory details people tend to miss

On a food label, the trouble rarely comes from the product name or the ingredient list. It comes from the small details: the exact date wording, the lot number, what to do when the pack is tiny, what to say about allergen traces, and what happens when you put a flag on the jar. EU law has rules for all of them, and all of them need space in the design, planned from the start.

We covered the full list of mandatory information and the minimum text size in our article on what has to fit on a label. This one is about what gets missed most often.

The date: the wording is fixed, you don't pick it

Regulation (EU) No 1169/2011 spells out, in Annex X, the actual words to use. In the English version:

The date is written as day, month, year, in uncoded form. For "best before" you don't always need all three: for products that keep up to 3 months, day and month are enough; from 3 to 18 months, month and year; beyond 18 months, the year alone. A label sold in Romania uses the Romanian wording from the Romanian version.

The wording can be followed by the date itself or by a pointer to where it's printed, such as "see lid." That matters for design: the date is usually printed on the production line, so you leave a clear, light-colored area on the label or pack where the ink will show. With a use-by date, the wording is followed by the storage conditions, and the date has to appear on every individually packed portion.

The lot: a small line you can't skip

A separate directive, 2011/91/EU, requires every food to carry a lot indication, meaning the production batch. The producer or packer sets it, it's preceded by the letter "L" (unless it's clearly distinguishable from everything else), and it has to be easily visible, clearly legible and indelible.

There's a useful exemption: if the date on the product shows at least the day and month, uncoded, the lot doesn't need to appear separately. If the date shows only month and year, you need the lot. The lot is usually printed along with the date, in the same clear area.

Small packs: what stays mandatory

For packs whose largest surface is under 10 cm² (sachets, individually wrapped candies, small portions), only four items are mandatory on the pack: the name, allergens, net quantity and the date. The ingredient list is provided by other means or on the customer's request.

Reusable glass bottles that are permanently marked and carry no label also get lighter rules.

Allergens and "may contain traces of"

Annex II of the regulation lists 14 groups of allergens that must be emphasized in the ingredient list: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphites, lupin and molluscs.

"May contain traces of…" is a different thing. The regulation doesn't require it; it's voluntary information. And voluntary information, says Article 36, must not mislead, be ambiguous or be confusing. Printed on every product "just in case," it tells an allergic customer nothing.

Watch out for food sold without packaging, too: in a bakery display case or at a bulk counter, allergen information is still mandatory. That calls for a sign or a card next to the product, not a label.

The flag on the jar and the main ingredient

Regulation (EU) 2018/775 has applied since April 1, 2020. If the packaging shows where the food comes from, through words, a flag, a symbol or a place name, and the main ingredient comes from somewhere else, you have to say so. Think of a jam sold as a local product but made from imported fruit.

That statement goes in the same field of vision as the origin claim. When the origin is written in words, the text about the main ingredient needs an x-height of at least 75% of the origin claim's. In design terms, you can't put "Made in Romania" big on the front and the explanation small on the back.

Nutrition declarations for small producers

Annex V of the regulation exempts from the nutrition declaration foods, including handcrafted ones, supplied in small quantities by the manufacturer directly to the consumer or to local shops that sell directly to consumers. What "small quantities" and "local" mean in practice is something to confirm with the food authority or a food safety consultant before you drop the table from your label.

We handle the design and leave room for everything required, but the legal content is confirmed by the producer. For sticker labels and their formats, see our stickers and labels page.