This material is for informational purposes only. It is not intended as legal advice. We encourage you to review the EU and UK legislation and consult your legal counsel if you have questions about the laws and regulations concerning your product. This material only reflects the position at the date of writing and requirements in the EU and/or UK may change – particularly in light of the developing position with Brexit. You should refer to current UK Brexit guidance about your products (where available) to learn more about the changes that may affect you following the end of the transition period.
All food items sold on Amazon websites in Europe must comply with The European Food Information for Consumers Regulation. (Refer to 1169/2011/EC “EU FIC”). This legislation sets out the mandatory labelling requirements for food.
For distance selling (e.g. selling goods online), mandatory information needs to be provided both at the point of sale (product detail page) and at point of delivery (when goods are received by the customer). With regard to the information provided at point of sale, this can be through clear images of the product itself and/or through text on the product detail page (images and product detail page information must not contradict each other).
Please see below overview of the key EU requirements for the labelling of pre-packed food.
Food products that are first made available in the UK on or before December 31, 2020 must comply with the EU FIC.
Products that are first made available in the EU or UK on or before December 31, 2020 can continue to circulate until they reach their end user and do not need to comply with the changes that take effect from January 1, 2021. You can retain evidence of when products were first made available in the UK or EU by keeping documents including contracts of sale, invoices and documents concerning the shipping of goods for distribution.
Food products that are first made available in Great Britain (England, Scotland and Wales) after December 31, 2020 must comply with an amended version of the EU FIC as a result of the Food (Amendment) (EU Exit) Regulations 2019/529. Different rules apply to goods you sell in: (1) Great Britain (England, Scotland and Wales); and (2) Northern Ireland.
For distance selling (e.g. selling goods online), mandatory information needs to be provided both at the point of sale (product detail page) and at point of delivery (when goods are received by the customer). With regards to the information provided at point of sale, this can be through clear images of the product itself and/or through text on the product detail page (images and product detail page information must not contradict each other).
Please see below overview of the key UK requirements for the labelling of pre-packed food.
Food (or foodstuff) means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans.
Examples of food include:
Note that there are additional requirements in relation to certain other foods, including:
This guidance is applicable to pre-packed foods. Pre-packed products are foods that have been put into packaging before putting on sale and cannot be altered without opening or changing the packaging. For example, frozen food, tinned fruit and cupboard staples such as cereals and biscuits.
Depending on the nature of the product, mandatory information needs to be provided on the product label. Please see below for more detailed information on the applicable requirements.
The following product information must be displayed on the detail pages of pre-packed products in the language applicable to the country in which the product is sold. Information must be conspicuous, legible and adhere to font size requirements.
Product type | Location of information | Mandatory | Required if applicable | Recommended to optimise customer experience |
---|---|---|---|---|
Pre-packed item | Physical label (either on the packaging or an attached label) |
|
|
|
Pre-packed item | Product Detail Page |
|
As mentioned above | As mentioned above |
Ingredients identified as allergenic should be highlighted in the list of ingredients.
The below ingredients are allergens. If a food contains any of these allergens, highlight the allergen in the ingredients list by means of a distinguishing typeset (bold, separately coloured etc.):
Claims on food products must not be false, ambiguous or misleading and should comply with the relevant requirements (Refer to detailed information below).
In general, claims for foods must not be false, ambiguous or misleading about:
Claims stating that food or its ingredient can help treat, prevent, or cure a disease or adverse condition is prohibited. See the health claims section below for more information.
In addition, you can use only nutrition and health claims approved under EU Regulation (EC) No 1924/2006 on nutrition, and health claims made on food (the ‘Regulation’) on the label and detail page.
A nutrition claim is any claim that states, suggests or implies that a food has particular beneficial nutritional properties due to the presence, absence, increased or reduced levels of energy or of a particular nutrient or other substance. Nutrition claims provide information about the nutritional composition of the food. For example: 'source of calcium', 'low fat', and 'high fibre' and 'reduced salt'.
Only nutrition claims listed in the Annex to the Regulation can be made in relation to food and only if the product meets the specific conditions of use for that claim. For example, 'low fat' can only be made on products containing no more than 3g of fat per 100g for solids.
A health claim is any claim that states, suggests or implies that a relationship exists between a food category, a food or one of its ingredients and health. Only health claims authorised by the European Food Safety Authority (EFSA) and the Commission are permitted. The EU Register contains a list of specific health claims and the outcome of their assessment (whether authorised or not) as well as their conditions of use. An example of a specific health claim would be 'calcium helps maintain normal bones'. Generic and non-specific claims, such as 'good for you' or 'healthy' might be allowed if they are accompanied by a relevant specific authorised health claim listed in the EU Register, provided they meet the specific conditions of use.
Health claims cannot:
Nutrition and health claims are only permitted if the average consumer can be expected to understand the beneficial effects as expressed in the claim. As mentioned above, if general wellbeing claims are used (such as 'superfoods', good for you), then these must be accompanied by a specific health claim, i.e., you need to explain why it is considered a 'superfood'. For example, Mackerel, as part of a healthy balanced diet, can be considered a superfood because it is a source of Omega-3 fatty acids. The claim could therefore state: 'Omega 3 fatty acids EPA and DHA contribute to normal heart function' however, should be accompanied by explaining where the Omega 3 comes from 'contains x mg of eicosapentaenoic acid and docosahexaenoic acid per 100 g'. To use this health claim, you also need to tell the customer that the beneficial effect is obtained with a daily intake of 250mg EPA and DHA.
This table explains the concepts mentioned in this guide.
Concept | Explanation |
---|---|
'Name' of food | Certain foods have legal names that must be used if the product meets certain standards (e.g. jam). In other instances, a customary name (e.g. Bakewell tart) can be used, provided customers generally accept the terminology. Failing this, a descriptive name (e.g. pasta in tomato sauce) must be used. |
QUID | The QUID tells a consumer the percentage of particular ingredients contained in
a food product. You must show a QUID if:
|
Business information | Name and business address of the manufacturer. If the manufacturer is based outside of the EU, then details of the company importing the food into the EU must be provided. |
Durability indication | A 'best before' or 'use by' date is not required however, you must include a
lot number on:
|
Nutrition information | Nutrition information is required for most pre-packed foods (unless exempt) and
must be provided per 100g or per 100ml. For example:
|
Storage statement | Storage statements are required if the durability date is listed as 'use by'. |
Recycling | Clearly state if the packaging is recyclable. |
Country of origin |
|
Product claims and warnings | Where consumers should be warned of a particular risk, other than allergens
(which is mandatory). For example, 'contains a source of Phenylalanine' for all
products containing the sweetener Aspartame. Nutrition and health claims are subject to specific requirements (refer to section on Nutrition and health claims mentioned above). |
For more information, refer to:
The UK Regulations apply to all products sold in the UK, but the provisions apply differently to Great Britain (England, Scotland and Wales, “GB”) and Northern Ireland. You can read more about the position in Northern Ireland (“NI”) below.
Food (or foodstuff) means any substance or product, whether processed, partially processed or unprocessed, intended to be or reasonably expected to be ingested by humans.
Examples of food include:
Note that there are additional requirements in relation to certain other foods, including:
This guidance is applicable to prepacked foods. Prepacked products are foods that have been put into packaging before putting on sale and cannot be altered without opening or changing the packaging. For example, frozen food, tinned fruit and cupboard staples such as cereals and biscuits.
Depending on the nature of the product, mandatory information needs to be provided on the product label. See below for more detailed information on the applicable requirements.
The following product information must be displayed on the detail pages of prepacked products in the language applicable to the country in which the product is sold. Information must be conspicuous, legible and adhere to font size requirements.
Product type | Location of information | Mandatory | Required if applicable | Recommended to optimise customer experience |
---|---|---|---|---|
Prepacked item | Physical label (either on the packaging or an attached label) |
|
|
|
Prepacked item | Product Detail Page |
|
As mentioned above | As mentioned above |
The below ingredients are allergens. If a food contains any of these allergens, they have to be highlighted by means of a distinguishing typeset (for example, all in capital letters, etc.).
Please see below a list of all substances or products causing allergies or intolerances as stated in Annex II of 1169/2011/EC (as retained and amended by UK law):
Claims on food products must not be false, ambiguous or misleading and should comply with the relevant requirements.
In general, claims for foods must not be false, ambiguous or misleading about:
Claims stating that food or its ingredient can help treat, prevent or cure a disease or adverse condition is prohibited. See the health claims section below for more information.
In addition, only nutrition and health claims that have been approved under EU Regulation (EC) No 1924/2006 (as retained and amended by UK legislation via the Nutrition (Amendment etc.) (EU Exit) Regulations 2019/651) on nutrition and health claims made on food can be used on the label and detail page.
A nutrition claim is any claim that states, suggests or implies that a food has particular beneficial nutritional properties due to the presence, absence, increased or reduced levels of energy or of a particular nutrient or other substance. Nutrition claims provide information about the nutritional composition of the food. For example: 'source of calcium', 'low fat', 'high fibre' and 'reduced salt'.
Only nutrition claims listed in the Annex to the Regulation can be made in relation to food and only if the product meets the specific conditions of use for that claim. For example, 'low fat' can only be made on products containing no more than 3 g of fat per 100 g for solids.
A health claim is any claim that states, suggests or implies that a relationship exists between a food category, a food or one of its ingredients and health. Only health claims authorised by the relevant authority as listed below are permitted:
Until the end of the Brexit transition period (currently December 31, 2020) the EU Register contains a list of specific health claims and the outcome of their assessment (whether authorised or not) as well as their conditions of use.
After the end of the Brexit transition period (currently December 31, 2020) a register will be maintained by the UK authorities containing a list of specific health claims and the outcome of their assessment (whether authorised or not) as well as their conditions of use.
Health claims cannot:
Nutrition and health claims are only permitted if the average consumer can be expected to understand the beneficial effects as expressed in the claim. As mentioned above, if general wellbeing claims are used (such as 'superfoods', good for you), then these must be accompanied by a specific health claim, which explains why it is considered a 'superfood'. For example, Mackerel, as part of a healthy balanced diet, can be considered a superfood because it is a source of Omega-3 fatty acids. The claim could therefore state: 'Omega 3 fatty acids EPA and DHA contribute to normal heart function'. This should be accompanied with the explanation for where Omega 3 comes from and that it contains x mg of eicosapentaenoic acid and docosahexaenoic acid per 100 g. To use this health claim, you also need to tell the customer that the beneficial effect is obtained with a daily intake of 250 mg EPA and DHA.
This table explains the concepts mentioned in this guide
Concept | Explanation |
---|---|
Name of food | Certain foods have legal names that must be used if the product meets certain standards (e.g. jam). In other instances, a customary name (e.g. Bakewell tart) can be used, provided customers generally accept the terminology. Failing this, a descriptive name (e.g. pasta in tomato sauce) must be used. |
QUID |
The QUID tells a consumer the percentage of ingredients contained in a food product. You must show a QUID if:
|
Business information | Name and business address of the manufacturer. If the manufacturer is based outside of the UK, then details of the company importing the food into the UK must be provided. |
Durability indication |
A 'best before' or 'use-by' date is not required, however, you must include a Lot number on:
|
Nutrition information |
Nutrition information is required for most prepacked foods (unless exempt) and must be provided per 100 g or per 100 mL. For example:
|
Storage statement | Storage statements are required if the durability date is listed as 'use by'. |
Recycling | Clearly state if the packaging is recyclable. |
Country of origin |
|
Product claims and warnings |
Where consumers should be warned of a particular risk, other than allergens (which is mandatory). For example, 'contains a source of Phenylalanine' for all products containing the sweetener Aspartame. Nutrition and health claims are subject to specific requirements. (Refer to section on Nutrition and health claims mentioned above.) |
Please note that different rules will apply in Northern Ireland (NI) from January 1, 2021 as a result of the Northern Ireland Protocol. In particular:
The relevant authority for authorising health claims in Northern Ireland is the Department of Health.
The UK Government has released guidance on selling products in GB and NI after Brexit. We encourage you to visit the following UK government website for guidance on changes that may affect you from January 1, 2021:
For more information, refer to:
We encourage you to visit the Business Companion website, which contains guidance on UK product compliance rules:
For more information, refer to: