EU 1169/2011: Food Labelling Regulation Guide
EU 1169/2011 explained for food makers, including nutrition declarations, allergens, mandatory particulars, label sizes and key FDA differences.
EU 1169/2011 is the main food labelling regulation setting out what information must appear on food labels across all 27 EU member states plus the EEA countries Norway, Iceland and Liechtenstein. Regulation (EU) No 1169/2011, known as the Food Information to Consumers (FIC) Regulation, has applied since December 13, 2014, with the mandatory nutrition declaration in force since December 13, 2016.
If you are used to FDA labels, the main differences are immediate: energy appears in both kJ and kcal, nutrition values are declared per 100 g or 100 ml rather than per serving, salt replaces sodium, and 14 allergens are emphasized within the ingredient list rather than declared in a separate Contains statement.
EU 1169/2011 mandatory particulars under Article 9
Every prepacked food sold in the EU must carry the mandatory information required by Article 9. This includes:
- The name of the food
- The ingredient list, with allergen emphasis
- Quantity of certain ingredients (QUID) when emphasized on pack
- Net quantity
- Date of minimum durability ("best before") or "use by" date
- Special storage or use conditions
- Name and address of the responsible food business operator in the EU
- Country of origin where required, such as for certain meats or where omission would mislead
- Instructions for use where needed
- Alcoholic strength above 1.2%
- The nutrition declaration
These requirements go beyond the nutrition table itself. When preparing an EU label, you need to consider the complete package rather than simply converting an FDA Nutrition Facts panel into a different format.
The EU food labelling regulation nutrition declaration
Articles 30 to 35 establish the nutrition declaration. The mandatory declaration uses a fixed list in a fixed order: energy (kJ and kcal), fat, of which saturates, carbohydrate, of which sugars, protein, and salt.
The values are declared per 100 g or per 100 ml.
Fibre, mono- and polyunsaturates, polyols, starch, and vitamins and minerals at significant amounts may be added voluntarily. Nothing else may appear in the table.
If you normally prepare FDA labels, three differences are particularly important:
- Salt, not sodium. The EU declares salt, calculated as sodium × 2.5. If your US specification sheet provides sodium, you must convert it before preparing the EU declaration.
- Per 100 g/ml is mandatory. Per-portion values can be added voluntarily, but they do not replace the mandatory per-100 g or per-100 ml declaration. There is no US-style serving-size derivation. See per-100g vs per-serving.
- No added sugars line and no %DV column. Percentages of Reference Intakes (RI: 8400 kJ/2000 kcal for energy, Annex XIII) are voluntary. Fibre is optional, and trans fat is not declared at all.
These differences mean that the same underlying recipe data can produce substantially different FDA and EU nutrition panels.
Regulation 1169/2011 allergen requirements: 14 allergens
Annex II identifies 14 substances: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphur dioxide/sulphites above 10 mg/kg or mg/l, lupin, and molluscs.
These allergens must be emphasized within the ingredient list, typically using bold type or another typeset that clearly distinguishes them from the other ingredients.
Unlike the US system, a separate "Contains" statement is not permitted when an ingredient list is present. This makes allergen formatting part of the ingredient list itself rather than a separate declaration beneath it.
For a detailed comparison with the US nine-allergen system, see our allergen labeling guide.
EU 1169/2011 legibility and small package rules
Article 13 establishes minimum type-size requirements for mandatory food information. The minimum is an x-height of 1.2 mm.
Where the package's largest surface is under 80 cm², the minimum x-height is 0.9 mm.
Package size can also affect which information must appear. Packages whose largest surface is under 25 cm² are exempt from the mandatory nutrition declaration.
For very small packages where the largest surface is under 10 cm², only the name, allergens, net quantity, and date need to appear on the package. The ingredient list must be provided by other means.
These exemptions are based on package dimensions, so they should be checked before the label layout is finalized.
EU 1169/2011 vs FDA food labels at a glance
| Element | EU 1169/2011 | US 21 CFR 101.9 |
|---|---|---|
| Energy | kJ + kcal | Calories (kcal) only |
| Basis | Per 100 g / 100 ml | Per RACC-derived serving |
| Sodium | Salt (Na × 2.5) | Sodium (mg) |
| Sugars | Total sugars only | Total + added sugars with %DV |
| Fibre | Voluntary | Mandatory |
| Allergens | 14, emphasized in-list | 9, parenthetical or Contains |
| Percentages | %RI voluntary | %DV mandatory |
The two systems use different approaches even when they start from the same product data. An FDA label centers the Nutrition Facts declaration around the serving, while Regulation 1169/2011 requires the nutrition declaration on a standardized per-100 g or per-100 ml basis.
The EU also uses salt rather than sodium, requires both kJ and kcal for energy, and handles allergens within the ingredient list. These differences are why an existing US Nutrition Facts panel should not simply be reused for an EU product.
National add-ons to Regulation 1169/2011: Nutri-Score and other schemes
Regulation 1169/2011 harmonizes the back-of-pack nutrition declaration, but member states may recommend voluntary front-of-pack schemes.
Nutri-Score is the most widespread. It has been adopted in France, Belgium, Germany, the Netherlands, Spain, Luxembourg, and Switzerland.
Distance selling also has an important requirement. For foods sold online, all mandatory information except the date marking must be available before the customer completes the purchase.
This means your compliance work may extend beyond the physical package. The required food information also needs to be considered when products are offered through online sales channels.
NFL renders the EU tabular declaration, including kJ/kcal conversion, salt calculation, allergen bolding, and per-100 g calculations from your recipe, as one of the formats listed on the coverage page. Build the recipe once in recipe management, then switch the output country.
Frequently asked questions about EU 1169/2011
What is EU 1169/2011?
EU 1169/2011 is the Food Information to Consumers Regulation, the main rulebook for food labelling across all 27 EU member states plus the EEA countries Norway, Iceland and Liechtenstein. It has applied since December 13, 2014, while its mandatory nutrition declaration has applied since December 13, 2016. It covers nutrition information, ingredients, allergens and other mandatory food particulars.
Do EU labels need per-serving values?
No. Per 100 g or per 100 ml is the mandatory basis for the nutrition declaration under Regulation 1169/2011. You may add per-portion values voluntarily, but the portion size must be quantified on the label and the number of portions must be stated. The optional portion information does not replace the mandatory per-100 g or per-100 ml declaration.
Can I sell a US-labeled product in the EU unchanged?
No. A US Nutrition Facts panel does not satisfy Regulation 1169/2011. The energy units, declaration basis, salt conversion, allergen emphasis, language requirements, and EU operator address differ. You therefore need an EU-specific label rather than simply reusing the US panel, although the nutrition declaration can be calculated from the same underlying recipe data.
Does the EU declare sodium or salt on nutrition labels?
The EU declares salt, not sodium. Under the EU food labelling regulation, salt is calculated as sodium × 2.5 and appears in the mandatory nutrition declaration. If your existing specification or recipe data contains sodium because it was prepared for a US Nutrition Facts label, that value needs to be converted when preparing the EU declaration.
Is Nutri-Score mandatory anywhere?
No. Nutri-Score remains voluntary under EU law. Member states can recommend the scheme but cannot make it compulsory because a mandatory national scheme would conflict with the harmonized regulation. Many major retailers, however, require Nutri-Score commercially in countries that have adopted the system.
Need an EU-compliant declaration from your existing recipe? The free generator converts sodium to salt, kcal to kJ, and per-serving values to per-100 g automatically.
