Effective 13 December 2014, the food labelling requirements set out in Regulation (EC) no. 1169/2011 apply. 

Nutrition Declaration
One of the key changes of this new legislation is that the nutritional value of the 'Big 7' must be declared. This includes the energy value, fat content, saturated fats, carbohydrates, sugars, proteins and salt per 100 grams or per 100 ml. In addition, this may also be identified by portion and the percentage of the established reference intake may also be mentioned. The mandatory substances may be supplemented with the monounsaturated and polyunsaturated fatty acids, polyols, starch, fibre and significant quantities of vitamins and minerals (see table for illustration purposes).

Furthermore, the energy content may be repeated on the front of the packaging (per 100 g/ml and in addition by portion); alone or together with the nutrients fat, saturated fat, sugar and salt. If the energy content per portion is identified on the label, then the number of portions contained in the package must also be mentioned. The principle that applies to these nutrients is that they may be identified on the front in units per 100 g/ml òr per portion.

List of Ingredients
What is also new is that vegetable oils and fats must now be broken down by specific plant origin. This means that the specific specie(s) must be identified, but that the use of category names ('vegetable oils', 'vegetable fats', 'vegetable oils and fats') will remain voluntary. When a group name is used together with the addition 'in different proportions', it is not necessary to identify the specific vegetable oils and fats in sequence of declining weight. When a category name is used, the total amount of vegetable oil and/or fat counts as the ingredient on the list of ingredients.

Furthermore, the designation hydrogenated for hydrogenated vegetable or animal oils or fats will be replaced by 'fully hydrogenated' for fully hydrogenated oils and fats, or 'partially hydrogenated' for partially hydrogenated oils and fats.

MVO has prepared a position on the labelling of rapeseed/colza oil with the conclusion that Colza Oil and Rapeseed Oil are synonyms. MVO Position on the Labelling of Rapeseed/Colza Oil.

Article 21 of Regulation no. 1169/2011 stipulates that substances that cause allergic reactions or intolerances must be included in the list of ingredients. The identification of such substances must be emphasised by using a deviating typography, such as a deviating font (for example, printed in bold, different font colour). In addition to this legal obligation, a producer may decide to voluntarily identify the allergens present in the food product on the packaging; for example by including the header 'Allergy information: contains ...'. This additional identification is permitted, but may not replace the legal obligation.

FEDIOL has prepared a statement on the exception concerning the labelling of refined soy and peanut oil as allergens: ‘Code of Practice on the production and labelling of certain oils in connection with allergy’.

The FDE has prepared a manual on best practices for the food industry concerning the risk management of allergens. To view this manual visit the FDE's Website.

Country of Origin
Identification of the country of origin/place of origin remains mandatory, since the omission of this information could mislead the consumer concerning the actual country of origin or the actual place of origin. Furthermore, this remains mandatory for beef, honey, fresh vegetables and fruit, and olive oil. The way that the mandatory designation of origin is to be provided for when dealing with pig, sheep, goat and poultry meat was clarified at the end of 2013. Read MVO's position in origin labelling here

  • Country of Origin: (pursuant to Regulation (EEC) no. 2913/92, Article 24) is the country where the last substantial economic processing took place or where a new product was produced or where a key production action was performed. For oil the country of origin therefore would be the place where it was refined.

  • Place of Origin: is the place from which the product originates according to the designation (in accordance with Regulation 1169/2011). For example, if corn oil is imported from the United States, then the US is the 'place of origin'.

Additional Information about Regulation (EU) no. 1169/2011:

For more information about the European labelling requirements visit the European Commission's website at http://ec.europa.eu/food/food/labellingnutrition/foodlabelling/proposed_legislation_en.htm and the NVWA's website at http://www.nvwa.nl/onderwerpen/regels-voor-ondernemers-eten-en-drinken/dossier/etikettering-van-levensmiddelen.

FoodDrinkEurope and Eurocommerce have prepared a guidance to assist retailers and food producers in implementing the labelling requirements. Download the guidance here

The European Commission has prepared two Q&As about the Regulation: Part 1 and Part 2. This document assists companies in interpreting and applying this Regulation.

Infant Feeding
The Delegated Regulation (EU) no. 2016/127 among other things (in Article 7, paragraph 2, sub a) stipulates that the mandatory nutrition declaration for infant formula and follow-on formula pursuant to Regulation (EU) no. 1169/2011 may be supplemented by additional information such as the amount of protein, carbohydrates or fat components. Annex I and II contain the composition requirements for various substances, including proteins and lipids, in infant formula and follow-on formula, respectively.

Medical Feeding
Article 6 of the Delegated Regulation (EU) no. 2016/128 contains the special requirements concerning the supplementary (mandatory) nutrition declaration of components such as fats and proteins in food for medical purposes. 

Genetically Modified Organisms
Regulation (EC) No. 1829/2003 and Regulation (EC) No. 1830/2003 state that all products originating from genetically modified organisms must be labelled, irrespective of whether genetically modified material is still detected or is present. This applies to packaged and unpackaged products. 

  • Regulation (EC) No. 1829/2003: regulates the authorization and labelling of genetically modified food and foods produced from GMOs
  • Regulation (EC) No. 1830/2003, regulates the traceability of ‘genetically modified organisms (GMOs)’, and the traceability of ‘foods produced with GMOs’.

Which terms
One of the following terms must be stated on the food label:

  • When the food comprises more than one ingredient, the words ‘genetically modified’ should be included in the ingredient list between brackets immediately after the name of the relevant ingredient.
  • When the food is made with genetically modified organisms, the words ‘produced with genetically modified [name of the ingredient]’ should be included in the ingredient list between brackets immediately after the name of the relevant ingredient.
  • When the ingredient of a food is indicated by a name of a category, the words ‘contains genetically modified [name of the organism]’ or ‘contains [name of the ingredient] produced with genetically modified [name of the organism]’ should be included in the list of ingredients.
  • If there is no list of ingredients, the words ‘genetically modified’ or ‘produced using genetically modified [name of the organism]’ should be stated clearly on the label.

A product must be able to be followed in the production chain, it must be traceable. Traceability applies to:

  • Products or source material consisting or containing genetically modified organisms (GMOs)
  • food produced from GMOs, irrespective of the detectability of DNA or protein in the food

Regulation no. 1169/2011 also states that suppliers that do not supply directly to the end user must ensure that other food business operators receive sufficient information in order to be able to comply with their obligations in relation to the labelling legislation.

Threshold value
Non genetically modified products may be mixed with traces of genetically modified material. In principle, this can occur when growing crops, but also when transporting or producing products. This minimal mixing is not always preventable or technically avoidable. That is why an exception to the labelling and traceability obligation is possible, under the condition that the food business operator has done everything possible to prevent mixing, This applies when the operator can demonstrate that the product unintentionally or unavoidably contains genetically modified material and that this concerns levels less than 0.9% of the total. In such situations, a product does not need to be labelled as genetically modified.

Dutch regulations
When serving non pre-packaged dishes or food to consumers, establishments, including catering establishments, do not need to mention whether GMOs or products produced with GMOs have been used. This is a Dutch regulation. However, establishments, including catering establishments, must know via the information they receive from their suppliers (the previous link in the chain) whether they are using GMOs or products produced with GMOs. 

In some member states, national provisions or private schemes apply to food without GMO’s or which no ingredients produced from GMO’s exist. In the Netherlands, in accordance with the applicable criteria as stated in the Novel Foods (Commodities Act) Decree, only the statement ‘prepared without genetic engineering’ is permitted. Other statements, such as GMO-free are not permitted in the Netherlands.

Food Information (Commodities Act) Decree
In the Netherlands, specific components of the Regulation (such as penalisation and the use of, at a minimum, the Dutch language on the label) are included in the Food Information (Commodities Act) Decree. Download the Decree here.


Last modified: September 3, 2020 15:43