Q&A with a Normec Foodcare Labelling Specialist
17 april 2025
Q&A with a Normec Foodcare Labelling Specialist
All prepackaged food products must be labelled with honest and clear information so that consumers know what they are buying and consuming. This can be done by means of a label or printed packaging. There are many detailed rules for the labelling of food products. A large part of the rules are contained in Regulation (EU) No 1169/2011 on the provision of food information to consumers. This European Regulation applies to all food sold in Europe. In addition, additional requirements are included in other European legislation and specific laws and regulations in force in the various European countries.
Labelling Specialist Isabel Widdershoven
At Normec Foodcare, we have a department with Labelling Specialists who are engaged in label checks, completing or checking specifications and resolving labelling and packaging issues on a daily basis to ensure that our customers comply with the various regulations. In doing so, we also take into account the interests of consumers, namely that a product can be consumed safely and that confidence in the product is not lost.
Our specialists receive a wide range of labelling questions. In this article, we share a number of practical questions and Labelling Specialist Isabel Widdershoven provides you with advice.
Do I have to indicate the origin on the label of English liquorice?
The indication of the country of origin or place of provenance may be mandatory if its omission could mislead the consumer as to the actual country of origin or place of provenance of a food product. Furthermore, specific legal requirements regarding origin labelling apply to a number of food categories, such as fresh meat, honey, fruit and vegetables, olive oil, and fishery and aquaculture products.
Regulation (EU) No 1169/2011 distinguishes between voluntary and mandatory origin labelling. Voluntary origin labelling refers to a situation where the country of origin or place of provenance of the food is indicated on a voluntary basis, for example in the product name. In this case, you must comply with the rules in Article 26(2) and (3) of Regulation (EU) 1169/2011, which are further elaborated in Implementing Regulation (EU) 2018/775.
However, origin labelling does not always apply when a country or place is mentioned. This is the case when geographical terms are part of generic and customary names that are not generally considered to be an indication of the origin or place of origin of the food. These products are exempt from voluntary origin labelling.
This concerns foodstuffs/recipes for which generic/customary names have developed over time. Examples include Gelderse worst (a type of sausage), Chinese cabbage and spaghetti Bolognese. We can also add English liquorice to this list. This immediately answers our question: you do not have to indicate the origin on the label of English liquorice, because it is considered a generic/customary name.
It is important to note that generic/common names are always considered in the country where the product is marketed. Generic/common names may differ from one Member State to another. Our advice is to assess each case individually to determine whether it is clear to consumers that a generic/common name is used in order to determine whether origin labelling is required.
Which ingredients do I need to KWID on a label for a product called “Roomboterappeltaart met noten” (butter apple pie with nuts)?
Quantitative ingredient declaration (KWID) is used to state the quantity of an ingredient or category of ingredients as a percentage. KWID is mandatory when a particular ingredient or category of ingredients is emphasised in some way on the label. This emphasis can take various forms, including text, images or symbols. KWID is also mandatory if an ingredient or category of ingredients appears in the name of the food or is commonly associated with that name by consumers. KWID is also mandatory when it is important to characterise a food and distinguish it from products with which it could be confused due to its name or appearance. The relevant regulations can be found in Article 22 of Regulation (EU) 1169/2011.
A number of ingredients must be KWID on the label of “Roomboterappeltaart met noten” (butter apple pie with nuts). The name includes butter, apple and nuts. These ingredients must therefore be KWID because they appear in the name.
KWID can be done in two ways: in the name or in the list of ingredients. A combination of both is also possible: part in the name and part in the ingredient declaration. The percentage may be stated before or after the ingredient concerned. In the case of this ‘Butter apple pie with nuts’, you cannot KWID all the components in the name, because not all components are listed separately here. The nuts are listed separately, so you can KWID them in the name, and butter and apple can be KWIDed in the list of ingredients.
Can I display an image of an orange on the packaging of a drink with natural orange flavouring?
An image of one or more ingredients on a label can be used to emphasise their presence. An image on a label is a form of voluntary information. The following applies: voluntary food information must not be misleading, ambiguous or confusing for consumers (Article 36(2) of Regulation (EU) No 1169/2011). Whether an ingredient may be depicted depends on its presence, quantity and the overall composition of the product in which it is present. The use of images must always be assessed on a case-by-case basis, taking into account the entire label or the overall presentation of the product.
In the case of the drink with natural orange flavouring, it is important to determine whether, in addition to the natural orange flavouring, orange is also present. This refers to orange as a fruit, flavouring ingredient, concentrate, extract or juice as an ingredient.
If this is not the case, the image of an orange is not automatically permitted. The reason for this is that there is no orange present, but rather orange flavour, which comes from the natural orange flavouring. For this reason, the orange may not be depicted without the indication “flavour” or “aroma”. “Flavour” or “aroma” must always be clearly legible near the image. Depending on the position of the image on the label, the statement must appear on the main field of vision and other sides. The name must also clearly state “flavour” or “aroma”.
Can I state the net quantity on the front of a product and the other mandatory information on the back?
Every label must state the net quantity or another quantity indication. There are rules governing the font size and unit of volume. You are not required to state the net quantity in a fixed place. The net quantity may therefore also be stated on the front of a label.
However, another requirement means that this is often not possible in practice. It is a legal requirement that the net quantity is stated in the same field of vision as the name and, where applicable, the alcohol percentage.
It is important to know the difference between the name and the commercial name. By the name of the product, we mean the legal name or trade name, not the commercial name. In practice, we often see the commercial name on the front and the name on the back (or other side). The commercial name and name often differ, which means that the net quantity must be stated on the back (or other side) next to the name and that stating it on the front is not sufficient in law.
If the commercial name is the same as the name and the net quantity is in the same field of vision as the commercial name, then it is acceptable. Repeating the net quantity on another side is also permitted, provided that the net quantity is also stated in the same field of vision as the name.
The answer to this question is therefore that the net quantity cannot be stated on the front if all other mandatory information, including the name, is stated on the back. The name and net quantity must be in the same field of vision.
What nutritional values must I state on the label if I include the claim “source of fibre”?
All prepackaged foods must have a nutrition table with at least the following nutritional information: energy, fats, saturated fatty acids, carbohydrates, sugars, proteins and salt. In addition, the values for monounsaturated fatty acids, polyunsaturated fatty acids, polyols, starch and fibre may be stated. Vitamins and minerals may also be stated, provided they are present in significant quantities.
On the other hand, it is not permitted to list other nutrients in the table, such as trans fatty acids or omega-3 fatty acids. The order of the table is laid down by law and the nutrition declaration must, in principle, be presented in table form, unless there is insufficient space, in which case the information may be presented in a list.
This question indicates that the claim “source of fibre” appears on the label, which means that fibre is no longer voluntary but must be included in the nutrition table. The nutrition declaration is mandatory for nutrients for which nutrition and/or health claims are made or for nutrients that have been added. The values for energy, fats, saturated fatty acids, carbohydrates, sugars, fibre, protein and salt must be stated on this product.
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