New Labelling Requirements - April 1st 2020

Hannah Wild

March 10, 2020

What is Origin Labelling and what does this mean?

“Article 26(2)(a) of Regulation (EU) No 1169/2011 requires the indication of the country of origin or place of provenance of food where its omission could mislead the consumer as to the true country of origin or place of provenance of the final food. In practice this means it is required if the information accompanying the food or the label as a whole (words, images or the general layout) would otherwise imply that the food has a country of origin or place of provenance that is different from its actual country of origin or provenance.

Origin information, even if not required by the above provision, can be added voluntarily to food labels of to menus or other information accompanying food.

What is the new requirement?

On 28 May 2018 Implementing Regulation(EU) 2018/775 extended the above to ensure that information that is given about the origin of a food, whether on the basis of it being required or included voluntarily, does not mislead consumers about where the main ingredients come from, by implementing Article 26(3) of Regulation 1169/2011.

This entered into force on 1 June 2018 and applies from 1 April 2020.

This implementing Regulation clarifies how the origin of primary ingredients must be labelled when different from the given origin of the food. A primary ingredient is one that constitutes over 50% of the food or an ingredient that is normally associated with food of that description by the consumer.

This provision applies to origin and provenance information on food labels and on menu descriptions.

For more information on origin labelling and the new requirement for primary ingredient information contact our regulatory team on or call us on 01933 272 089.