- Mandatory Information
- Repeating Nutrition Information on the Front of Pack
- Presentation of Nutrition Information
- Calculation of Nutrient Values
- Exemption from nutrition labelling for manufacturers of 'small quantities'
- Further Information
Having a nutrition declaration on prepacked foods is mandatory. However, there are certain foods exempted from the requirement to display nutrition information.
When providing nutrition information the declaration must give:
(a) The energy value and
(b) The amounts of fat, saturates, carbohydrate, sugars, protein and salt
You can also choose to give the amount of one or more of the following:
(f) Any of the vitamins or minerals listed in point 1 of Part A of Annex XIII to FIC, and present in significant amounts as defined in point 2 of Part A of Annex XIII to FIC
The amount of any nutrient not listed above cannot be added to the nutrition declaration, as it is a ‘closed list’. Where another nutrient, not on this list, must be declared on the label as a result of a requirement of the nutrition or health claims legislation (Regulation (EU) No. 1924/2006), the amount of the nutrient or other substance must be labelled in the same field of vision i.e. in close proximity, to the nutrition declaration.
Where the mandatory nutrition information is declared on the label, certain nutrients may be repeated in the ‘principal field of vision’, i.e. the front of pack. This repeated information is a voluntary measure but where a food business chooses to provide this additional declaration, only the following information can be provided:
- Energy only or
- Energy along with fat, saturates, sugar and salt
This repeated information may be provided:
- Per 100g/ml only
- Per 100g/ml and per portion or
- On a per portion basis only
When providing this ‘Front of Pack’ information Energy must always be indicated per 100g/ml as a minimum.
Nutrition information must be presented in tabular format with the numbers aligned. Where space does not permit, the declaration may appear in linear format. The energy value must be expressed in Kilo Joules (kJ) and Kilo Calories (kcal) and the amount of the nutrients must be expressed in grams (g).
All elements of the nutrition declaration must be included in the same field of vision. They must be presented together in a clear format and, where appropriate, in the order of presentation provided for in Annex XV to FIC.
The nutrition declaration must be expressed per 100 g/ml, using the measurement units specified in Annex XV to FIC. When provided, the declaration on vitamins and minerals must in addition to this form of expression, be expressed as a percentage of the reference intakes set out in point 1 of Part A of Annex XIII to FIC in relation to per 100 g or per 100 ml.
The legislation allows for various methods of calculating the nutrient values. It does not necessarily require laboratory analysis and it may be possible for a food business operator to calculate the values themselves depending on the type of product. The declared values in the nutrition table are average values* and must be based on:
- the manufacturer's analysis of the food
- a calculation from the known or actual average values of the ingredients used; or
- a calculation from generally established and accepted data
*The nutrient values are average values to take into account the natural variation in foodstuffs due to, for example, seasonality or supplier differences. However, there is EU guidance on the permitted tolerances for nutrient values which should be consulted.
The nutrient values must be for the food as sold. However, where appropriate the information may relate to the food after preparation, provided that sufficiently detailed preparation instructions are given and the information relates to the food as prepared for consumption.
Conversion factors for the calculation of the energy value are given in Annex XIV to FIC
The legislation on the provision of food information to consumers allows for an exemption from the mandatory requirement for nutrition labelling for food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer.
In Ireland, S.I. No. 559 of 2016 defines what is meant by ‘small quantities’ and also defines ‘local’. Food manufacturers who meet the criteria will be exempt from the mandatory obligation to provide nutrition information on their prepacked food (Note: 'food' includes beverages - however, alcoholic beverages are not currently obliged to provide nutrition information).
In summary, this Irish legislation:
- amends the European Union (Provision of Food Information to Consumers) Regulations 2014 (S.I. No. 556 of 2014)
- applies to ‘prepacked’ food. This legislation does not apply to food that is sold loose or packed in the premises from which it is sold
- applies only to manufacturers who either supply their products directly to the final consumer or to local retail establishments that in turn supply directly to the final consumer
- defines ‘local retail establishment’ as a retail establishment that is not more than 100km from the place of manufacture
- defines ‘small quantities’
- provides an option for food manufacturers to base the calculation of the quantity supplied on either weight (kilograms or litres) or number of units.
- applies to the total quantity of food produced by a food manufacturer.
- requires food manufacturers to prove that they meet the terms of the exemption.
Please have a look at our FAQ on the exemption for manufacturers of small quantities of products to help determine if it applies to you