What shall be considered in food labelling?

The labelling of food is subject to the LMIV and has recently been redesigned. Below, you will find principles that have to be taken into consideration in the food market.


Pre-packaged foodstuffs must be labelled with different mandatory labelling elements in accordance with the European and national legislation. In the case of foodstuffs in pre-packages, the following shall be specified:


• the sales denomination

• the manufacturer

• the list of ingredients

• the minimum shelf life (or consumption date)

• the lot number

• the filling capacity.


In addition, certain ingredients must be labelled for the preventative health protection, as some sort of ingredients may trigger allergies and intolerances if disposed in certain conditions. In order to achieve price clarity in this trade, the price and the basic fare (the price per kilogram or litre) are to be indicated when delivering the food. The labelling is thus intended to provide basic information about the type, quantity and quality of a food and thus to enable a proper purchasing decision.


In addition to the mandatory labelling elements, the food may be advertised with additional information of the manufacturers, whereby the data must comply with Food Law and should not be used for misleading purposes.


In particular areas, such as nutritional and health related information, specific conditions for the use and the type of labelling are required.

Particular regulations (also including those related to labelling) apply for instance to the area of organic food, additives, genetically modified substances, substances related to nanotechnology, irradiated foodstuffs etc.

Labelling of allergens in food packaging:

Manufacturers must clearly identify certain substances that can cause allergies or intolerances in the food list. In the future, these substances must be visibly highlighted in the list of ingredients on packaged foods, for example by using a different font or a different background colour.

Labelling of allergies in bulk goods:

Even in the case of non-packaged foodstuffs, so-called „loose or bulk goods“, the specification of these substances will be mandatory in the close future.

Indication of origin for meat products:

The indication of origin has been prescribed for beef since 2000; from April 2015 onwards this is also required for pigs, sheep, goats and poultry meat. Details have been defined at EU level in December 2013 (Commission Implementing Regulation (EU) No 1337/2013 of 13 December 2013).

Minimum font size:

All obligatory information must be in a clearly visible place and clearly legible and printed at least in a 1.2 mm-sized font – relative to the height of the small „x“, i.e. the middle part of the letter. If the largest surface area of the package is less than 80 square centimetres, the font size must be at least 0.9 mm.

Nutritional value labelling, new Form since 13.12.2014, from 13.12.2016 Mandatory fields:

The nutritional information, which has been largely optional so far, will be mandatory from the 13th December 2016 throughout the European Union for mandatory pre-packaged food. Nutritional values must also include the proportion of saturated fatty acids and sugars. In addition, the salt content must be indicated. Nutritional values, which are already obligatory due to nutritional claims (e.g. „less fat“), must comply with the specifications of the LMIV (since 13.12.2014). The same applies to nutritional values, which are made voluntarily. For all other packaged foodstuffs, a general labelling requirement applies as from 13.12.2016.


Regulation for the distance of foodstuff sales:

If foodstuff is sold my means of “distance selling platforms”, such as online shops or similar, mandatory labels such as the list of ingredients and the nutrition labelling must be available before the contract is concluded. An exception applies to the minimum shelf-life date, which must be indicated at the time of delivery.

Food products imitation and related products:

In order to protect consumers against deception, specific labelling requirements have been defined for so-called „food imitations“, where a common ingredient has been replaced by another ingredient. The substitute substance must be indicated in the immediate vicinity of the product name with a minimum size of 75% of the product name.

Meat or fishery products which might be constituted of smaller pieces must be presented with the words „assembled from pieces of meat“ or „made from fish pieces“.


Food products imitation and related products:

In order to protect consumers against deception, specific labelling requirements have been defined for so-called „food imitations“, where a common ingredient has been replaced by another ingredient. The substitute substance must be indicated in the immediate vicinity of the product name with a minimum size of 75% of the product name.

Meat or fishery products which might be constituted of smaller pieces must be presented with the words „assembled from pieces of meat“ or „made from fish pieces“.


Refined oils and fats of vegetable origins:

When vegetable oils and fats are grouped together in the list of ingredients with the designation „vegetable oils“ or „vegetable fats“, a list with the particulars of the specific plant origin (e.g. palm oil, soya oil) must follow immediately afterwards. The indication of a hardened oil or grease must be provided with the expression „fully hardened“ or „partially hardened“.

Foods containing caffeine:

Warnings have to be written on the labels of certain caffeine-containing foods (such as energy drinks) for children, pregnant women and breastfeeding mothers.

Indications on frozen products:

In the case of frozen meat, frozen meat preparations and frozen unprocessed fishery products, the freezing date must be indicated as „frozen on: DD.MM.YY”

Indication „Nano“:

All ingredients, which are available in the form of technically produced nanomaterials, must be listed clearly in the list of ingredients. The word „Nano“ must follow the name of such ingredients.

Instruction for use and storage instructions:

A new provision regards the obligation to provide specific “instructions for use” of the foodstuff, (e.g. preparation instructions) as well as the obligation to specify storage instructions, if necessary (e.g. certain storage conditions).

Further new and actual regulations:

It is nowadays also mandatory to specify if thawed products have been used, or if there is the presence of added water, added animal proteins in meat products, or the utilization of non-edible sausage casing.