On September 4, 2026, the UK Food and Standards Agency released packaging and labelling guidance. It provides the legal requirements food businesses need to follow if they are supplying products in England, Northern Ireland, and Wales. Pre-packed and non-pre-packed foods, allergen declarations, food packaging, product composition, nutritional information, food authenticity, and labelling presentation are covered in this guidance.
Let’s know more inclusions and changes this update has brought to the UK’s current legal framework and requirements such food businesses must take care of.
Changes Introduced in the September 2026 FSA Update
The changes are regarding the updates in the legal terminology. The guidance explains how the relevant legislation should be understood in Great Britain versus Northern Ireland. It states that references to EU Regulations should be understood as references to assimilated EU law except in Northern Ireland. In Northern Ireland, relevant EU food law continues to apply.
Great Britain
Food businesses here should follow the assimilated version of Regulation 1169/2011, the Food Information to Consumers (FIC) Regulation.
Northern Ireland
EU food law, including Regulation (EU) No. 1169/2011, continues to apply in the circumstances described in the guidance.
Food Labelling Requirements for Pre-Packed Food
All prepacked food requires a food label displaying some mandatory information. Further, food labelling must be accurate and must not mislead consumers. Businesses must also consider whether their products fall under additional product-specific regulations. These can impose requirements beyond the general food information rules.
The FSA identifies product-specific rules covering products such as the following:
- Bread and flour
- Cocoa and chocolate products
- Soluble coffee
- Milk products
- Honey
- Fruit juices and nectars
- Infant formula
- Jams and marmalades
- Meat products, including sausages, burgers and pies
- Fish
- Natural mineral waters
- Spreadable fats
- Sugars
- Irradiated food
- Foods containing genetically modified organisms or ingredients
Mandatory Information on Food Packaging
There are several categories of information that food labels need to comply with legally. Check them below:
1. Name of the Food
The name of the food must be clearly stated. It must not mislead consumers. Use the specific legal name where the legislation prescribes it. In the absence of such a prescription, a customary name may be used if one is established and understood by consumers.
If neither a legal nor customary name is applicable, the business must provide a descriptive name that explains the true nature of the food. It must distinguish it from products with which it could otherwise be confused.
Where food has undergone a relevant processing treatment, the process may also need to appear in the food’s name. Examples given by the FSA include terms such as “smoked bacon”, “salted peanuts” and “dried fruit”.
2. Ingredients List
Where a food contains two or more ingredients, including water and additives, the ingredients must generally be listed under the heading “Ingredients” or an appropriate heading containing the word “ingredients”.
They must be listed in descending order of weight based on the quantities used when the food was manufactured. This means the ingredient used in the greatest quantity generally appears first. There are exemptions from the requirement to provide an ingredients list for some foods. The guidance gives examples including some fresh fruit and vegetables, carbonated water, and foods consisting of a single ingredient.
3. Allergen Labelling
A product having one or more of the 14 allergens is required to be declared by law. These relevant allergens must be identified within the ingredients list. They should also be emphasised so that consumers can identify them easily.
A different font or type style, a contrasting background, or bold text are a few ways to emphasise allergens. The objective is to make such ingredients readily distinguishable from the rest of the ingredients list.
4. Quantitative Ingredient Declaration (QUID)
A Quantitative Ingredients Declaration (QUID) tells consumers the percentage of a particular ingredient or category of ingredients contained in a food. The FSA guidance states that QUID is required when an ingredient or category:
- Appears in the name of the food or is normally associated with that name;
- Is emphasised on the label through words, pictures or graphics; or
- Is essential for characterising the food and distinguishing it from another food with which it could otherwise be confused.
The quantity must be expressed as a percentage corresponding to the amount of the ingredient used when the food was manufactured. The percentage must appear either In or immediately next to the name of the food or In the ingredients list in connection with the relevant ingredient or category.
5. Net Quantity Requirements
Packaged foods generally need a net quantity declaration where the quantity exceeds 5g or 5ml. For food packaged in a liquid or covered by an ice glaze, the drained net weight must also be declared where applicable.
The guidance also identifies exemptions, including certain foods that are:
- Sold by number where the items can be clearly seen and counted;
- Sold by number where the quantity is otherwise indicated on the label;
- Below the 5g/5ml threshold, subject to the stated exceptions;
- Sold by weight or number in the presence of the purchaser in specified circumstances.
Businesses should assess the specific product and its method of sale when determining the appropriate quantity declaration.
6. Date Labelling and Storage Conditions
Food labels must include either a “best before” or “use by” date, as applicable. It will let consumers know how long the food can be kept and how it should be stored. Relevant food businesses need to make sure that date marking and storage instructions are appropriate for the product and consistent with its safety and quality characteristics.
7. Business Name and Address
Food packaging must include the relevant business name and physical address. The address may generally be that of the business under whose name the food is marketed or the importer, whatever is applicable.
There are specific address requirements depending on whether food is being placed on the GB or NI market. For products sold in Great Britain, the guidance states that from 1 January 2024, food products must include a UK, Channel Islands or Isle of Man address for the food business. Where the business is outside the relevant area, the importer address requirements apply.
For food sold in Northern Ireland, the relevant business address must be in Northern Ireland or the EU. Check the conditions described in the guidance. Importantly, the address must be a physical postal address to contact the business. An email address or telephone number alone cannot replace the required address.
8. Country of Origin and Place of Provenance
If you fail to provide this information, it could mislead consumers about the true origin or provenance of the food. The FIC framework also contains specific origin rules, including rules relating to primary ingredients, some meats, and meat, fish and seafood products
The guidance provides a specific reference for businesses that need to determine when origin information is mandatory. There are additional considerations for food placed on the Northern Ireland market. They are under applicable EU origin rules.
9. Preparation and Cooking Instructions
Preparation or cooking directions must be present on the label of those products where the consumer must know their appropriate use. If a product needs heating, the label will generally need to communicate relevant information. It includes the oven temperature, cooking time, or microwave instructions where applicable.
10. Nutrition Labelling
Present compulsory nutrition information in the needed format. It should include energy and six nutrients. The declaration must provide values per 100g or 100ml. Energy should be expressed in both Kilojoules (kJ) and Kilocalories (kcal). The nutrition declaration must also meet the minimum font-size requirements that apply.
11. Additional Labelling Requirements for Certain Foods
Some foods and drinks have additional mandatory labelling requirements. The FSA specifically identifies products containing or using sweeteners or sugars, aspartame and some colourings, liquorice, caffeine, and polyols. These are categories where additional information may need to be provided to consumers.
How Must Mandatory Information Be Displayed?
Food businesses need to consider what information appears on the label as well as its presentation. The FSA specifies minimum font-size requirements based on the x-height of the font. The usual minimum is 1.2mm. Where the largest surface area of packaging is less than 80cm², a minimum x-height of 0.9mm may be used.
The food information that’s compulsory must also be easy to see and clear to read and understand. It should be difficult to remove where appropriate and not be hidden or obscured. It should not be detracted from or interrupted by other written or pictorial material. Consumers should not be required to open the product to get the mandatory information.
Requirements for Non-Pre-Packed Food
Non-prepacked food can include food that is sold loose in retail outlets, restaurant-served meals, takeaway food, or food packed at the selling point at the consumer’s request, like a sandwich prepared in front of the consumer. Consumers must know the food name, information and presence of 14 declarable allergens, and a QUID declaration about products that have meat.
This information may be provided through a label attached to the food or through a notice, ticket or label that is readily visible to the intending purchaser. For irradiated food, the relevant statement “irradiated” or “treated with ionising radiation” must appear near the food’s name.
Unlike prepacked food, businesses are currently not generally required to give a full ingredients list for non-prepacked food. However, they should make allergen information available. Clear signposting must tell consumers where they can obtain allergen information that’s not provided directly in writing, such as from a member of staff.
Additional Food Packaging and Labelling Requirements
Some other updates provided in the guidance are as follows:
1. Prepacked for Direct Sale (PPDS) Food
PPDS foods should have a full ingredients list. There should be a clear emphasis on allergenic ingredients within that list.
2. Vacuum Packaging and Modified Atmosphere Packaging
Businesses that use vacuum packing (VP) or modified atmosphere packaging (MAP) must also consider food safety and packaging controls. The FSA states that businesses must do the following:
- Use packaging materials that will not contaminate the food;
- Store wrapping materials in a way that protects them from contamination;
- Package food in a manner that prevents contamination;
- Ensure containers are clean and undamaged;
- Pay particular attention to cans and glass jars; and
- Maintain the cleanliness of packaging materials.
3. Food Authenticity and Misleading Labelling
Food labelling is also closely connected to food authenticity. FSA’s description of food authenticity is ensuring that food matches its description. The information consumers receive should let them make informed decisions. They can consider factors like diet, allergies, personal preferences, and cost. Mislabelled food can deceive consumers and create competition that’s not fair.
The description of a food can relate to its name, ingredients, origin, and processing. The FSA also makes clear that falsely describing, advertising or presenting food is an offence and that multiple laws are in place to protect consumers against dishonest or misleading food descriptions.
So, businesses should review marketing claims, product names, images, ingredient declarations and origin statements.
Applicable Legislation in Different Areas
Here’s an overview of legislation that applies:
| Area | Applicable Legislation |
| Great Britain |
The assimilated version of Regulation 1169/2011. It contains the provision of food information to consumers
|
| England |
The Food Information Regulations 2014 provide the enforcement framework for the applicable FIC requirements
|
| Northern Ireland |
The Food Information Regulations 2014 (Northern Ireland) provide the enforcement framework for the EU FIC Regulation 1169/2011 applicable here
|
| Wales |
The Food Information (Wales) Regulations 2014 provide the enforcement framework for the assimilated FIC Regulation in Wales
|
Conclusion
The 4 September 2026 FSA update should not be interpreted as a completely new food-labelling regime. Its principal change is the updated terminology referring to “assimilated EU law” in the relevant Great Britain context, while EU food law continues to apply in Northern Ireland under the applicable arrangements. However, the updated guidance provides a useful consolidated reminder of the requirements that food businesses need to consider when designing, reviewing or updating packaging and labels.
If your business requires a review and implementation of these laws appropriately, reach our Artixio team at info@artixio.com.
