UK Food Labelling Policies and Procedures

Food labelling in the UK is one of the most heavily regulated areas of consumer protection law. Getting it wrong exposes a business to local-authority enforcement, civil claims, criminal prosecution under the Food Safety Act 1990, and severe reputational damage.

Getting it right is a matter of having documented policies, current ingredient and allergen data, and trained staff who can apply both consistently.

Legal Basis

The framework for UK food labelling is the retained EU Food Information for Consumers Regulation (EU FIC, Regulation 1169/2011), the Food Safety Act 1990, the Food Information Regulations 2014 (with parallel devolved equivalents), the General Food Regulations 2004, the Weights and Measures Act 1985, and the Food Hygiene (England) Regulations 2013.

The Food Standards Agency is the lead regulator, with enforcement delivered by local authority Trading Standards and Environmental Health teams.

Two recent changes are particularly significant. Natasha's Law, in force since 1 October 2021, requires full ingredient and allergen labelling on food prepacked for direct sale (PPDS).

The Nutrition (Amendment etc.) (EU Exit) Regulations 2020 settled the post-Brexit position on nutrition labelling and health claims, with the FSA continuing to authorise new claims under the GB regime.

What a Food Labelling Policy Should Cover

The 14 named allergens, identified across raw materials, recipes and finished products.
Mandatory information for prepacked food: name of food, ingredient list with allergen emphasis, quantitative ingredient declaration (QUID) where required, net quantity, date marking, storage conditions, name and address of operator, country of origin where relevant, instructions for use, alcoholic strength.
Nutrition declaration in the legal back-of-pack format.
PPDS labelling procedure (Natasha's Law) for food made and packaged on the same site for direct sale.
Verbal information procedure for non-prepacked food.
Voluntary "may contain" precautionary statements used only where supported by risk assessment.
Claims procedure (nutrition, health, organic, free-from) compliant with the relevant authorisation regime.
Country of origin and place of provenance rules, including the rules for primary ingredient origin where the food's origin is given.
Date marking discipline ("use by" for safety, "best before" for quality) and supplier change management.

Common Compliance Pitfalls

Recipe changes implemented at production without a parallel label change.
"May contain" statements used as a blanket disclaimer instead of as a risk-assessed declaration (the FSA expects evidence).
Allergen information held by the chef but not transferred to front-of-house or to the labelling system.
Imported products relabelled inconsistently, with mismatched allergen, origin or quantity declarations.
PPDS treated as outside scope when sandwiches and cakes are made and packaged on the same premises.
Nutrition claims made without authorisation under the GB nutrition and health claims register.

Sector-Specific Considerations

Hospitality and food service: The verbal allergen procedure for non-prepacked food and the PPDS labelling procedure for grab-and-go items are the two most enforced areas. Staff training records are routinely requested at inspection.

Retail and wholesale: Specification management with suppliers, change-control on artwork, and "use by" verification at receipt are the operational priorities.

Manufacturers: The QUID rules, allergen cross-contamination controls and post-Brexit GB versus Northern Ireland labelling routes (the Windsor Framework introduced "Not for EU" labelling for Great Britain goods) all require documented procedures.

What Policy Pros Delivers

Our Food Labelling Policy package includes the main policy aligned to EU FIC, the Food Information Regulations 2014, Natasha's Law and the GB nutrition and health claims framework.

We also draft the supporting allergen management policy, the recipe change-control procedure, the supplier specification template, the verbal information procedure for non-prepacked food, and the PPDS label-design procedure.

The package is suitable for hospitality groups, food manufacturers, food service operators, retail bakeries, school caterers, contract caterers and small producers.

Documents are reviewed and updated as the FSA publishes new guidance, including the rolling consultations on labelling reform during 2025-2026.

For more information, please email, call or complete an enquiry form for a quote.