How to Write a Food Ingredients List (Order, QUID and Additives)

What counts as an ingredient?

Key takeaway: An ingredient is generally something used to make the food that remains present in the finished product, even in an altered form.

Regulation 1169/2011 defines an ingredient broadly. It can include substances, products, flavourings, food additives, food enzymes and components of compound ingredients that are used in manufacture or preparation and remain present in the finished food. Residues are not treated as ingredients merely because trace amounts remain.

An ingredients list may therefore need to cover:

• Primary raw materials

• Oils, fats, flour, sugar and salt

• Additives that perform a technological function

• Flavourings

• Enzymes where declaration is required

• Vitamins and minerals added to the food

• Ingredients within sauces, fillings, coatings or other compound ingredients

• Allergens present through any ingredient or compound ingredient

Which constituents may be omitted?

Article 20 provides limited circumstances in which certain constituents do not have to appear in the ingredients list. Examples can include processing aids and additives carried over from an ingredient where they perform no technological function in the finished product. Some carriers and substances used temporarily during processing may also qualify.

These omissions must be assessed carefully. An omission from the ordinary ingredients declaration does not remove the obligation to communicate the presence of a substance or product causing an allergy or intolerance where Article 21 requires its declaration.

Use the correct ingredient name

Ingredients should be identified by their specific legal name or, where no legal name exists, an appropriate customary or descriptive name. Internal abbreviations, supplier codes and vague terms that consumers cannot understand should not be copied directly from technical specifications.

What is QUID in food labelling?

Key takeaway: QUID is the percentage declaration required for certain ingredients that are named, highlighted or essential to the character of a food.

QUID means quantitative ingredient declaration. Article 22 requires the quantity of an ingredient or ingredient category to be stated when it:

• Appears in the name of the food or is normally associated with that name

• Is emphasised through words, images, graphics, type size, colour or styling

• Is essential to characterise the food and distinguish it from similar products

The European Commission’s QUID guidance gives examples such as strawberry yoghurt, salmon mousse, chocolate ice cream and ham-and-mushroom pizza. When an ingredient is highlighted in this way, its proportion will normally need to be shown unless a specific exemption applies.

Worked QUID example

A business manufactures Strawberry Yoghurt using:

• Yoghurt: 85%

• Strawberry preparation: 12%

• Sugar: 3%

Because strawberry appears in the product name, the relevant strawberry quantity must be declared. If the strawberry preparation itself contains only 60% strawberries, the declaration must reflect the amount of strawberry in the finished food rather than presenting the entire preparation as pure strawberry.

The calculation would be:

12% strawberry preparation × 60% strawberry content = 7.2% strawberry in the finished formulation.

Ingredients: yoghurt (MILK), strawberry preparation 12% [strawberries 60%, sugar, thickener: pectin], sugar.

Depending on the presentation and applicable guidance, the label may also need to communicate that strawberries constitute 7.2% of the finished product. The QUID value should be calculated from controlled formulation data and reviewed against the precise name, images and claims used on the pack.

Where should the QUID percentage appear?

The percentage is normally placed either in or immediately next to the name of the food, or in the ingredients list next to the relevant ingredient or category. The declared figure generally corresponds to the quantity used at the time of manufacture, subject to special calculation rules and exemptions.

When might QUID not be required?

Exceptions can apply, including certain situations where:

• A drained net weight is already declared

• The quantity is required by another specific EU rule

• An ingredient is used in a small quantity for flavouring

• The quantity does not influence consumer choice

• The food consists of a single ingredient

• A particular non-prepacked food is not covered unless national rules require QUID

Do not apply an exemption solely because an ingredient has a low percentage. The reason for its presence in the product name, imagery or marketing remains relevant.

How do you list additives and E numbers?

Key takeaway: Declare an additive using its functional class followed by its specific name or E number.

Food additives are substances used for technological purposes such as preserving food, maintaining texture, adding colour, controlling acidity or stabilising a product. Their use is regulated by Regulation (EC) No 1333/2008, which establishes Union lists and conditions of use for authorised additives.

In the ingredients list, an additive is generally declared by:

Functional class + specific name

or

Functional class + E number

Examples include:

• Preservative: sodium nitrite

• Preservative: E 250

• Antioxidant: ascorbic acid

• Antioxidant: E 300

• Thickener: xanthan gum

• Thickener: E 415

• Colour: curcumin

• Colour: E 100

The European Commission confirms that additives should be identified by their functional class followed by the specific name or E number.

Is an E number evidence that an additive is unsafe?

No. An E number identifies an additive authorised for use in the European Union under defined conditions. The European Food Safety Authority assesses the safety of new additives and proposed new uses, while authorised substances may also be re-evaluated as scientific evidence develops.

However, authorisation does not mean an additive can be used in every food or at any concentration. The business must verify that the additive is permitted for the relevant food category and complies with applicable maximum levels, restrictions and specifications. The European Commission’s additives database reflects the Union list in Annex II of Regulation 1333/2008.

How should compound ingredients be listed?

Key takeaway: A compound ingredient is usually named in the list and followed immediately by its own component ingredients.

A compound ingredient is an ingredient made from two or more ingredients. Examples include chocolate, mayonnaise, fruit filling, biscuit pieces, pesto, stock, sauce or a prepared spice paste.

Annex VII allows a compound ingredient to appear under its own legal or customary designation, positioned according to its total weight in the finished food and followed by a breakdown of its components.

For example:

Ingredients: wheat flour, chocolate pieces 18% [sugar, cocoa mass, cocoa butter, emulsifier: lecithins (SOYA), natural vanilla flavouring], butter (MILK), sugar, egg (EGG).

When may compound sub-ingredients be omitted?

Narrow exemptions apply to certain compound ingredients, including some whose composition is defined in EU legislation and which account for less than 2% of the finished product. Other exemptions may apply where the compound ingredient itself is a food for which an ingredients list is not required.

These exemptions do not override allergen declaration requirements. If a compound ingredient introduces an Annex II allergen, the relevant allergen must still be communicated and emphasised as required.

Practitioner observation: Supplier specifications frequently list a sauce or filling as a single item without giving a complete sub-ingredient breakdown. Artwork should not be approved until the technical team has obtained the current composition, allergen status and additive functions from the supplier.

How are allergens shown in an ingredients list?

Key takeaway: Annex II allergens must be named and visually emphasised within the ingredients list.

Article 21 requires substances or products listed in Annex II to be indicated with a clear reference to the allergen’s name. The allergen must be emphasised through a typesetting method that clearly distinguishes it from the rest of the list, such as a different font, style or background colour.

Bold text is widely used, but EU law does not prescribe bold as the only method. Whatever method is selected must make the allergen clearly distinguishable.

Example:

Ingredients: wheat flour (WHEAT), butter (MILK), sugar, pasteurised egg (EGG), almonds (ALMONDS), raising agent: sodium carbonates.

The ingredient name should identify the relevant Annex II substance. A vague statement such as “contains gluten” does not replace the need to name the relevant cereal, such as wheat, rye, barley or oats, where applicable.

For a detailed explanation of the on-pack declaration mechanics, see allergen labelling requirements for prepacked food. For allergen characteristics, cross-contact controls and operational management.

Country variations

Regulation 1169/2011 creates an EU-wide framework, but the mandatory information must appear in a language easily understood by consumers in the Member State where the food is marketed. Member States may require information in one or more official EU languages within their territory, while national rules may also affect certain product categories and non-prepacked foods.

A label approved for one EU market should therefore not automatically be released in another market without checking language, product-specific and national requirements.

A practical ingredients-list approval process

Key takeaway: Build the ingredients list from controlled formulation and supplier data, then verify every legal trigger before approving artwork.

Use this seven-step process:

1. Confirm the current recipe. Use the approved manufacturing formulation, including rework, processing aids and ingredient preparation details.

2. Collect complete supplier specifications. Obtain sub-ingredients, additive functions, allergen status and percentage composition where needed.

3. Determine ingredient order. Rank ingredients by weight at the time they are used, applying Annex VII rules where relevant.

4. Identify QUID triggers. Review the product name, front-of-pack wording, images, graphics and claims.

5. Check additive declarations. Confirm authorisation and declare each relevant additive by functional class plus name or E number.

6. Apply allergen emphasis. Trace allergens through all ingredients and compound ingredients.

7. Complete an independent pre-print review. Compare the final artwork against the approved specification and retain evidence of sign-off.

Pre-print checklist

Before release, verify that:

• The heading includes the word “ingredients”

• Every required ingredient is present

• The order matches the current manufacturing recipe

• Ingredient names are legally and technically accurate

• Compound ingredients are properly broken down

• QUID percentages are calculated and positioned correctly

• Additive functional classes are stated

• E numbers or specific additive names are accurate

• Annex II allergens are clearly identified and emphasised

• Marketing images and claims do not create an undeclared QUID obligation

• The correct market language is used

• The approved list matches the final packaging artwork

Write compliant ingredient lists with confidence

Key takeaway: Effective training helps technical, product-development and packaging teams apply food ingredients list rules consistently before labels reach print.

Ingredients-list errors commonly begin with fragmented data: product developers hold the recipe, suppliers hold compound-ingredient information, marketing controls the front-of-pack emphasis, and artwork teams control the final presentation.

The Food Labelling Regulations Training helps relevant teams understand Regulation 1169/2011, ingredient order, QUID, allergens, additives and wider food-label approval requirements. It should form part of a documented process rather than replace product-specific legal and technical review.

Applying food ingredients list rules correctly requires more than arranging words in a sequence. Businesses must connect formulation data, supplier information, packaging claims, allergen controls and artwork approval through one controlled sign-off process.

Sources and Methodology

Key takeaway: This article is based on current EU legislation, European Commission guidance, EFSA information and practical label-review principles.

The article was prepared using:

• Regulation (EU) No 1169/2011 on the provision of food information to consumers, including Articles 18–22 and Annex VII.

• European Commission Notice on the application of quantitative ingredient declaration principles.

• Regulation (EC) No 1333/2008 on food additives.

• European Commission information and database resources concerning authorised additives and their labelling.

• European Food Safety Authority information on additive safety assessment and re-evaluation.

• Search-intent analysis and professional good practice for controlled label review.