EU Nutrition Declaration: What to Include & Format

The mandatory EU nutrition declaration lists energy in kilojoules and kilocalories, plus fat, saturates, carbohydrate, sugars, protein and salt, normally per 100 g or 100 ml. Regulation (EU) No 1169/2011 requires a table where space permits, while per-portion values and selected extra nutrients may be added voluntarily.

A nutrition declaration allows consumers to compare the energy and nutrient content of packaged foods using a consistent format. For most prepacked foods sold in the European Union, it forms part of the mandatory food information required under Regulation (EU) No 1169/2011, commonly called the Food Information to Consumers Regulation.

The core requirements are harmonised across the EU, but sector-specific legislation and properly adopted national measures may add requirements for particular products. Businesses should therefore verify both the EU framework and the rules applying in each country where the product will be marketed.

At a glance

• Declare energy in both kJ and kcal.

• List fat, saturates, carbohydrate, sugars, protein and salt.

• Express the information per 100 g or 100 ml.

• Use a table with aligned figures where packaging space permits.

• Treat per-portion values and reference-intake percentages as additional information.

• Document the evidence, calculations and approval process behind every declared value.

This article concerns the back-of-pack nutrition declaration. Voluntary front-of-pack systems are covered separately in Nutri-Score explained, while wording such as “low fat” or “high fibre” is addressed in the guide to nutrition and health claims.

What must be declared on an EU nutrition label?

Key takeaway: The mandatory declaration contains energy and six named nutrient amounts in a prescribed order.

Article 30 of Regulation (EU) No 1169/2011 requires the mandatory nutrition declaration to contain:

1. Energy

2. Fat

3. Of which saturates

4. Carbohydrate

5. Of which sugars

6. Protein

7. Salt

Energy must appear in both kilojoules and kilocalories. Nutrient amounts are generally expressed in grams. The items must be presented together and, where appropriate, in the order established by Annex XV.

Mandatory declaration format

The label must state salt, not simply sodium. Where appropriate, a statement may be placed near the declaration explaining that the salt content is exclusively due to naturally occurring sodium.

Which additional nutrients may be included?

The mandatory declaration may be supplemented with:

• Mono-unsaturates

• Polyunsaturates

• Polyols

• Starch

• Fibre

• Specified vitamins and minerals present in significant amounts

These additions are voluntary unless another legal provision or a claim requires further information. They must follow the prescribed order and should not reduce the clarity or space given to mandatory information. Vitamins and minerals must also be expressed as a percentage of the relevant nutrient reference value.

How must energy be shown in the nutrition declaration?

Key takeaway: Energy must be declared in both kilojoules and kilocalories, in that order.

The energy line should use the format kJ/kcal, followed by the appropriate values per 100 g or 100 ml. Annex XIV provides the conversion factors used to calculate energy from energy-producing nutrients, including carbohydrate, protein, fat, fibre, polyols, organic acids and alcohol.

An illustrative energy line might read:

Energy: 840 kJ / 200 kcal

The figures should arise from a documented calculation or analysis. Businesses should not convert between kJ and kcal using an improvised rounded multiplier after the rest of the declaration has been finalised, because this can create inconsistent values.

Illustrative nutrition declaration

The following example demonstrates the required sequence. The figures are illustrative and must not be copied onto a real product without product-specific evidence.

How should an EU nutrition declaration be formatted and rounded?

Key takeaway: Use a clear table with aligned numbers, and apply a documented rounding method consistently.

Article 34 requires the mandatory particulars to appear together in the same field of vision. They should be presented in a tabular format with the numbers aligned when space permits. A linear format is allowed only where available space does not permit a table.

A compliant layout should therefore:

• Keep all mandatory nutrients together.

• Preserve the prescribed order.

• Align figures so they can be scanned easily.

• State the per-100 g or per-100 ml basis clearly.

• Use the required measurement units.

• Meet the wider legibility requirements for mandatory food information.

• Avoid decorative formatting that obscures nutrient names or values.

Rounding and tolerances

Regulation (EU) No 1169/2011 requires declared values to represent averages rather than exact amounts in every individual unit. Natural ingredient variation, manufacturing differences and changes during storage mean that measured values may not always equal the printed figure precisely.

The European Commission’s tolerance guidance provides a framework used by competent authorities when comparing declared values with analytical results. It distinguishes between nutrients and concentration ranges and includes measurement uncertainty. The guidance is not legislation and does not replace the Regulation or decisions by courts and enforcement authorities.

Businesses should establish a written rounding and tolerance procedure that:

1. Uses representative average values.

2. Applies the same rounding convention across product ranges.

3. Accounts for normal production and shelf-life variation.

4. Prevents systematic understatement of nutrients such as sugars, fat or salt.

5. Applies stricter controls where a nutrition or health claim depends on a threshold.

6. Retains calculations and supporting evidence for review.

Can values be shown per portion and as a percentage of reference intake?

Key takeaway: Per-portion and reference-intake information may supplement, but generally not replace, the per-100 g or per-100 ml declaration.

Article 33 permits values to be expressed per portion or consumption unit where the portion is easily recognisable, quantified on the label and accompanied by the number of portions or units in the package. The portion must also be identified close to the nutrition declaration.

For example:

• Per 30 g portion

• Per biscuit

• Per 250 ml glass

• Four portions per package

The chosen serving should be realistic and consistently applied. A deliberately small serving can create an incomplete impression even when the mathematical calculation is correct.

Reference-intake percentages

Energy and specified nutrients may also be shown as a percentage of the reference intake for an average adult. When this format is used, the statement “Reference intake of an average adult (8 400 kJ/2 000 kcal)” must appear close to it.

Reference-intake percentages are voluntary additional information. They do not replace the underlying obligation to provide accurate amounts in the required units.

Is nutrition labelling mandatory for every food?

Key takeaway: Nutrition declarations are mandatory for most prepacked foods, but Regulation 1169/2011 contains defined exemptions.

Annex V exempts several categories from the mandatory nutrition declaration. Examples include certain unprocessed single-ingredient foods, herbs and spices, salt, some coffees and teas, flavourings, food additives, chewing gum, very small packages and qualifying small-quantity direct supplies.

Packaging with a largest surface of less than 25 cm² is one listed exemption. Annex V also covers food, including handcrafted food, that is supplied in small quantities by the manufacturer to final consumers or to local retail establishments that supply final consumers. The practical meaning of “small quantities”, “local” and direct supply may require confirmation under the approach of the relevant national authority.

Alcoholic beverages above 1.2% alcohol by volume also receive a general exemption from the mandatory nutrition declaration under Article 16(4), subject to other Union rules applicable to particular products. Food supplements and natural mineral waters are governed through separate legal frameworks rather than the ordinary nutrition-declaration section of Regulation 1169/2011.

An exemption should never be assumed merely because a product is simple, artisan-made or sold by a small business.

When an exemption may not solve the issue

Before relying on an exemption, check whether:

• Sector-specific EU legislation requires nutrition information.

• A nutrition or health claim triggers additional declaration requirements.

• Vitamins or minerals have been added.

• The product is sold in a market with an applicable national measure.

• Voluntary nutrition information has been provided and must therefore comply with presentation rules.

For broader label requirements, consult the complete EU food labelling regulations guide.

Country variations: Regulation 1169/2011 creates the main EU-wide framework, but Member States may adopt justified additional particulars for specific foods and determine enforcement practices within their competence. Confirm local requirements before placing the same label on multiple national markets.

How should a business approve a nutrition table before printing?

Key takeaway: A controlled sign-off process is as important as the arithmetic behind the values.

A practical nutrition-declaration workflow should include the following stages:

1. Confirm the product scope. Determine whether the food is prepacked, whether Regulation 1169/2011 applies and whether any sector-specific regime is relevant.

2. Check exemptions. Record the legal basis if the business intends to rely on one.

3. Lock the formulation. Use the approved recipe, ingredient specifications and processing conditions.

4. Select the evidence method. Choose laboratory analysis, recipe calculation, accepted data or an appropriate combination.

5. Calculate the complete declaration. Include energy, mandatory nutrients and any justified voluntary nutrients.

6. Apply the correct basis. Present values per 100 g or per 100 ml, then add any permitted portion information.

7. Review order and units. Check Annex XV sequence, kJ/kcal presentation and measurement units.

8. Check claims separately. Verify that any nutrition or health claim complies with its own legal conditions.

9. Complete technical approval. Require sign-off by an authorised quality, regulatory or technical reviewer.

10. Control later changes. Reassess the declaration whenever the formulation, supplier, process, portion size or legal requirements change.

A recurring operational weakness is treating nutrition values as static artwork rather than controlled product data. The declaration should be connected to formulation control, supplier approval and packaging-change procedures.