Who is responsible for the label of a private label food in the EU?
The operator under whose name the food is marketed is responsible for its label, under Article 8 of Regulation (EU) No 1169/2011; for private label that is the brand on the pack, or the importer if the brand is outside the EU. The manufacturer answers for its own registration, and for approval when it makes meat or fish products.
Who answers for the label: the brand or the manufacturer?
The brand. Regulation (EU) No 1169/2011, Article 8(1) makes the responsible operator the one "under whose name or business name the food is marketed", or "the importer into the Union market" when that operator is not established in the EU. Under Article 8(2), that operator "shall ensure the presence and accuracy of the food information".
Read plainly, a co-packer that makes the food but does not market it under its own name is not that operator for your product; your brand is. Article 8(4) adds that operators "shall not modify the information accompanying a food" where the change would mislead. The articles are quoted as adopted in 2011; check the current text on EUR-Lex.
What must the label of a private label food show?
The particulars in Article 9(1). They include the name of the food, the list of ingredients, allergens from Annex II, the net quantity, the date of minimum durability or "use by" date, the name and address of the operator in Article 8(1), the origin where Article 26 requires it, and a nutrition declaration.
| Particular | Wording in Article 9(1) | For a private label |
|---|---|---|
| Name of the food | "the name of the food" | Needed on every pack, whatever the brand name |
| Ingredients | "the list of ingredients" | Taken from the recipe the manufacturer uses; check it against the final formula |
| Allergens | Any ingredient or processing aid listed in Annex II "causing allergies or intolerances" | Processing aids count, not only ingredients |
| Net quantity | "the net quantity of the food" | Needed on every pack |
| Date | "the date of minimum durability or the 'use by' date" | One of the two, depending on the food |
| Operator | "the name or business name and address of the food business operator referred to in Article 8(1)" | Your company, or the importer if your company is outside the EU |
| Origin | "the country of origin or place of provenance where provided for in Article 26" | Only where Article 26 requires it; see the origin section below |
| Instructions for use | Where it "would be difficult to make appropriate use of the food in the absence of such instructions" | Only for foods that are hard to use without them |
| Alcohol | "the actual alcoholic strength by volume" | Beverages with more than 1.2% alcohol by volume |
| Nutrition declaration | "a nutrition declaration" | Point (l); applies from 13 December 2016 (Article 55) |
Article 9(1) has further points that this table does not show; read the full list on EUR-Lex before you approve the artwork. Article 55 says the Regulation "shall apply from 13 December 2014", with the nutrition declaration following on 13 December 2016.
How large and in which language must the text be?
At least 1.2 mm x-height, in a language consumers easily understand. Article 13(2) requires an x-height "equal to or greater than 1,2 mm" for printed mandatory particulars, or 0.9 mm when the largest surface of the pack is under 80 cm². Article 15(1) requires a language "easily understood by the consumers".
The x-height is defined in Annex IV, and Article 13(1) asks for information that is easily visible and clearly legible. Article 15(2) says a Member State "may stipulate that the particulars shall be given in one or more languages" within its territory. This guide does not cover the national language rules of the five countries; the food authority of each country where you sell is the place to check them.
When must the label say where the food or its main ingredient comes from?
When leaving it out could mislead. Article 26(2)(a) makes origin mandatory "where failure to indicate this might mislead the consumer as to the true country of origin". If a label gives an origin and the primary ingredient comes from elsewhere, Article 26(3) requires that ingredient's origin or a statement that it differs, under Implementing Regulation (EU) 2018/775.
Regulation 2018/775 lets you give the primary ingredient's origin as "‘EU’, ‘non-EU’ or ‘EU and non-EU’", or name the Member States or third countries (Article 2). The information must be in a font size "not smaller than the minimum font size" and in the same field of vision as the origin indication (Article 3). Article 4 says it "shall apply from 1 April 2020". Article 26(2)(b) of Regulation 1169/2011 adds the meats listed in its Annex XI.
Article 1(2) of Regulation 2018/775 leaves out "registered trade marks where the latter constitute an origin indication" until further rules are adopted, which matters if your brand name sounds like a place. Whether a "Made in EU" line fits your product is a separate question, covered in the guide to "Made in EU" on private label products.
Does the manufacturer need to be registered or approved?
Every food manufacturer is registered; one making meat or fishery products also needs approval. Regulation (EC) No 852/2004, Article 6(2) says "every food business operator shall notify the appropriate competent authority" of each establishment under its control. Under Regulation (EC) No 853/2004, Article 4(2), the establishments it covers "shall not operate unless the competent authority has approved them".
Why meat and fish: Article 4(2) covers "those products of animal origin for which Annex III to this Regulation lays down requirements". Annex III, as adopted, has sections on meat products (Section VI) and fishery products (Section VIII), next to other meats, live bivalve molluscs, and raw milk and dairy products. Approval comes after at least one on-site visit by the authority (Regulation 852/2004, Article 6(3)).
So ask a meat or fish co-packer for proof of its approval, not only of a registration. Your own business may need registering too: Sweden's Livsmedelsverket, for example, asks a new business selling food supplements to register with the municipality at least two weeks before it starts (Livsmedelsverket).
What does your situation decide for you?
Two facts decide most of it: whose name is on the pack, and what the food is made of. Your name on the pack makes your company the responsible operator, unless the company is outside the EU, when the importer takes that role. Meat products and fishery products need an approved establishment, not only a registered one.
| Your situation | Who answers for the label | What else it decides |
|---|---|---|
| Your brand on the pack, your company in the EU | Your company (Article 8(1)) | Your company's name and address go on the label as the operator |
| Your brand on the pack, your company outside the EU | The importer into the Union market (Article 8(1)) | The importer's name and address go on the label as the operator |
| A retailer sells the food under its own brand | The retailer, as the operator under whose name the food is marketed | The retailer's name and address go on the label |
| You resell the manufacturer's own brand | The manufacturer, under whose name the food is marketed | You must not change the information in a way that misleads (Article 8(4)) |
| The food is a meat product or a fishery product | As in the rows above | The manufacturer's establishment needs approval (Regulation 853/2004, Article 4(2) and Annex III) |
| The pack names a country, but the main ingredient comes from elsewhere | As in the rows above | Give the primary ingredient's origin or say that it differs (Article 26(3), Regulation 2018/775) |
| The largest surface of the pack is under 80 cm² | As in the rows above | Minimum x-height of 0.9 mm instead of 1.2 mm (Article 13(3)) |
Where do I find food manufacturers that make products for other brands?
NordSourced lists 130 food and beverage manufacturers in the five countries whose own websites say they make products for other brands; the ranked list is the food and beverage list. If your product is a meat product or a fishery product, ask the manufacturer for proof of its approval under Regulation (EC) No 853/2004, not only of its registration.
By region: food and beverage manufacturers in the Baltics and food and beverage manufacturers in the Nordics.
| Manufacturer | Country | Product groups | In its own words |
|---|---|---|---|
| JP Foods | Estonia | Food & beverages | “Your brand, your logo and pack sizes to your request, produced on the same certified line with documentation from day one.” source |
| Valio | Finland | Food & beverages | “From concept to launch, our dedicated OEM team ensures smooth collaboration, compliant documentation, and reliable delivery every step of the way.” source |
Documentation from the manufacturer is not the label itself: the operator under whose name the food is marketed still answers for the label (Article 8(1)). Ask what the documentation covers and how a change to the recipe reaches your ingredient and allergen list.
Questions and answers
Does a private label food need to be registered before it goes on sale?
The establishment does. Regulation (EC) No 852/2004, Article 6(2), requires every food business operator to notify the competent authority of each establishment under its control, for registration. A manufacturer handling products of animal origin covered by Annex III of Regulation (EC) No 853/2004 also needs approval. Food supplements add a national notification in several countries.
If a supermarket sells my food under its own brand, who is responsible for the label?
The supermarket. Article 8(1) of Regulation (EU) No 1169/2011 makes the operator under whose name or business name the food is marketed responsible for the food information. When the food is sold under the retailer's brand, the retailer must ensure the information is present and accurate (Article 8(2)), even though you or a co-packer made the food.
Is a nutrition declaration mandatory on a private label food?
Yes, as a rule. Article 9(1)(l) of Regulation (EU) No 1169/2011 lists a nutrition declaration among the mandatory particulars, and Article 55 made point (l) apply from 13 December 2016, two years after the rest of the Regulation. Both dates have passed, so a new product needs one unless the Regulation exempts that food; read the exemptions on EUR-Lex.
What may a private label food label claim?
Health claims only if authorised: Regulation (EC) No 1924/2006, Article 10(1), prohibits health claims unless they meet the general requirements and are on the lists of authorised claims. Origin must not mislead either; Article 26(2)(a) of Regulation (EU) No 1169/2011 makes the country of origin mandatory where leaving it out might mislead consumers about the true country of origin.
Can I use an English-only label for food sold in the Baltics and the Nordics?
Only if each country's rule allows it. Article 15(1) of Regulation (EU) No 1169/2011 requires mandatory food information in a language easily understood by consumers where the food is sold, and Article 15(2) lets each Member State require one or more languages in its territory. Check each country's rule before you print, since the label is your brand's responsibility.
Which EU food labelling dates apply to a product launched now?
All of them have passed. Regulation (EU) No 1169/2011 applies from 13 December 2014 and its nutrition declaration from 13 December 2016 (Article 55). The primary ingredient origin rules of Implementing Regulation (EU) 2018/775 apply from 1 April 2020. A product launched in 2026 must therefore meet each of these rules that applies to it from its first batch.
Will the manufacturer write the food label for me?
It can help, but the duty stays with the operator under whose name the food is marketed (Article 8(1) of Regulation (EU) No 1169/2011), which must ensure the information is present and accurate. 2 of the 130 food manufacturers NordSourced lists say on their own website that documentation comes with your product.
What is the minimum font size on a small food package?
An x-height of 0.9 mm when the largest surface of the package is under 80 cm², under Article 13(3) of Regulation (EU) No 1169/2011. On larger packs, mandatory particulars need an x-height equal to or greater than 1.2 mm (Article 13(2)). The x-height is defined in Annex IV, and the text must also be easily visible and clearly legible.
Does my food label have to say where the main ingredient comes from?
Only when the label gives an origin for the food and the primary ingredient comes from somewhere else. Then Article 26(3) of Regulation (EU) No 1169/2011 and Implementing Regulation (EU) 2018/775 require the primary ingredient's origin, as EU, non-EU, EU and non-EU, or named countries, or a statement that it differs. The rule applies from 1 April 2020.
Can my brand name suggest a country of origin?
Implementing Regulation (EU) 2018/775 leaves out registered trade marks that constitute an origin indication until further rules are adopted (Article 1(2)), so its primary ingredient rules do not yet apply to such a trade mark. Article 26(2)(a) of Regulation (EU) No 1169/2011 still makes the origin mandatory where its absence could mislead consumers about the true country of origin.
Where do I find a private label manufacturer for a meat or fish product in the Baltics and the Nordics?
Start from the food and beverage list, which covers the 130 food and beverage manufacturers NordSourced lists in the five countries, each listed because its own website says it makes for other brands. Under Regulation (EC) No 853/2004, Article 4(2), establishments handling products in its Annex III, which covers meat products and fishery products, need approval by the competent authority, so ask each one for proof of it.
How many private label food manufacturers are there in the Baltics and the Nordics?
NordSourced lists 130 food and beverage manufacturers in the five countries whose own websites say they make products for other brands: Latvia 25, Lithuania 23, Estonia 11, Finland 45, Sweden 26. A company counts only if its website says it makes for other brands, so the real number of producers is higher. The ranked lists start from the food and beverage list.
Where to go next
Sources
- Regulation (EU) No 1169/2011 on food information to consumers, Articles 8, 9, 13, 15, 26 and 55 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Implementing Regulation (EU) 2018/775 on the origin of the primary ingredient, Articles 1 to 4 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Regulation (EC) No 852/2004 on the hygiene of foodstuffs, Article 6 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Regulation (EC) No 853/2004 on hygiene rules for food of animal origin, Article 4 and the section headings of Annex III (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Regulation (EC) No 1924/2006 on nutrition and health claims, Article 10 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Om vi vill sälja kosttillskott, vad ska vi tänka på?, Livsmedelsverket (Swedish Food Agency). Checked 13 Oct 2026.
Directory figures are counted from the manufacturers listed on NordSourced, each listed because its own website says it makes products for other brands; see how we check. This page is general information, not legal advice. Found a mistake? Tell us.