Sandwich Labelling Regulations

sandwich labelling regulations changes 2016
Sandwich Labelling Regulations is a pretty tedious topic so if you want to cut straight to the chase, feel free to call us on 01332 864895 during office hours for advice and help setting up a sandwich labelling system. Alternatively, fill in the form at the bottom of this article and we will call you back.

Sandwich Labelling Regulations are set out in the EU Food Information for Consumer Regulations (EU FIC). The governing document is the EU 1169/2011 regulation and can be found online or by clicking the link at the end of this article. The document is quite a heavy read, consequently, this article is intended to help food businesses understand their obligations under the EU FIC rules in a simpler way. This guidance is in no way definitive and you should verify your labels with your local Trading Standards Department.

The new regulations add or clarify existing regulations and replace a number of older regulations (see image).

How are Sandwich Labelling Regulations enforced?

The EU hands down regulations to EU member states. The enforcement of EU regulations is decided by the national government of the EU member state. In the case of the UK, the government has handed that role to Council Trading Standards Departments. These are normally run by the County, City or Metropolitan Council in your area. Trading Standards is not normally a function of the District Council. In other European states, this monitoring and enforcement may be different from the UK but the regulations are the same for the entire EU.

In our experience, as Trading Standards Departments are independent, County to County, the interpretation of regulations can vary from Council to Council which can be very frustrating. We have seen sandwich labelling regulations enforced differently between customers living within different enforcement areas and that is why you should verify your labelling with your local Trading Standards Department.

Sandwich Labelling Regulations Scope

The sandwich labelling regulations in force today became legally binding on December 13, 2016. There was an interim change from December 13, 2014, which was specific to text sizes and allergen labelling. Before that, EU regulations were not in force and the UK Government had its own set of labelling rules.

The regulations define what food must be labelled and what information must be placed on the label depending upon the category of food business involved, effective from December 13, 2016.

For the purpose of the regulations, a food business falls into one of three categories:

Category 1 Sandwiches made for consumption solely on site or to order, at or from the catering establishment they are made (e.g. Subway, Cafes, Restaurants).
Category 2 Sandwiches pre-packed and made for direct sale on site or from a distribution truck or from a stall operated by that company.
Category 3 Sandwiches made at a central kitchen and distributed to a number of retail outlets.

Category Requirements and Responsibility

All categories are required to declare if any part of their product is irradiated either by labelling or using appropriate signage stating that nature.

Category 1 Food Businesses

Sandwiches or any product made at these establishments does not need any labelling to be sold to the pulic.

Category 2 Food Businesses

Sandwiches or any product for sale to the public need to include
a) An accurate description of the product
b) A declaration of any food additives are in the food such as Antioxidants, Flavourings, Sweeteners

Category 3 Food Businesses

Sandwiches pre-packed and for sale directly to the public at shops or petrol stations need to be labelled in full with the following:
a) Accurate description of the product
b) Quantitative ingredient listing
c) Allergen listing included in the ingredient listing
d) Use by, best before or best before end date (dependent upon the type of product)
e) Storage instructions (if necessary)
f) Preparation instructions (if necessary)
g) Nutrition declaration
h) Country of origin/manufacture if not clear from the manufacturer declaration
i) Identification of the manufacturer (Food Business)

The main areas that changed in 2014 were:

  • Text size
  • Allergens
  • Allergen indication

Text Sizes

For ‘standard sized’ packaging, text sizes were specified for the first time to ensure legibility. The size was set at a minimum on 1.2mm high for the lower case “x”. The theory being a standard font will reflect a normal size from the size of that letter.

Smaller packaging can have smaller text at 0.9mm but sandwich labelling packaging is invariably larger than the threshold for smaller packaging. Packaging under 25cm2 is not subjet to any regulation.

Allergens in Sandwich Labelling Regulations

The new sandwich labelling regulations require allergens to be highlighted; sandwich labelling has the specific allergens in common with all food labelling which are:

  • Cereals containing gluten (or their hybridised strains)
    • Wheat (such as spelt, Khorasan wheat/Kamut)
    • Rye
    • Barley
    • Oats
  • Eggs
  • Milk
  • Fish
  • Crustaceans (for example crab, lobster, crayfish, shrimp, prawn)
  • Peanuts
  • Nuts – specifically tree nuts:
    • Almonds
    • Hazelnuts
    • Walnuts
    • Cashews
    • Pecans
    • Brazil nuts
    • Pistachios
    • Macadamia nuts or Queensland nuts
  • Sesame seeds
  • Soya
  • Celery and celeriac
  • Mustard
  • Lupin
  • Molluscs (for example mussels, oysters, squid)
  • Sulphur dioxide and sulphites (at concentration of more than ten parts per million)

No other allergens are required. For example, yeast and coconut are often indicated on packaging but these are not allergens as designated in the regulations.

How to indicate Allergens

In the new sandwich labelling regulations, allergens must now be indicated in the ingredient list (a required piece of information in its own right). The ingredient list must be made in quantitative order with the quantity of each ingredient indicated as a percentage. The allergens must be highlighted in some form but the legislation does not dictate how this must be done.

Generally speaking, the allergens can be listed with bold, capital or underlined text. You may also use a different colour or a different font to highlight or a combination of several of these elements to make the item stand out. You should also explain what the highlighted information indicates with a comment such as:

for allergen information see ingredients in UPPERCASE


for allergens, see ingredients listed in bold

being sure to use the indicative style in the phrase.

Positive ID Labelling has developed software specifically to help with these changes. Nutridata was launched in 2016 and can automatically list your ingredients in complete Quantitative Order (so called QUID listing).

Illegal Allergen Listings

Over the years, it has become common to see a phrase such as “May contain nuts” on the packaging. This is incredibly unhelpful if you have a nut allergy as realistically it would prevent you eating a product that doesn’t contain nuts on the whim of the manufacturer.

Getting allergy information right is important so that people who suffer allergies can protect themselves but also so that allergy sufferers can consume pre-packed food that really does not contain allergens.

It is possible to provide advisory information on your labels but phrases such as these should be avoided as they serve no beneficial purpose for either the consumer or the proprietor. The insurance industry has made us all risk averse and is more than likely the source of this change.

The advisory information you might include that is useful would be something like “made in a kitchen that processes foods with nuts” or “processed in a kitchen that handled gluten based products”. Hygiene standards should mean that cross-contamination is kept to a minimum but it is appropriate to advise consumers if consuming a product puts them at risk.

Sandwich Labelling Regulations Changes from December 13, 2016

The main change in sandwich labelling regulations from this date is the implementation of nutrition information on the product. This must be included on qualifying products on the back of the pack as a minimum. Adding nutrition data to the front of a pack is an option and not required by law. However, both back of pack and front of pack labelling have very strict rules regarding what can be declared and how.

Nutrition data must be declared per 100g or 100ml of product. I can optionally be declared by portion or serving sizes but this cannot replace the per 100g/ml listing.

What must be declared and the order in which it must be declared along with a generic statement about daily average intake is set out in the regulations:

  1. Items listed in bold are mandatory
  2. Items listed in itallic are optional
  3. Optional items are listed at your discretion and you may include any or all of the optional items.
  4. Note: The sequence of the declaration whether a mandatory nutrient or optional nutrient is mandatory

Mandatory Nutrition Declaration

Nutrition Information per 100g

  • Energy (kJ)
  • Energy (kcal)
  • Fat (g)
  • Saturated Fats (g)
  • Mono-unsaturated Fats (g)
  • Poly-unsaturated Fats (g)
  • Carbohydrate (g)
  • Sugars (g)
  • Polyols (g)
  • Starch (g)
  • Protein (g)
  • Fibre (g)
  • Salt (g)
  • Vitamins & Minerals (g)/(mg)/(μg)

Reference Intake for an average adult (8400kJ/2000kcal)

All items have the units indicated as kiloJoules (kJ), calories (kcal) or grams (g). The regulations do not specify the level of accuracy required for the data but having studied examples in use, we would suggest:

  • Energy declared to the nearest kJ or kcal>/li>
  • To the nearest 1g for 10g or more per 100g
  • To the nearest 0.1g gram for 0.1g to 9.9g per 100g

Layout: Where space permits, information should be conveyed in a table, but if space on the label makes this difficult, it is legal to convey the nutrition information in a paragraph format.

Guideline Daily Amounts (GDAs)

The EU has specified guideline daily amounts (GDAs) for certain nutrients. The guideline amounts are as follows:

  • Energy: 8,400kJ or 200kcal
  • Total Fat: 70g
  • Saturated Fat: 20g
  • Carbohydrate: 260g
  • Total Sugars: 90g
  • Protein: 50g
  • Salt: 6g

You can use the guideline daily amounts alongside any portion or serving size based declaration but those declarations are additional to the mandatory 100g/100ml declaration. You will often find the %GDA on “Front of Pack” labelling sometimes called Traffic Light Labelling.

Front of Pack Sandwich Labelling Regulations

Front of Pack Labelling is optional but where you choose to exercise the option, the way you declare information is defined in the regulations.

You may only declare the Energy (in kiloJoules and kilocalories) in the serving size or you may declare

  • Energy (kJ/kcal)
  • Fat (g) and optionally %GDA
  • Saturated Fat (g) and optionally %GDA
  • Sugar (g) and optionally %GDA
  • Salt (g) and optionally %GDA

Importantly, if you declare %GDA for one, you must declare for all.

The front of pack area must include a description of how much of the food gives this much nutrition. E.g. if it is a 200g sandwich, the declaration should state: “A 200g portion provides the following” or “This 200g pack contains”.

The information should also include the mandatory statement: Reference Intake for an average adult (8400kJ/2000kcal)

Labelling your Sandwiches

So, you now have a grasp of what is required but how do you deliver that? Most food businesses subject to the sandwich labelling regulations will need to produce their labels using a computer and specialist printer. We supply off-the-shelf labelling equipment with bespoke labels for thousands of food businesses that allow them to meet the regulations. The video below shows how this can be achieved with a label printer, labelling software and a spreadsheet. For nutrition data, you can make use of our Nutridata nutrition calculation software, available under a number of license and lease options.

Contact us here:

Source: EU FIC Regulations

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