UK food labelling after Brexit — UK FIC requirements and new standards

What is UK FIC and how does it differ from EU FIC?

UK FIC (Food Information to Consumers Regulations 2014, SI 2014/1855) is the primary legislation governing food labelling in the United Kingdom after Brexit. Before Brexit, the UK applied EU Regulation (EU) No 1169/2011 — from 1 January 2021, a separate UK act applies, retained as domestic law with modifications introduced by the UK Government.

Key differences between UK FIC and EU FIC:

• Operator address: UK FIC requires the name and address of a UK Food Business Operator (FBO) to appear on the label. The address of an EU producer or EU distributor is not sufficient. An importer or distributor based in England, Scotland or Wales must be shown as the FBO.
• Territorial scope: UK FIC applies in England, Scotland and Wales (GB). Northern Ireland follows separate rules arising from the Windsor Framework — products sold in NI may carry either an EU or a UK address, depending on the target market.
• Language: English is required (in Wales, Welsh is also required for products intended for the Welsh market). EU rules permit any official EU language of the country of sale — UK FIC requires English as the primary language.
• Fortifying substances and vitamins: Reference Intake (RI) values for nutrition labelling are preserved from EU law but form part of UK law, not EU law.
• Substantive label content (ingredients list, allergens, dates, nutritional value) is largely the same as under EU FIC, because UK FIC derives from retained EU law — however, the UK Government may diverge in future.

Source: gov.uk/guidance/food-labelling-changes-after-brexit.

Scope of UK FIC — when the rules apply

UK FIC applies to pre-packed food sold to consumers or to catering establishments in England, Scotland and Wales. It also applies to food imported from the EU and from third countries — including Poland. Polish food products placed on the UK market must comply with UK FIC on the packaging or on a sticker applied by the importer. Note that importing organic food from the UK is subject to additional certification requirements separate from FIC.

Mandatory information on UK food labels — checklist

UK FIC sets out an exhaustive list of mandatory information on the label of pre-packed food sold in the UK. The absence of any element constitutes a breach of the regulations and may result in the goods being detained at the border or withdrawn from the market by the FSA (Food Standards Agency). The list below contains all required elements in accordance with gov.uk:

• Name of the food — the legal or customary name of the product in English; it may not be replaced solely by a trade mark or logo.
• Ingredients list — in descending order by weight, in English; must include the names of all ingredients, including compound ingredients above 2%.
• Allergens — 14 major allergens must be emphasised (e.g. in bold) in the ingredients list; see the section below for details.
• Net quantity — the mass or volume of the product; in metric units (g, kg, ml, l).
• Date marking:
  • Use by — for highly perishable products that pose a health risk after the date; selling the product after this date is unlawful.
  • Best before — for products with a longer shelf life; the product may be sold after this date but may have lost quality.
• Storage conditions and/or conditions of use — required where the durability date depends on proper storage conditions (e.g. "keep refrigerated").
• Name and address of the UK Food Business Operator (FBO) — the importer or distributor with an address in the UK (England, Scotland or Wales); an EU address is not sufficient for the GB market.
• Country or place of origin — mandatory for selected categories (see section below); for other categories voluntary, but must be accurate.
• Instructions for use — required where the absence of such instructions would make it difficult to make appropriate use of the product.
• Lot mark — the production batch number, required for traceability; often marked as "L" + number or as the production date.
• Alcohol content — mandatory for beverages containing more than 1.2% vol; expressed as a percentage by volume.
• Nutrition declaration — mandatory for most pre-packed products; includes energy value (kJ/kcal), fat, saturates, carbohydrate, sugars, protein, salt.

Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

Minimum font size and legibility

UK FIC requires mandatory information to be printed in a minimum font with an x-height of at least 1.2 mm (for packages where the largest surface area exceeds 80 cm²) or 0.9 mm (for smaller packages). The information must be clear, legible and indelible. The legibility requirements mean in practice that stickers applied by the importer must be permanently fixed and must not obscure original producer information required by other legislation.

Allergens — Natasha's Law and PPDS labelling

Allergen labelling is one of the most important requirements under UK FIC. Incorrect or missing allergen information can directly endanger consumers' lives and constitutes a serious breach of the regulations, enforced by the FSA and local food safety authorities (Trading Standards).

14 allergens mandatory under UK FIC

Under UK FIC (Schedule 1 to SI 2014/1855) the following allergenic substances and products thereof must be emphasised on the label or in the ingredients information:

1. Cereals containing gluten — wheat (including spelt and khorasan wheat), rye, barley, oats and their hybridised strains and products thereof
2. Crustaceans and products thereof
3. Eggs and products thereof
4. Fish and products thereof
5. Peanuts and products thereof
6. Soybeans and products thereof
7. Milk and products thereof (including lactose)
8. Nuts — almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts and products thereof
9. Celery and products thereof
10. Mustard and products thereof
11. Sesame seeds and products thereof
12. Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/l (expressed as SO₂)
13. Lupin and products thereof
14. Molluscs and products thereof

Each of these allergens must be typographically emphasised (e.g. in bold, italics or underlined) in the ingredients list so that it is clearly visible against the surrounding text. Source: gov.uk/food-labelling-and-packaging/overview.

Natasha's Law — PPDS food

Natasha's Law (Food Information (Amendment) (England) Regulations 2019) came into force on 1 October 2021 and applies to PPDS food — Pre-Packed for Direct Sale, that is, products packed at the point of sale and sold directly to the consumer at the same premises (e.g. sandwiches prepared in a bakery, salads packed in a restaurant for takeaway, cakes packed by a patisserie).

Before Natasha's Law came into force, PPDS products were exempt from full labelling requirements — only the product name was needed. From 1 October 2021 PPDS products must carry:

• The full name of the food
• A full ingredients list with the 14 allergens emphasised

Natasha's Law is directly linked to the tragedy of Natasha Ednan-Laperouse, who died in 2016 from anaphylactic shock after consuming a sandwich whose packaging carried no allergen information. The legislation primarily affects UK producers and retailers, but Polish importers supplying factory pre-packed food (classic pre-packed) are subject to the standard UK FIC requirements, not Natasha's Law. However, if a product is repacked in the UK for PPDS sale, the relevant UK business must comply with Natasha's Law. Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

Allergens outside the ingredients list — additional rules

UK FIC permits alternative methods of allergen communication for food sold loose or unwrapped, but for imported pre-packed food the only permitted method is typographical emphasis within the ingredients list. "May contain" declarations are voluntary and relate to the risk of unintentional cross-contamination — they do not replace the mandatory allergen labelling for intentionally added ingredients.

Country of origin — when it is mandatory

Indicating the country or place of origin of food is mandatory under UK FIC for the following product categories:

• Beef and veal — country of birth, rearing and slaughter (Beef (Labelling) Regulations)
• Lamb and mutton — country of birth, rearing and slaughter
• Pork, poultry and goat meat — country of rearing and slaughter (extended UK rules from 2024)
• Fish and seafood — fishing zone, production method (wild/farmed) and species; for processed fish products — country of production if different from country of capture
• Honey — country or countries of origin; if a blend of honeys from different countries, all must be listed or the label must read "blend of honeys from EU and non-EU countries"
• Olive oil — country of origin of the olives; if a blend — "blend of olive oils from EU countries"
• Fresh fruit and vegetables — for selected categories covered by marketing standards (e.g. apples, pears, tomatoes, lettuce) country of origin is mandatory
• Wine — country or region of production required under wine regulations

For all other products, indicating country of origin is voluntary. However, if an importer chooses to provide country of origin information voluntarily, it must be accurate and must not mislead the consumer. Detailed guidance is available at: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

Country of origin and the description "Made in Poland"

Polish producers exporting to the UK may voluntarily display "Made in Poland" or "Country of origin: Poland" on products for which there is no obligation to state origin. However, if a product contains a primary ingredient from a different country than the country of production, UK FIC requires the country of origin of that ingredient to be indicated, or information that it differs from the country of production — e.g. "Produced in Poland from Ukrainian wheat". This requirement has applied since March 2020 at EU level and is preserved in UK FIC.

Border controls should also be borne in mind — animal products and high-risk products of plant origin are subject to checks under the BTOM system. Further information: BTOM border controls for food. For plant products requiring phytosanitary certificates, registration in IPAFFS for plant products is also required.

Language on labels — English is mandatory

One of the fundamental requirements of UK FIC is that all mandatory information must be provided in English. The rules do not permit another language — including Polish — to replace English for legally required information.

English as the primary language — practical implications

For Polish food exporters to the UK this means:

1. Translating the label into English before the product is placed on the UK market (or having the UK importer apply a sticker)
2. Ensuring the product name, ingredients list, allergens and all other mandatory elements are correctly translated — a transliteration or a near-equivalent description is not sufficient
3. Using English allergen names consistent with the terminology in UK FIC Schedule 1
4. Applying English date markings: "Use by" (not "spożyć do" or "Mindesthaltbarkeitsdatum") and "Best before" (not "Najlepiej spożyć przed")

Additional Welsh language requirement in Wales

Products intended for sale in Wales must carry mandatory information in both English and Welsh — in accordance with the Welsh Language Act and specific rules for the Welsh market. This applies to products that will be sold in shops located in Wales. For Polish exporters selling through national distributors or exclusively to England/Scotland, this requirement will generally not apply — but it is worth confirming the distribution scope with your commercial partner.

Translation by the UK importer — sticker on the packaging

A commonly used and accepted method is for the UK importer to apply an English-language sticker to the original Polish packaging — before the product is placed on the UK market. The sticker must contain all mandatory UK FIC information and must be permanently affixed so that it cannot be accidentally removed. The UK importer thereby assumes the role of UK Food Business Operator (FBO) and bears responsibility for label compliance with UK FIC. The sticker must be legible and meet the minimum font size requirements.

Language and customs clearance for food imports to the UK

Language non-compliance on a label is one of the most common causes of problems during customs clearance and FSA inspection. A customs agent can help identify documentation gaps before shipment and ensure the goods meet the formal requirements at the UK border.

Practical steps for Polish food exporters to the UK

Implementing UK FIC requirements for products exported from Poland to the UK requires a systematic approach. Below is a step-by-step action plan for every Polish producer or food exporter planning or already carrying out sales to the UK.

Step 1 — Designate a UK Food Business Operator (FBO)

UK FIC requires the label to show the UK entity responsible for the product — the UK FBO. For a Polish producer this means:

• Appointing a UK importer or distributor to assume the FBO role, or
• Registering your own entity (sp. z o.o., Ltd) in the UK and listing its address on the label

A Polish company cannot be the UK FBO unless it has a UK address. Using a UK importer is the most common solution for exporters without their own UK structure.

Step 2 — Label audit against UK FIC

Every product exported to the UK requires a label check covering:

• Presence of all 11+ mandatory UK FIC elements
• Correct emphasis of 14 allergens in the ingredients list
• English language for all mandatory information
• UK FBO address
• Correct date marking (Use by vs Best before)
• Nutrition declaration in UK FIC format
• Correct indication of country of origin (where mandatory)

Step 3 — Check additional sector-specific requirements

In addition to the general UK FIC requirements, certain product categories are subject to additional rules:

• Meat and dairy products — hygiene and health requirements, health certificates, establishment number approved by APHA/VMD
• Organic products — UK Organic certification (the GB Organics logo has replaced the EU Organic logo) — see the section on organic food imports
• Food supplements — Food Supplements (England) Regulations 2003
• Alcoholic beverages — specific rules on alcoholic drinks labelling
• Confectionery and sweetened drinks — HFSS regulations (see section below)

Step 4 — Print English-language stickers

If the original packaging does not comply with UK FIC (e.g. it is in Polish), the UK importer should, before placing the goods on the market:

• Prepare an English-language sticker containing all mandatory information
• Permanently affix the sticker to the original packaging (without covering legally required information)
• Retain documentation confirming that the sticker complies with UK FIC

Step 5 — Customs and sanitary documentation

Importing food to the UK also requires appropriate documents for customs clearance, including health certificates for animal products, phytosanitary certificates for high-risk products of plant origin, and notifications through the IPAFFS system. Details: IPAFFS for plant products and BTOM border controls for food.

HFSS — regulations on high-fat, sugar and salt products

Since October 2022, the UK has had HFSS (High in Fat, Sugar and Salt) rules in place for food products with a high content of fat, sugar or salt. These rules do not directly concern the content of the label, but they affect how such products may be promoted and displayed in the UK.

What the HFSS rules are and what they cover

The HFSS rules (implemented by The Food (Promotion and Placement) (England) Regulations 2021) restrict:

• Placing HFSS products in so-called "promotional locations" — at checkouts, at the beginning of store aisles, and at end-of-aisle displays
• Price promotions (multibuy offers, e.g. "buy 2 for the price of 1") and volume promotions (e.g. a free larger pack) for HFSS products
• Television and digital advertising of HFSS products directed at children (Ofcom rules)

Classifying a product as HFSS

A product is classified as HFSS using the Nutrient Profiling Model (NPM) developed by the FSA/Ofcom. The model assigns penalty points for energy, sugars, saturated fat and sodium content, and bonus points for fruit, vegetable, nut, fibre and protein content. A product scoring 4+ points (for food) or 1+ point (for drinks) is classified as HFSS. The NPM is calculated per 100 g or 100 ml of product based on the nutrition declaration on the label.

HFSS and food imports from Poland

For Polish producers exporting to the UK, this means that products meeting the HFSS criteria may have restricted marketing and display opportunities in the UK. When designing a recipe or planning a UK market entry strategy, it is worth checking with your UK distributor whether the product will be classified as HFSS and what commercial implications that has. It should also be noted that sweetened drinks are subject to the Soft Drinks Industry Levy — a tax on sweetened beverages that must be factored into import cost calculations. Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

HFSS exemptions

Not all shops are subject to the HFSS rules. Small stores (with a floor area below 185.8 m², i.e. 2,000 sq ft) are exempt from the product placement requirements. Online shops and business-to-business (B2B) sales are subject to different rules in certain respects. Detailed guidance at: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

Summary of current official rules

UK FIC (Food Information to Consumers Regulations 2014, SI 2014/1855) governs pre-packed food labelling in England, Scotland and Wales. Key requirements for Polish food exporters to the UK: (1) all mandatory information in English, (2) address of a UK Food Business Operator (FBO) — an EU address is not sufficient, (3) 14 allergens typographically emphasised in the ingredients list, (4) correct date marking (use by vs best before), (5) country of origin for meat, fish, honey, olive oil and selected fruit/vegetables. Natasha's Law (from 1 October 2021) applies to PPDS — products packed at the point of sale. HFSS rules from 2022 restrict the promotion and placement of high-fat/sugar/salt products. Northern Ireland (NI) follows separate rules arising from the Windsor Framework. This article reflects the legal position as at 2026-06-06. Please contact a customs agent before taking action.

FAQ — frequently asked questions

Are food labels in Polish permitted in the UK?

No. Under UK FIC (Food Information to Consumers Regulations 2014 SI 2014/1855) all mandatory label information must be provided in English. A Polish translation may be added voluntarily as supplementary information, but it does not replace the English text. In Wales, Welsh is additionally required on products intended for the Welsh market. Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

How does UK FIC differ from EU FIC after Brexit?

The key difference: UK FIC requires the address of a UK Food Business Operator (FBO) on the label — an EU address is not sufficient. The UK importer becomes the FBO responsible for label compliance. The substantive label content (ingredients list, allergens, dates) is largely preserved from EU law as retained law, but it applies as UK law, not EU law. The rules may be modified by the UK Government independently of changes in EU law. Source: gov.uk/guidance/food-labelling-changes-after-brexit.

Which allergens must be highlighted on the label?

UK FIC requires 14 major allergens to be emphasised on the label or in the ingredients information: gluten-containing cereals (wheat, rye, barley, oats), crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts), celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin, molluscs. They must be typographically emphasised, e.g. in bold. Source: gov.uk/food-labelling-and-packaging/overview.

When is country of origin mandatory on UK food labels?

Country of origin is mandatory for: beef and veal, lamb and mutton, pork, poultry, fish and seafood (certain categories), honey, olive oil, fresh fruit and vegetables (certain categories), wine. For other products, indicating the country is voluntary, but if the information is given it must be accurate and must not mislead. If the primary ingredient comes from a different country than the country of production, this must be indicated. Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

What is Natasha's Law and does it affect importers?

Natasha's Law (Food Information (Amendment) (England) Regulations 2019) came into force on 1 October 2021. It applies to PPDS (Pre-Packed for Direct Sale) food — products packed at the point of sale and sold directly to the consumer (e.g. sandwiches, salads, cakes packed on site). Such products must carry the full food name and a full ingredients list with allergens emphasised. Importers of factory pre-packed food are not directly covered by Natasha's Law but must comply with the standard UK FIC requirements for pre-packed food. Source: gov.uk/guidance/food-labelling-giving-food-information-to-consumers.

Official sources

• Food labelling and packaging — GOV.UK — GOV.UK
• Food labelling changes after Brexit — GOV.UK — GOV.UK
• Food labelling and packaging: overview — GOV.UK — GOV.UK