EU Food Labelling Requirements for Private Label Cookies (2025)

If you are launching a private label cookie, protein bar, or energy ball in the EU, labelling is not optional. EU Regulation 1169/2011 on the provision of food information to consumers, known as the FIC, sets out the mandatory information that must appear on every pack sold in the European market. Getting this right before production saves real time and cost later.

Below is what has to be on the label, how it must be presented, and where the line falls between what your contract manufacturer provides and what you, as the brand owner, are responsible for arranging.

Note. This guide covers EU requirements under Regulation 1169/2011. Individual member states may add their own requirements. Verify with a local regulatory consultant before your first market launch.

1. Mandatory Label Elements

Regulation 1169/2011 defines a list of mandatory particulars for pre-packaged food. For cookies and bakery snacks, all of the following apply.

Element	Requirement	Status
Name of the food	Legal or customary name describing the product	Required
Ingredients list	Descending order by weight at time of manufacture	Required
Allergens	Highlighted within the ingredients list (bold, underline, or caps)	Required
Net quantity	In grams or kilograms for solid products	Required
Best before / use by date	”Best before” for stable products; “Use by” for perishables	Required
Storage conditions	Required if the date depends on specific storage	Required
Name and address of FBO	Food business operator responsible for placing on the market	Required
Country of origin	Required for cookies if omission would mislead consumers	Conditional
Instructions for use	Only if the product could not be used correctly without them	Conditional
Alcohol content	Required if the product contains more than 1.2% alcohol by volume	Conditional
Nutrition declaration	Per 100g, and optionally per serving	Required
Lot mark	Traceability code (Directive 2011/91/EU)	Required

2. The 14 Mandatory Allergens

Annex II of Regulation 1169/2011 lists 14 substances that cause allergies or intolerances and must always be declared. Several of these are almost always present in cookie and snack products.

• Cereals containing gluten
• Crustaceans
• Eggs
• Fish
• Peanuts
• Soybeans
• Milk (including lactose)
• Nuts (tree nuts)
• Celery
• Mustard
• Sesame seeds
• Sulphur dioxide and sulphites
• Lupin
• Molluscs

Allergens must be emphasised within the ingredients list using a typographic distinction such as bold, italics, or capitalisation. A separate “Contains:” statement does not replace highlighting inside the list, though many brands include both.

May Contain Declarations

“May contain” and “produced in a facility that also handles…” statements are voluntary. They are not regulated by 1169/2011. They reflect a cross-contamination risk assessment specific to the manufacturing facility, so your manufacturer should provide documented HACCP records and production schedules to inform the decision. Do not add precautionary allergen labelling without a factual basis. It erodes trust for the people who rely on it most.

3. Nutrition Declaration

Since December 2016, a full nutrition declaration has been mandatory on all pre-packaged food. For cookies, the mandatory block per 100g is as follows.

Nutrient	Unit	Notes
Energy	kJ and kcal	Both must be declared
Fat	g
of which saturates	g	Mandatory sub-declaration
Carbohydrate	g
of which sugars	g	Mandatory sub-declaration
Fibre	g	Voluntary but strongly recommended
Protein	g	Critical for protein cookies
Salt	g	Salt, not sodium

Voluntary declarations such as polyols, starch, vitamins, and minerals may follow the mandatory block. For protein cookies, protein content per serving is often flagged on the front of pack as a marketing claim, but that claim must comply with EU Regulation 1924/2006 on nutrition and health claims.

Per Serving Declarations

You may also declare nutrition per serving, provided the serving size is stated in grams and the number of servings per pack is indicated. For individually wrapped cookies, declaring per unit is common practice and makes consumer-facing claims easier to substantiate.

4. QUID: Quantitative Ingredient Declarations

QUID is required when a characterising ingredient is named in the product name or shown in imagery. For private label cookies, it most often applies to:

• Chocolate chip cookies — the percentage of chocolate chips must be declared.
• Hazelnut cookies — the percentage of hazelnuts must be declared.
• Oat cookies — the percentage of oats, if oats feature in the name.
• Protein cookies — if “protein” is in the name, the protein source percentage may be required.
• Fruit bites — the percentage of the named fruit component.

The percentage is calculated at the time of manufacture. It is expressed in the ingredients list directly after the ingredient name, or in close proximity to the product name.

5. Presentation and Legibility Rules

Mandatory information must sit in one field of vision and meet the minimum legibility standards in Article 13.

• Minimum font size of 1.2mm x-height for packages with a surface area over 80cm².
• Minimum font size of 0.9mm x-height for packages between 25cm² and 80cm².
• Packages smaller than 25cm² are exempt from the nutrition declaration but must still carry allergen information.
• Information must appear in a language understood by consumers in the country of sale.
• Multi-market packs may carry several languages at once.

Practical note for flow wrap and doypack. Flow wrap and doypack are both common private label formats, and both count as pre-packaged under 1169/2011, so both need the full mandatory declaration. For small flow-wrap units sold inside a retail outer, the mandatory information can sit on the outer rather than each unit, as long as consumers can see it before purchase.

6. Who Is the Food Business Operator?

Under Article 8, the food business operator responsible for labelling is the operator whose name or business name markets the food. In a private label arrangement that is you, the brand owner. It is not the contract manufacturer.

In practice:

• Your company name and address must appear on the label.
• You are legally responsible for the accuracy of the label information.
• Your manufacturer must supply accurate technical data, but the compliance responsibility stays with you.

A good contract manufacturer gives you a full product specification sheet with every recipe: verified nutrition values, ideally from accredited lab analysis rather than calculation, confirmed allergen status, and shelf life data. Verifying that documentation and turning it into compliant label copy is your job.

7. Nutrition and Health Claims

The moment your product claims anything beyond a factual description, EU Regulation 1924/2006 applies. Here are the common claims on cookie and energy ball products and what each one requires.

Claim	Condition
”High protein” / “Rich in protein”	At least 20% of energy from protein
”Source of protein”	At least 12% of energy from protein
”Low sugar”	No more than 5g sugars per 100g
”Sugar free”	No more than 0.5g sugars per 100g
”High fibre”	At least 6g fibre per 100g
”Source of fibre”	At least 3g fibre per 100g
”No added sugar”	No added mono- or disaccharides; state “Contains naturally occurring sugars” if sugars are present
”Gluten free”	Maximum 20 ppm gluten (EU Regulation 41/2009)

Health claims that link a nutrient to a body function are governed by the EU Register of authorised health claims. Only claims on the approved list may be used. Claims about reducing disease risk need a specific authorisation and rarely apply to snacks.

8. Label Approval Checklist

Run through all of this before artwork goes to print.

1. The legal name of the food is accurate and not misleading.
2. Ingredients are listed in descending order by weight.
3. Every one of the 14 potential allergens present is highlighted in the ingredients list.
4. QUID percentages are declared for all characterising ingredients.
5. The nutrition table includes every mandatory nutrient per 100g.
6. Energy is declared in both kJ and kcal.
7. Net weight is stated correctly in grams.
8. The best before date format is correct (DD/MM/YYYY, or MM/YYYY for shelf-stable products).
9. Storage conditions match the best before date assumptions.
10. The FBO name and address (your company) is present.
11. Country of origin is stated if the name or imagery would otherwise mislead.
12. All text meets the minimum x-height for the pack size.
13. The label is in the correct language or languages for your target markets.
14. Any nutrition or health claim is on the EU authorised list and meets its conditions.
15. The lot mark format is agreed with your manufacturer.

Working with your manufacturer. A compliant label depends on accurate data from your production partner. Before you finalise artwork, request a full product specification sheet with lab-verified nutrition values, confirmed allergen status, and declared shelf life with storage conditions. At Cookie Label we provide this documentation as standard with every private label product.

Getting Your Label Right

EU labelling is non-negotiable, but it is manageable with the right documentation and a partner who knows what you need. The failures we see most on private label products are the same three every time: allergen highlighting errors, incorrect QUID declarations, and unsubstantiated nutrition claims. Start from accurate specification data and most of that risk disappears.

Developing a private label cookie or snack range for the EU and want a partner who understands the compliance side? Get in touch with Cookie Label. We produce cookies, protein cookies, energy balls, bars, fruit bites, and oat cookies in flow wrap and doypack from our approved facility in Slovakia, with IFS Food certification in progress.