List of ingredients

Heading (Article 18)

Article 18(1) requires the list of ingredients to be headed or preceded by “ingredients” (or a heading which includes the word “ingredients”).

The list of ingredients shall be headed or preceded by a suitable heading which consists of or includes the word “ingredients”. It shall include all the ingredients of the food, in descending order of weight, as recorded at the time of their use in the manufacture of the food.

Article 18(1)

Names of ingredients (Article 18(2) and (3))

• General: The name used for an ingredient must be the name which would be used if the ingredient were sold as a food. Therefore the same rules apply to the name in the ingredients list as apply to the name of the food. See Name of Food for details. However, in some cases, Generic Names are permitted (see below).
• Nano-materials: All ingredients present in the form of engineered nanomaterials must give their standard names followed by the word “nano” in brackets. The Regulation contains a definition of “engineered nanomaterials”. See Definition.

Variation to “descending order of weight” rule (Annex VII, Part A)

The general rule given above is that ingredients are listed in “descending order of weight, as recorded at the time of their use in the manufacture of the food”. There are though certain situations where variation is permitted. Details are given in Annex VII, Part A, of the Regulation. The categories are listed here - full details are provided in Table of variations to “descending order of weight” rule.

• Added water and volatile products
• Ingredients used in concentrated or dehydrated form and reconstituted at the time of manufacture
• Ingredients used in concentrated or dehydrated foods, which are intended to be reconstituted by the addition of water
• Fruit, vegetables or mushrooms, none of which significantly predominates in terms of weight and which are used in proportions that are likely to vary, used in a mixture as ingredients of a food
• Mixtures of spices or herbs, where none significantly predominates in proportion by weight
• Ingredients constituting less than 2% of the finished product
• Ingredients, which are similar or mutually substitutable, likely to be used in the manufacture or preparation of a food without altering its composition, its nature or its perceived value, and in so far as they constitute less than 2% of the finished product
• Refined oils of vegetable origin
• Refined fats of vegetable origin

Generic names (Annex VII, Part B)

Although the general requirement stated above is that the name used for an ingredient must be the name which would be used if the ingredient were sold as a food, certain exemptions are provided in Annex VI, Part B. These are commonly referred to as “generic names”. Details are provided in a table - see Table of Generic Names.

Additives (Annex VII, Part C)

Food additives and food enzymes belonging to one of the specified categories (see Table of Additive Categories) must be designated by the name of that category, followed by their specific name or, if appropriate, E number. If an ingredient belongs to more than one of the categories, the category appropriate to the principal function in the case of the food in question shall be indicated.

However, it is not required to list food additives and food enzymes:

1. whose presence in a given food is solely due to the fact that they were contained in one or more ingredients of that food, in accordance with the carry-over principle (see Definition of “carry-over principle”) provided that they serve no technological function in the finished product; or
2. which are used as processing aids. (For definition of “processing aid”, see Definitions of Additives, etc.)

Note also that in the case of the specified allergens or substances causing intolerance, their presence must be indicated.

The definitions of “food additives” “food enzymes” and “processing aids” which apply here are given in separate legislation. See Definitions of Additives, etc.

Note: As mentioned elsewhere, as a requirement of the Food Additive Regulation 1333/2008, for certain colours a special warning statement is needed stating “[name or E number of the colours]: may have an adverse effect on activity and attention in children”. For listing of the colours, view listing.

Flavourings (Annex VII, Part D)

Flavourings shall be designated either by the terms:

• “flavouring(s)” or by a more specific name or description of the flavouring if the flavouring component contains flavourings as defined in points (b), (c), (d), (e), (f), (g) and (h) of Article 3(2) of Regulation (EC) No 1334/2008, See Definitions of Flavouring Categories
• “smoke flavouring(s)”, or “smoke flavouring(s) produced from food(s) or food category or source(s)” (e.g. “smoke flavouring produced from beech”), if the flavouring component contains flavourings as defined in point (f) of Article 3(2) of Regulation (EC) No 1334/2008 and imparts a smoky flavour to the food. See Definitions of Flavouring Categories

The term “natural” for the description of flavourings shall be used in accordance with Article 16 of Regulation (EC) No 1334/2008. Note that this is a complex provision and Regulation 1334/2008 should be consulted for full details.

Quinine and/or caffeine used as a flavouring in the production or preparation of a food shall be mentioned by name in the list of ingredients immediately after the term “flavouring(s)”.

Compound Ingredients (Annex VII, Part E)

“compound ingredient” means an ingredient that is itself the product of more than one ingredient;

Article 2(2)(h)

A compound ingredient may be included in the list of ingredients, under its own designation in so far as this is laid down by law or established by custom, in terms of its overall weight, and immediately followed by a list of its ingredients.

Although the rules on allergens must still be met, the list of ingredients for compound ingredients shall not be compulsory:

1. where the composition of the compound ingredient is defined in EU-derived domestic legislation in force or retained direct EU legislation in force, and in so far as the compound ingredient constitutes less than 2% of the finished product; however, this provision shall not apply to food additives (unless the additives are already exempt from being labelled under points (a) to (d) of Article 20 - see below);
2. for compound ingredients consisting of mixtures of spices and/or herbs that constitute less than 2% of the finished product, (unless the additives are already exempt from being labelled under points (a) to (d) of Article 20 - see below); or
3. where the compound ingredient is a food for which a list of ingredients is not required under EU-derived domestic legislation in force or retained direct EU legislation in force.

Omission of the List of Ingredients

The following foods do not require a list of ingredients:

1. fresh fruit and vegetables, including potatoes, which have not been peeled, cut or similarly treated;
2. carbonated water, the description of which indicates that it has been carbonated;
3. fermentation vinegars derived exclusively from a single basic product, provided that no other ingredient has been added;
4. cheese, butter, fermented milk and cream, to which no ingredient has been added other than lactic products, food enzymes and micro-organism cultures essential to manufacture, or in the case of cheese other than fresh cheese and processed cheese the salt needed for its manufacture;
5. foods consisting of a single ingredient, where:
   1. the name of the food is identical to the ingredient name; or
   2. the name of the food enables the nature of the ingredient to be clearly identified.

Article 19(1)

Omission of Items from the List of Ingredients

Although the rules on allergens must still be met, the following do not need to be included in the list of ingredients:

1. the constituents of an ingredient which have been temporarily separated during the manufacturing process and later reintroduced but not in excess of their original proportions;
2. food additives and food enzymes:
   1. whose presence in a given food is solely due to the fact that they were contained in one or more ingredients of that food, in accordance with the carry-over principle (see Definition of “carry-over principle”), provided that they serve no technological function in the finished product; or
   2. which are used as processing aids; (For definition of “processing aid”, see Definitions of Additives, etc.)
3. carriers and substances which are not food additives but are used in the same way and with the same purpose as carriers, and which are used in the quantities strictly necessary; (For definition of “carriers”, see Definitions of Additives, etc.)
4. substances which are not food additives but are used in the same way and with the same purpose as processing aids and are still present in the finished product, even if in an altered form;
5. water:
   1. where the water is used during the manufacturing process solely for the reconstitution of an ingredient used in concentrated or dehydrated form; or
   2. in the case of a liquid medium which is not normally consumed.

Article 20