As part of a large international survey, Bech-Bruun has examined the Danish rules for labelling of foodstuffs, with particular focus on domestic requirements. The outcome of the analysis was recently published in an international report collecting the rules for labelling of foodstuffs in a number of EU member states and Norway.

Bech-Bruun’s Life Science Team has examined Danish rules for labelling of foodstuffs, which apply in addition to the EU food labelling requirements. The outcome was recently published in a European report entitled: “National Implementing Regulation on the European Regulation no. 1169/2011”. As far as we know, the report is the first of its kind to examine the experiences with introducing the EU Food Information for Consumers Regulation (FIC) in Europe. The report provides an overview of domestic food labelling requirements in EU member states and in Norway on the statutory basis of the FIC.

European food labelling requirements

The FIC harmonises the requirements to food information for consumers in Europe while allowing certain domestic features such as labelling language, allergen labelling, labelling of non-prepacked food, and determination of domestic sanctions. The FIC officially became effective on 13 December 2014, whereas individual parts did not become effective until 2016.

The FIC is available in all European languages.

Danish food labelling requirements

In addition to the FIC, the Danish authorities have issued Executive Order no. 1355 of 27 November 2015, which became effective on 1 January 2016. The Executive Order regulates the labelling of foodstuffs marketed to consumers and in B2B relations and is available at retsinformation.dk (in Danish only).

Bech-Bruun’s examination reveals that Executive Order no. 1355 of 27 November 2015 supplements the FIC on a number of topics:

  • Danish or similar language on food packaging
  • Specification of net quantity
  • Allergen labelling
  • Labelling of non-prepacked food
  • Labelling of food packaged at consumers’ request
  • Labelling of food packaged for direct sale
  • Identification labelling of pre-packaged minced meat products

The Danish Veterinary and Food Administration (DVFA) has compiled a labelling guidance, which comprises the DVFA’s interpretation of the FIC and domestic labelling requirements.

DVFA’s food labelling guidance (in Danish only).

Sanctions

Breach of the food labelling regulation is usually sanctioned administratively in connection with food control, and sanctions range from an enforcement notice to a fine and/or an order for compliance. In gross cases, breach may be sanctioned by up to 2 years’ imprisonment.