Food labelling: the 7 most common EU 1169/2011 mistakes
The EU Food Information to Consumers regulation (EU 1169/2011) governs what must appear on food labels: ingredient list, allergens, nutrition declaration, origin, mandatory particulars. In practice, most non-conformities found during inspections don't come from ignorance of the regulation — they come from poorly mastered product data.
Here are the seven mistakes we see most often, and the common root cause behind nearly all of them.
1. Allergens not emphasised in the ingredient list
The 14 mandatory allergens must be typographically emphasised (bold, capitals) within the ingredient list itself. A separate 'contains: gluten' statement is not enough. The classic miss: a compound ingredient whose allergen is not surfaced (egg hidden in a sauce, whey in a flavouring).
2. Ingredient list in the wrong order
Ingredients must be listed in descending order of weight, measured at the time of use. After three successive reformulations, if the label hasn't followed the recipe, the order is wrong. It's the textbook case of drift between the real recipe and the printed label.
3. Nutrition values that don't follow reformulations
Every raw-material or dosage change alters the nutrition declaration. When the calculation lives in a spreadsheet detached from the recipe, nobody re-runs it systematically — and the gap between declared and actual values exceeds the accepted tolerances.
4. Missing or wrong QUID
Whenever an ingredient is highlighted (product name, picture, claim), its percentage must appear in the ingredient list. A 'chocolate chip cookie' with no chip percentage is non-compliant.
5. Origin not declared when required
The origin of the primary ingredient must be stated when it differs from what the label suggests. A mid-year sourcing change — frequent under supply pressure — can silently make an existing label non-compliant without any team having decided it.
6. Illegible mandatory particulars
Minimum font size (1.2 mm x-height), sufficient contrast, same field of vision for certain particulars: typographic constraints that get lost during pack redesigns when the regulatory constraint never reaches the design studio.
7. Translations out of sync across markets
The same product sold in several countries must carry equivalent information in every language. When each subsidiary manages its label on its own, versions drift apart with every update.
The common root cause of all seven: the label is disconnected from the product data. When the ingredient list, allergens and nutrition values are generated automatically from the recipe — as crumble-ai does — the label follows the formulation by construction, in every language, and every deviation is blocked at the source.
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