EU food country of origin

When EU food must show country of origin or place of provenance

Direct answer. Article 9(1)(i) of Regulation (EU) No 1169/2011 lists, as a mandatory particular, “the country of origin or place of provenance where provided for in Article 26.” Article 26(2) says that indication shall be mandatory (a) where failure to indicate it might mislead the consumer as to the true country of origin or place of provenance of the food, in particular if the information accompanying the food or the label as a whole would otherwise imply a different one, and (b) for meat falling within the Combined Nomenclature codes listed in Annex XI, subject to the implementing acts in paragraph 8. Article 26(3) says that where the origin of a food is given and it is not the same as that of its primary ingredient, the origin of the primary ingredient shall also be given, or shall be indicated as being different. Commission Implementing Regulation (EU) 2018/775 Article 4 says that regulation shall apply from 1 April 2020. For prepacked food sold by distance communication, Article 14(1)(a) makes mandatory food information available before purchase, except the Article 9(1)(f) date. When Article 26 makes origin mandatory, that particular is in the before-purchase set. This page is not legal advice.

EU Food Info Guard (Shopify App Store · Write a review) reviews allergen, ingredient, nutrition, net quantity, origin, operator, and storage gaps before food product display. The listing does not say it decides whether Article 26 requires an origin line, or that it calculates a place of provenance. Honey has its own origin rules: EU honey origin on the product page.

Related: FibreLedger Textile Labels — EU fibre composition uses Annex I names.

Free check first: EU food label particulars checklist runs in your browser and sends nothing. Paste food label text and see which mandatory particulars and Annex II allergens it names.

Checklist before you treat origin as mandatory

Article 26(2): when omission could mislead, and Annex XI meat

The Commission’s origin-labelling page states the same general rule as Article 26(2)(a): indication is mandatory where failure to indicate the country of origin or place of provenance might mislead the consumer, in particular if the information accompanying the food or the label as a whole would otherwise imply a different origin. That page also says the regulation requires origin labelling for fresh, chilled and frozen meat of swine, sheep, goats and poultry. That is the Annex XI path in Article 26(2)(b). The same page says Commission Regulation (EU) No 1337/2013 sets modalities requiring, with some exceptions, the place of rearing and the place of slaughter for prepacked fresh, chilled and frozen meat of those animals, applicable as of 1 April 2015. Confirm the exceptions in that regulation. This page does not list Combined Nomenclature codes.

The primary ingredient, from 1 April 2020

Article 26(3) applies where the country of origin or place of provenance of a food is given and is not the same as that of its primary ingredient. The food business operator then either gives the primary ingredient’s origin, or indicates that it is different. The article says application of that paragraph is subject to the implementing acts in paragraph 8. Implementing Regulation (EU) 2018/775 is the act that lays down those rules. Its Article 4 says the regulation enters into force on the third day following publication in the Official Journal, shall apply from 1 April 2020, and that foods placed on the market or labelled prior to the date of application may be marketed until the stocks are exhausted. The Commission page says the same application date, and notes a Commission notice of 30 January 2020 on how to apply Article 26(3). Read the notice and the implementing regulation before you draft the wording. This page does not reprint the indication formats.

Other sector rules, and distance selling

Article 26(1) applies without prejudice to labelling requirements in specific Union provisions. The Commission origin page says mandatory origin provisions have been developed for instance for honey, fruit and vegetables, fish, beef and beef products, and olive oil. Those are the sectors that page names. Honey on a product page is EU honey origin. This page does not restate the honey percentages.

Article 9(1)(i) is mandatory only where Article 26 provides for it. Article 14(1)(a), for prepacked foods offered for sale by means of distance communication, requires mandatory food information, except point (f) of Article 9(1), before the purchase is concluded, on the material supporting the distance selling or through other appropriate means clearly identified by the food business operator, without supplementary cost. Point (f) is the date of minimum durability or the “use by” date. Origin is not that exception. When Article 26 makes it mandatory, it is among the particulars Article 14(1)(a) puts before purchase. Ingredient percentages are QUID. The operator’s name and address are Article 9(1)(h).

What this page is not

Related pages

Not legal advice. Confirm Articles 9(1)(i), 14 and 26 of Regulation (EU) No 1169/2011, Implementing Regulation (EU) 2018/775, and any sector rule on EUR-Lex before you treat an origin line as required. The app reviews gaps in the food information you enter. It does not decide the country of origin.