EU FIC best-before and use-by date

The best-before or use-by date can wait until delivery — every other mandatory particular cannot

For prepacked food sold at a distance, Regulation (EU) No 1169/2011 Art. 14(1)(a) exempts only the Art. 9(1)(f) date of minimum durability or ‘use by’ date from the before-purchase duty; Art. 14(1)(b) requires all mandatory particulars, including that date, at delivery. EU Food Info Guard (Shopify App Store) separates pre-purchase facts from delivery-only notes in that distance-selling style. This page is not legal advice.

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.

What Art. 14 says

Regulation (EU) No 1169/2011 Art. 9(1)(f) lists as a mandatory particular “the date of minimum durability or the ‘use by’ date.” Art. 14 then sets the distance-selling rule. Confirm the live articles on that eli URL. This page is not legal advice.

Art. 14(1) opens: “Without prejudice to the information requirements laid down in Article 9, in the case of prepacked foods offered for sale by means of distance communication:”

(a) mandatory food information, except the particulars provided in point (f) of Article 9(1), shall be available before the purchase is concluded and shall appear on the material supporting the distance selling or be provided through other appropriate means clearly identified by the food business operator. When other appropriate means are used, the mandatory food information shall be provided without the food business operator charging consumers supplementary costs;

(b) all mandatory particulars shall be available at the moment of delivery.

The Commission’s distance-selling page states the same split in plain language: for prepacked foods, all mandatory food information before purchase except the date of minimum durability or the ‘use by’ date, and all mandatory particulars — including that date — at delivery.

What still belongs on the product page before purchase

Art. 14(1)(a) lifts only Art. 9(1)(f) from the before-purchase set. The other Art. 9(1) particulars still belong on the material supporting the sale (for example the product page), or through other appropriate means the operator clearly identifies, without extra cost:

Name of the food
List of ingredients
Annex II allergens emphasised in that list
Quantity of certain ingredients or categories of ingredients (QUID), where required
Net quantity of the food
Special storage conditions and/or conditions of use
Name or business name and address of the food business operator
Country of origin or place of provenance where Article 26 requires it
Instructions for use where they are needed to use the food
Actual alcoholic strength by volume for beverages containing more than 1.2% alcohol
A nutrition declaration

Those neighbouring jobs have their own pages: allergen labelling before purchase, nutrition declaration and net quantity, and food business operator name and address.

Variable data at delivery

The Finnish Food Authority distance-selling page states: “Variable information, such as batch ID and date of minimum durability (best before) or the ‘use by’ date (last day of use), does not have to be supplied at the moment of purchase. At the moment of delivery all mandatory information has to be supplied, including the variable information.”

The Food Safety Authority of Ireland’s Selling or Advertising Food Online leaflet states the same split: “The ‘best-before’ or ‘use-by’ date does not need to be provided before the customer purchases the food. However, all mandatory food information, including the ‘best-before’ or ‘use-by’ date, must be provided on the label of the food delivered to the customer.” A footnote on that sentence points to Annex X of Regulation (EU) No 1169/2011 for foods that are exempt from indicating the ‘best-before’ or ‘use-by’ date.

Non-prepacked foods

Art. 14(2) is a different rule: “In the case of non-prepacked foods offered for sale by means of distance communication, the particulars required under Article 44 shall be made available in accordance with paragraph 1 of this Article.” Art. 44(1)(a) makes the Annex II allergen particular mandatory; Art. 44(1)(b) leaves the other Article 9 and 10 particulars to national measures. The Commission distance-selling page states that allergen information under Article 44 is required unless national measures add some or all of the particulars in Articles 9 and 10. Confirm the live articles and the Member State measures that apply to the SKU. This page is not legal advice.

Shopify ops (native, high level)

If the date of minimum durability or the ‘use by’ date changes from batch to batch, keep that date off the product-page template. The delivered label still has to carry every mandatory particular, including that date. A short “dates shown on pack” note on the product page is optional; Art. 14 does not require it. Do not treat a product-page date line as a substitute for the label at delivery.

App path

EU Food Info Guard separates pre-purchase facts from delivery-only notes in a distance-selling style. It detects all 14 EU Annex II allergens straight from ingredient text and flags an allergen the ingredients mention but the declared list omits. It syncs to a storefront theme block via an app-owned metafield, with no template edits, and runs weekly scheduled completeness reviews plus a full audit trail of every change. The app organizes merchant data. It does not decide lawfulness or replace counsel. Not legal advice.

Open the listing (apps.shopify.com/fic-food-info-guard) and install it on the store that distance-sells food.
Keep the date of minimum durability or the ‘use by’ date with the delivery-only notes, apart from the pre-purchase block.
Detect Annex II allergens from ingredient text and fix any allergen the ingredients mention but the declared list omits.
Sync the theme block via the app-owned metafield, then confirm the live product page shows the pre-purchase particulars before checkout.

Install EU Food Info Guard, keep delivery-only notes apart from the product-page facts, then confirm the live product page before purchase.

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What this page is not

Not legal advice, a compliance certification, or a substitute for counsel.
Not a date or lot tracker.
Not GPSR manufacturer or responsible-person fields. That path is GPSR manufacturer fields vs responsible person.
Not honey origin or blend percentages. That path is honey origin on the product page.