Key takeaways
- In the UK, prepacked food needs the full set of mandatory information; PPDS food needs only the name and an ingredients list with allergens emphasised; loose food needs allergen information available, not a label.
- The EU list of mandatory information is the same as the UK's, but the business address, language and health marks must suit the market of sale.
- The USA counts nutrition per serving in a fixed Nutrition Facts layout, accepts a 'Contains' statement for allergens, has no general date-marking rule and no QUID.
- Canada is bilingual, requires a best-before date only on short-life food, and makes a front-of-pack nutrition symbol mandatory from 2026.
- Australia and New Zealand require allergens in bold plus a summary statement, nutrition per serving and per 100 g, and origin labelling on most retail food.
- Every regime starts from the same recipe facts: ingredients in weight order, allergens, nutrition and portion. Hold those once and the labels are templates.
The UK's three regimes
Before comparing countries it helps to be clear that the UK is not one regime. The same sandwich carries different obligations depending on how it reached the customer:
- Prepacked, packed before sale and sold anywhere: the full list of mandatory information under the retained Food Information Regulation. Our UK food labelling rules guide walks through each item.
- Prepacked for direct sale (PPDS), packed on the premises it is sold from before the customer orders: since Natasha's Law, the name of the food and a full ingredients list with the 14 allergens emphasised, and nothing else is required. See the PPDS guide.
- Non-prepacked (loose), served, or packed at the customer's request: no label, but allergen information must be available, in writing or verbally with clear signposting to where it can be found.
Those three columns sit on the left of the table below. The other four are the markets UK food businesses most often export to or buy from, each with its own prepacked rules.
The comparison table
Green is required, amber is required in some circumstances, blue is voluntary, grey is not required. The words in each cell say what the rule actually is; the column headers link to the regulator's own guidance.
| Requirement | UK prepackedPacked before sale, sold anywhere | UK PPDSPacked on the premises it is sold from | UK looseServed or packed at the customer's request | EURegulation 1169/2011 | USAFDA, 21 CFR 101 | CanadaCFIA, Food and Drug Regulations | AUS / NZFSANZ Food Standards Code |
|---|---|---|---|---|---|---|---|
| Name of the food | Required: Legal or customary name | Required: On the pack | Required: On the menu, sign or ticket | Required: Legal or customary name | Required: Statement of identity | Required: Common name, bilingual | Required: Prescribed or descriptive name |
| Ingredients listIn descending order of weight | Required: Descending weight order | Required: Full list on the pack | Not required: Allergen information only | Required: Descending weight order | Required: Descending weight order | Required: Descending weight order, bilingual | Required: Descending ingoing weight order |
| How allergens are shown | Required: Emphasised in the ingredients list (bold, capitals…) | Required: Emphasised in the ingredients list | Required: Available in writing or verbally, with signposting | Required: Emphasised in the ingredients list | Required: In the list or a separate “Contains” statement; no emphasis rule | Required: In the list or a “Contains” statement | Required: Bold in the list plus a separate summary statement (PEAL) |
| Allergen list usedSee the 14 allergens guide for the full matrix | Required: The 14 | Required: The 14 | Required: The 14 | Required: The same 14 | Required: 9 major allergens | Required: 11 priority allergens plus gluten sources | Required: 14 categories, each tree nut named |
| “May contain” warnings | Voluntary: Only after a real risk assessment | Voluntary: Same as prepacked | Voluntary: Tell customers of cross-contact risks | Voluntary: Voluntary; must not mislead | Voluntary: Voluntary; must be truthful | Voluntary: Voluntary; CFIA wording guidance | Voluntary: Voluntary; VITAL guidance widely used |
| Quantity of key ingredients (QUID) | Required in some cases: % when an ingredient is named or pictured | Not required: Not required | Not required: Not required | Required in some cases: % when an ingredient is named or pictured | Not required: No general rule (juice % only) | Not required: No general rule | Required in some cases: % of characterising ingredients |
| Net quantity | Required: Metric; e-mark optional | Not required: Not required | Not required: Not required (sold by weight rules apply) | Required: Metric | Required: US customary and metric | Required: Metric | Required: Metric |
| Date marking | Required: Use-by (safety) or best-before (quality) | Not required: Not required (good practice) | Not required: Not required | Required: Use-by or best-before | Not required: Not required except infant formula; voluntary wording | Required in some cases: Best-before when shelf life is 90 days or less | Required: Use-by or best-before if shelf life under 2 years |
| Storage and use instructions | Required in some cases: Where needed for safety or quality | Not required: Not required | Not required: Not required | Required in some cases: Where needed | Voluntary: Not generally required; expected where safety depends on it | Required in some cases: Where storage affects the date | Required in some cases: Where needed for safety |
| Business name and address | Required: UK address (NI: UK or EU) | Not required: Not required | Not required: Not required | Required: EU-established business | Required: Manufacturer, packer or distributor | Required: Dealer name and principal place of business | Required: Supplier name and address |
| Country of origin | Required in some cases: Where omission would mislead, plus meat, honey, produce, olive oil | Not required: Not required | Required in some cases: Beef and some other meat at point of sale | Required in some cases: Same rule as the UK | Required in some cases: Imported goods marked; COOL for some retail foods | Required in some cases: Specific imported products | Required: Mandatory standard mark on most retail food |
| Nutrition declaration | Required: Per 100 g/ml; small-scale direct supply exempt | Not required: Not required | Not required: Not required | Required: Per 100 g/ml | Required: Nutrition Facts per serving; small-business exemptions | Required: Nutrition Facts table per serving | Required: Panel per serving and per 100 g |
| Front-of-pack nutrition | Voluntary: Traffic lights, voluntary | Not required: Not applicable | Not required: Not applicable | Voluntary: Voluntary; Nutri-Score in some states | Voluntary: FDA scheme proposed, not yet required | Required in some cases: Mandatory symbol for high sat fat, sugars or sodium (2026) | Voluntary: Health Star Rating, voluntary |
| Minimum text size | Required: 1.2 mm x-height (0.9 mm on small packs) | Required: Same x-height rule | Not required: Legible | Required: 1.2 mm x-height | Required: 1.6 mm (1/16 in) on the information panel | Required: 1.6 mm type height (0.8 mm small packs) | Required in some cases: Legible and prominent; 1.5 mm for warning statements |
| Language | Required: English | Required: English | Required: English | Required: Official language of the market | Required: English | Required: English and French | Required: English |
| Lot or batch mark | Required: Lot marking, unless the date is day-specific | Not required: Not required | Not required: Not required | Required: Lot marking | Voluntary: Not generally required; needed for recalls | Voluntary: Not generally required | Required: Lot identification |
The differences that catch UK businesses out
Nutrition: per 100 g or per serving
The UK and EU declare nutrition per 100 g or 100 ml, with per-portion figures optional. The USA and Canada declare per serving in a fixed Nutrition Facts layout with their own nutrient lists, rounding rules and daily values; Australia and New Zealand want both per serving and per 100 g. The numbers come from the same recipe, but a UK panel cannot simply be reprinted on a US pack, and the serving size itself is regulated in the USA.
Allergens: emphasised, stated, or both
UK and EU labels emphasise each allergen inside the ingredients list and may not rely on a separate statement. The USA and Canada accept a “Contains” line instead. Australia and New Zealand require the allergen in bold in the list and a summary statement in prescribed words. The lists differ too: the USA has nine, Canada adds mustard but not celery or lupin, and Australia names every tree nut. The 14 allergens guide has the full matrix.
Dates and lot marks
A UK label needs a use-by or best-before date and a lot mark. The USA has no general date-marking rule, and lot codes are expected for traceability rather than required. Canada only requires a best-before date on food with a shelf life of 90 days or less. Australia requires dates on anything with a shelf life under two years and a lot identification.
Quantity, origin and language
QUID, the percentage of a named ingredient, is a UK, EU and Australian rule with no North American equivalent. Country of origin is conditional in the UK and EU but mandatory on most retail food in Australia, with a prescribed standard mark. Canada is bilingual throughout; the EU wants the official language of each country of sale.
Front-of-pack schemes
Traffic lights in the UK, Nutri-Score in parts of the EU and the Health Star Rating in Australia are all voluntary. Canada's front-of-pack symbol for foods high in saturated fat, sugars or sodium becomes mandatory in 2026, and the FDA has proposed a US scheme that is not yet in force.
Labelling for several markets
- Hold the facts once.Ingredients in descending weight, allergens, nutrition per 100 g, portion weight, shelf life, origin of the primary ingredient. Every market's label is a view of that record.
- Build one layout per market. The UK and EU share a layout apart from the address and language. The USA, Canada and Australia each need their own nutrition panel and allergen format.
- Declare the union of allergen listswhen one pack serves several markets, in each market's format.
- Get a local check. An importer, distributor or labelling consultant in the destination reviews the artwork before the first print run.
- Change control.When a recipe or supplier changes, every market's label changes with it, from the same record, on the same day.
How Recipee makes this simpler
Most of the work in the table above is not design; it is having the right facts about the recipe to hand, every time, for every market. That is what Recipee holds. Each recipe carries its ingredients in descending weight, the allergens inherited from every sub-recipe, nutrition calculated per 100 g and per portion, the portion weight and the yields, so:
- the label builder prints a UK or PPDS label with the ingredients list and emphasised allergens generated from the recipe, not retyped;
- the same nutrition data gives the per-serving figures a US or Canadian panel needs and the per-100 g and per-serving pair Australia wants;
- a supplier change that adds an allergen reaches every product and every label from the one ingredient record;
- the product feed carries the ingredients, allergens and nutrition to your online shop, where distance-selling rules apply.
The market-specific layout is a template; the facts behind it are the part that goes wrong when they live in five spreadsheets. Book a demo and bring a product you sell in two countries.