Primary Ingredient Food EU

Labelling of Primary Ingredients – Changes 2020

From 1 April 2020, the new regulation on the origin of the primary ingredient of a food product will apply.


What does the new regulation on primary ingredients say?


Article 26 (3) of Regulation (EU) No. 1169/2011 states that the country of origin or place of provenance of the primary ingredient must be indicated if it does not correspond to the country of origin of the food.


What is a primary ingredient?


Primary ingredients are defined as one or more ingredients that make up more than 50% of the food content or that consumers usually associate with the name of the food.


When must the primary ingredient be declared?


If a food is labelled with an indication of origin and the primary ingredient of the product does not originate in the country/place of origin, its origin must also be indicated.


  • Plum jam from Germany with plums from “EU”
  • Cheese from Denmark with German milk


How should the information be presented on the label according to Article 13 of Regulation (EU) No 1169/2011 ?


  • The origin of the primary ingredient must appear in the same visual field as the indication of the country of origin or place of provenance of the food.
  • The font size must have a minimum x-height of 1.2mm.


In order to make it easier for manufacturers to correctly label their products according to the regulations, the international labelling team of the Tentamus Group will check the declaration of your products.


To find out more, please contact our expert Stefanie Hirsch:
+49 30 20 60 38 170


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