Trade Advice Document
Trading advice from several sources is available to help businesses comply with the law.
The Health and Safety Executive website has advice on:
The Chartered Trading Standards Institute provides advice on a number of topics:
Food labelling for bakers
In the guide
- How to present the information
- Meat products
- Irradiated foods
- Genetically modified foods
- Cakes & confectionery
- EU protected food names
- Gluten free & low gluten claims
The food-labelling essentials that a baker needs to know, including meat pies and sausage rolls
This guidance is for England
This guide applies to products that are sold loose, packed at the request of the purchaser, or packed on the premises from which they will be sold.
Bread, cakes, savoury products, meat pies, sausage rolls, etc sold in the manner above must be marked with their name, details of irradiated or genetically modified ingredients, and any allergens that are present. Products that contain meat must state the percentage of the product that is made up by the meat (or meats if it contains more than one type).
The guide does not cover products prepacked by you for sale from another premises, nor does it cover products prepacked by another packer and sold by you. These products require full labelling; as such, they are covered by 'Labelling of prepacked foods'.
How to present the information
In the case of goods that are sold loose or packed at the request of the customer, you should present the information on the shelf edge or on a notice that can be readily seen by customers. Where goods are prepacked on the premises from which they will be sold (prepacked for direct sale), you can present the information on a shelf edge or notice, or you can apply a label to the product.
In the case of allergens you can place a notice on display instructing the customer to ask a member of staff for allergen information.
The legal name of the product must be given. Under normal circumstances this is the name that describes the true nature of the food. A product marketed as 'Peter Pig' would need the descriptive name of the food to clarify what it is - for example, 'Marshmallow and digestive biscuit with a coating of pink icing'. The name 'Peter Pig' is a 'fancy name' and has no legal standing.
Sometimes a 'customary name' may be used instead of a descriptive name. A customary name is a name that allows the product to be clearly distinguished from other similar products and is readily understood by UK consumers without further clarification - for example, Belgian bun, Chelsea bun, etc.
If the product contains any of the following types of allergen then this must be declared:
- cereals containing gluten, such as wheat, rye, barley, oats, spelt, kamut, and their hybridised strains
- peanuts (also called groundnuts)
- nuts, such as almonds, hazelnuts, walnuts, Brazil nuts, cashews, pecans, pistachios, macadamias and Queensland nuts
- sesame seeds
- milk and milk products (including lactose)
- soy beans
- sulphur dioxide and sulphites at levels above 10mg/kg or 10mg/litre expressed as SO2
You should specify the allergen as it appears in the list above. If a product contains wheat then you would state 'Contains wheat' as this is specified in the list; however, if a product contains prawns you would state 'Contains crustaceans' as 'prawns' does not appear in the list.
For more information on allergens see 'Food allergens & intolerance'.
Any products which contain meat as an ingredient will need a declaration of the percentage of the product which is made up of meat; this is referred to as a 'quantitative ingredient declaration' (QUID) - for example, 'Sausage roll - contains 25% pork'.
If a product contains more than one type of meat a QUID will need to be given for each type of meat. Some products will need to have a minimum amount of meat before you can call them by certain names - meat pies, for example. Please see 'Composition of meat products' for more information.
If a food has been irradiated or contains ingredients that have been irradiated then you must state either 'Irradiated' or 'Treated with ionising radiation'. This should appear on the shelf edge or on a notice immediately above or next to the product.
Genetically modified foods
If the product contains or is made from genetically modified foods you must state either 'Contains genetically modified (name of organism)' or 'Contains (name of ingredient) produced from genetically modified (name of organism)'. In the case of foods sold loose or packed at the request of the consumer the information should appear on the shelf edge or on a notice immediately next to the product. If the product is prepacked for direct sale the information should appear on the product.
For more information see 'Genetically modified foods'.
Bread, made from wheat flour, other than white bread, must have a notice on it that clearly and conspicuously tells customers which type it is - for example:
- brown bread
- wheatgerm bread (must contain 10% added wheatgerm)
- wholemeal bread (all the flour used must be wholemeal)
- soda bread
It is illegal to use the name 'wheatmeal bread'.
Brand names such as 'Hovis' and 'Granary' are insufficient on their own, you will also need to give a descriptive name.
Other types of bread where the flour is not wholly wheat flour must be appropriately described - for example, rye bread.
Cakes & confectionery
Cakes are required to be labelled with their name. You must ensure that the description is true and accurate; some examples are below:
- it is important to realise that the words 'flavoured' and 'flavour' have very different meanings - for example, 'vanilla flavoured icing' derives its flavour only from real vanilla, but 'vanilla flavour icing' is synthetically flavoured and contains no vanilla. If neither word is used (vanilla slice, for example) the flavour must be only from natural vanilla
- the cream in cream cakes must be wholly dairy cream. If any artificial or imitation cream is used this must be stated in the name of the product.
- imitation cream and imitation chocolate must not be described as cream or creme, chocolate or choc
EU protected food names
Cornish pasties and traditional Cumberland sausages (among others) have been accredited with protected status. Any products using this name must comply with the compositional and/or origin requirements. The full list of UK protected food names is available on the GOV.UK website.
Gluten free & low gluten claims
A gluten-free claim is a statement to the consumer that eating the product will not cause an allergic reaction in sensitive individuals. Gluten-free claims should not be made unless production control and in-store handling procedures are sufficiently robust to ensure that there is no gluten contamination and that test results show that gluten is present at less than 20 mg/kg. If you wish to make a claim of 'very low gluten' then you must ensure that the product contains no more than 100 mg/kg.
Detailed information on labelling of 'gluten free' foods is available on the Food Standards Agency website.
Failure to comply may result in an improvement notice being issued, requiring compliance to be achieved. If the improvement notice is not complied with it is an offence under the Food Safety Act 1990. The maximum penalty is a fine and two years' imprisonment.
If allergen information does not comply with the requirements it is an offence under the Food Information Regulations 2014. The maximum penalty is a fine.
- Bread and Flour Regulations 1998
- EU Regulation (EC) No 1829/2003 on genetically modified food and feed
- Genetically Modified Food (England) Regulations 2004
- EU Regulation (EC) No 1333/2008 on food additives
- EU Regulation (EU) No 1169/2011 on the provision of food information to consumers
- Food Information Regulations 2014
Last reviewed / updated: March 2018
This information is intended for guidance; only the courts can give an authoritative interpretation of the law.
The guide's 'Key legislation' links may only show the original version of the legislation, although some amending legislation is linked to separately where it is directly related to the content of a guide. Information on amendments to UK legislation can be found on each link's 'More Resources' tab; amendments to EU legislation are usually incorporated into the text.
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The county council is not responsible for this information.