Regulation (EU) No 1169/2011 requires that food sold online shows the same mandatory particulars as the label, except the date of minimum durability or use by date, before the purchase is concluded and at no extra cost. That includes the name, ingredients with the 14 allergens emphasised, net quantity, nutrition declaration and food business operator.
Regulation (EU) No 1169/2011 on the provision of food information to consumers, dated 25 October 2011, requires that prepacked food sold online carries the same mandatory information as its label before the purchase is concluded. The only exception is the date of minimum durability or use by date, which must be available at delivery. The information must be free of supplementary charges to the consumer. For grocery retailers and food brands, this turns label content into regulated PIM (product information management) data.
This article describes the obligations factually; it does not constitute legal advice.
Which particulars are mandatory under Article 9?
Article 9(1) lists twelve mandatory particulars. Article 14 applies them to distance selling.
| Article 9(1) | Particular | Online before purchase |
|---|---|---|
| (a) | Name of the food | Yes |
| (b) | List of ingredients | Yes |
| (c) | Ingredients or processing aids from Annex II (allergens) still present in the finished product | Yes |
| (d) | Quantity of certain ingredients or categories of ingredients | Yes |
| (e) | Net quantity of the food | Yes |
| (f) | Date of minimum durability or use by date | No, at delivery |
| (g) | Special storage conditions and/or conditions of use | Yes |
| (h) | Name or business name and address of the food business operator under Article 8(1) | Yes |
| (i) | Country of origin or place of provenance where required by Article 26 | Yes |
| (j) | Instructions for use where needed for appropriate use | Yes |
| (k) | Actual alcoholic strength by volume for beverages above 1.2% alcohol | Yes |
| (l) | Nutrition declaration | Yes |
The regulation has applied since 13 December 2014; the nutrition declaration became mandatory from 13 December 2016. Under Article 30(1), the declaration covers energy, fat, saturates, carbohydrate, sugars, protein and salt.
What does Article 14 require for distance selling?
Article 14(1) states that for prepacked food offered by means of distance communication, mandatory particulars other than the durability date must be available before the purchase is concluded, appear on the material supporting the distance sale or be provided by other appropriate means clearly identified by the operator, and be provided without supplementary costs. All mandatory particulars must be available at delivery. Article 14(2) extends the obligation to non-prepacked food sold at a distance, for which allergen information under Article 44 is mandatory.
Article 8(1) assigns responsibility to the operator under whose name the food is marketed, or to the importer where that operator is outside the EU. Retailers selling third-party brands therefore depend on supplier data, which is why many grocery retailers request food information through GS1 GDSN.
How must the 14 allergens be handled?
Annex II lists 14 substances or products causing allergies or intolerances:
- Cereals containing gluten
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk
- Nuts
- Celery
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites
- Lupin
- Molluscs
Article 21(1)(b) requires these to be emphasised in the list of ingredients through a typeset that clearly distinguishes them, such as font, style or background colour. Online, the ingredient text needs markup that preserves this emphasis, and structured allergen attributes allow filtering and consistent display.
How should a PIM model food information?
Food data combines free text, controlled values and numbers that must stay consistent with packaging. Requirements to test during selection:
- Ingredient lists as rich text with allergen emphasis that survives syndication to each channel.
- Structured allergen attributes: contains, may contain, free from, mapped to the 14 Annex II categories.
- Nutrition tables per 100 g or 100 ml, with optional per-portion values and validation of units.
- Versioning by recipe change, so online content updates when packaging does, with effective dates.
- Localisation per market language, aligned with label text.
- Completeness rules that block publication when any Article 9 particular is missing, as part of product data quality scoring.
- Label images that meet product image standards, as supporting evidence alongside structured fields.
GS1 notes that a QR code with GS1 Digital Link can direct consumers to online ingredients, allergen and nutrition information, which raises the importance of keeping that content complete and current. Syndication to retailers is covered in the product data syndication guide.
Key takeaways
- Online food offers must show all Article 9 mandatory particulars, except the durability date, before purchase and at no extra cost.
- All particulars, including the durability date, must be available at delivery.
- The 14 Annex II allergens must be emphasised in the ingredient list.
- The nutrition declaration covers energy, fat, saturates, carbohydrate, sugars, protein and salt.
- Model ingredients, allergens and nutrition as versioned, structured PIM data aligned with the physical label.
Frequently asked questions
Does the best before date have to appear on a webshop?
No. Article 14(1) of Regulation (EU) No 1169/2011 exempts the date of minimum durability and the use by date from the information that must be available before the purchase is concluded. All mandatory particulars, including the date, must be available at the moment of delivery, which in practice means on the label of the delivered product.
What are the 14 allergens under EU law?
Annex II of Regulation (EU) No 1169/2011 lists cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin and molluscs. When used as ingredients or processing aids and still present in the finished product, they must be emphasised in the list of ingredients, for example in bold type.
Can a product image of the label replace structured food information online?
The regulation requires mandatory particulars to be available before purchase and to be legible, but does not prescribe a specific digital format. Many retailers require structured attributes as well as label images, since structured data supports search, filtering, allergen display and accessibility. Readable label images alone can be hard to verify and may not meet retailer data specifications.
For coverage of PXM, PLM and product compliance, including PPWR and DPP, see the independent resource PXM Atlas.