UK vs EU Food Labelling Regulations: Complete 2026 Comparison Guide

When the United Kingdom left the European Union on 31 January 2020, food supplement businesses that sell into both markets faced an immediate and ongoing challenge: two regulatory systems that began as identical but are now diverging at an accelerating pace. Understanding exactly where UK and EU food labelling rules align — and where they differ — is essential for any manufacturer, importer, or distributor who wants to avoid costly label reprints, regulatory enforcement action, or product recalls.

This guide provides a definitive, up-to-date comparison of UK and EU food labelling regulations as they stand in 2026, with specific focus on food supplements. It covers mandatory label elements, allergen declaration rules, nutrition labelling, health claims, the "Not for EU" requirement, Northern Ireland's unique position, and the growing list of ingredient-level divergences that affect what you can legally sell in each market.

Key takeaway: The UK and EU share the same foundational framework — both derived from EU Regulation No 1169/2011 (FIC) — but post-Brexit divergence means that a label compliant in Great Britain may not be compliant in the EU, and vice versa. Businesses selling in both markets must maintain separate label versions or design labels that satisfy both sets of requirements simultaneously.

1. The Legislative Framework: Same Origin, Diverging Paths

Both the UK and EU food labelling systems are rooted in EU Regulation No 1169/2011 on the provision of food information to consumers (FIC). When the UK left the EU, this regulation was retained in UK law as "assimilated law" and is now enforced as the Food Information Regulations 2014 (FIR 2014) in England, with equivalent regulations in Scotland, Wales, and Northern Ireland.

The critical difference is governance. In the EU, the European Commission and EFSA (European Food Safety Authority) continue to update and amend FIC through the standard EU legislative process. In Great Britain, the Food Standards Agency (FSA) and the Department of Health and Social Care (DHSC) now have independent authority to amend retained food law. This means the two systems will continue to diverge over time as each jurisdiction makes its own regulatory decisions.

2. Mandatory Label Elements: What Must Appear on Every Food Supplement Label

Both the UK and EU require the same core set of mandatory information on prepacked food supplement labels. The following table shows where the rules are identical and where they diverge.

Business Address: The Most Immediate Post-Brexit Difference

From 1 January 2024, all food products sold in Great Britain must carry a UK, Channel Islands, or Isle of Man business address. EU addresses are no longer acceptable on GB labels. Conversely, EU labels must carry an address within an EU member state. This means businesses selling in both markets must either maintain two label versions or use a dual-address format that satisfies both requirements simultaneously — for example, listing both a UK address and an EU distributor address.

Northern Ireland is a special case: products sold in Northern Ireland must carry a Northern Ireland or EU address, reflecting its continued alignment with EU food law under the Windsor Framework.

3. Allergen Labelling: 14 Allergens, Near-Identical Rules — With One Key Divergence

Both the UK and EU require the same 14 major allergens to be declared and emphasised within the ingredient list. The emphasis method (bold, italic, underline, or contrasting colour) is the same in both jurisdictions. For food supplement manufacturers, this means allergen labelling is one of the few areas where a single label approach can work across both markets.

The Mustard Exemption: A Divergence to Watch

In 2024, the EU amended FIC to clarify that certain highly refined mustard seed derivatives — where the allergenic protein has been removed through processing — do not need to be declared as allergens. Great Britain has not yet adopted this amendment. This means a product containing a refined mustard-derived emulsifier may not require allergen declaration in the EU, but still requires it in Great Britain. Food supplement businesses using such ingredients should check with their regulatory consultant before removing allergen declarations from UK labels.

For a complete guide to allergen labelling for food supplements, including Natasha's Law requirements for pre-packaged for direct sale (PPDS) products, see our dedicated article: Natasha's Law Compliant Labelling for Food Supplements: Complete 2026 Guide.

4. Nutrition Labelling: Identical Core Requirements, Diverging Voluntary Elements

Both the UK and EU require the same mandatory nutrition declaration on prepacked food supplements: energy (kJ and kcal), fat, saturates, carbohydrate, sugars, protein, and salt — presented per 100 g or 100 ml. Voluntary additional nutrients (such as vitamins, minerals, fibre, and monounsaturates) may be declared alongside the mandatory elements.

Nutrient Reference Values (NRVs)

For food supplements specifically, both the UK and EU use the same Nutrient Reference Values (NRVs) for vitamins and minerals as set out in Annex XIII of FIC. These values — for example, Vitamin C at 80 mg, Vitamin D at 5 µg, and Iron at 14 mg — are used to express the percentage of the NRV provided per serving. As of 2026, the UK and EU NRVs remain identical, meaning a single nutrition table can satisfy both markets for vitamin and mineral declarations.

Nutri-Score: EU Voluntary, Not Applicable in GB

Several EU member states (France, Germany, Belgium, Netherlands, Luxembourg, Spain, and Switzerland) have adopted Nutri-Score as a voluntary front-of-pack nutrition labelling system. Nutri-Score is not used in Great Britain, where the FSA uses the Traffic Light system (Reference Intake labelling). Food supplement businesses exporting to EU markets should be aware that Nutri-Score is voluntary but may be expected by retailers in certain member states.

5. Health Claims: Two Registers, Growing Divergence

Health and nutrition claims on food supplements are tightly regulated in both the UK and EU. Both systems require that any claim made on a label must be authorised and appear on an official register. At the point of Brexit (1 January 2021), the two registers were identical — the UK simply adopted all EU-authorised claims into the Great Britain Nutrition and Health Claims (GBNHC) Register.

Since then, however, the two registers have begun to diverge. New claims approved by EFSA after 1 January 2021 are not automatically valid in Great Britain. Similarly, any claims approved by the UK Health and Nutrition Claims Committee (UKHNCC) are not automatically valid in the EU. Businesses must check both registers when making claims on products sold in both markets.

For a detailed guide to making compliant health claims on food supplement labels, see our article: Understanding Health Claims for Food Supplements: UK Compliance Guide.

6. The "Not for EU" Label: When Is It Required?

The "Not for EU" designation is one of the most misunderstood aspects of post-Brexit food labelling. It is not a blanket requirement for all GB food products. It applies in two specific circumstances:

Circumstance 1: Products Containing Non-EU-Compliant Ingredients

If a food supplement contains an ingredient that is permitted in Great Britain but not authorised in the EU, the product cannot legally be sold in the EU and should be labelled "Not for EU" to prevent it from entering the EU single market via Northern Ireland. Examples of ingredients currently permitted in GB but banned or not authorised in the EU include:

• Titanium dioxide (E171) — banned as a food additive in the EU since August 2022 following an EFSA safety assessment. As of 2026, E171 remains permitted in Great Britain, though the FSA has indicated it is likely to follow the EU position. Products containing E171 sold in GB should carry "Not for EU" if they are also shipped to Northern Ireland.
• Novel foods not authorised by EFSA — if a novel food ingredient has received GB authorisation from the FSA but not EU authorisation from EFSA, products containing it cannot be sold in the EU.
• Certain food additives — where GB and EU permitted lists have diverged following independent regulatory reviews.

Circumstance 2: Products of Animal Origin

Under the Windsor Framework, food products of animal origin shipped from Great Britain to Northern Ireland require "Not for EU" labelling. This is because Northern Ireland remains part of the EU single market for goods, and products of animal origin are subject to strict EU sanitary and phytosanitary (SPS) controls. The "Not for EU" label ensures these products remain in Northern Ireland and do not cross the border into the Republic of Ireland and the wider EU market.

The categories of animal-origin products subject to this requirement include:

• Meat and meat products — required since October 2023
• Dairy products — required since October 2024
• Fish and seafood products — required since July 2025
• Eggs and egg products
• Honey
• Composite products containing the above (e.g., protein bars, meal replacement products containing whey, collagen, or fish oil)

For food supplement manufacturers, this means that products containing whey protein, collagen (bovine or marine), fish oil, or other animal-derived ingredients that are shipped from GB to Northern Ireland must carry "Not for EU" labelling.

Important: If your food supplement uses only plant-based ingredients that are fully authorised in both the UK and EU, and you are not shipping to Northern Ireland, the "Not for EU" label is not required. Applying it unnecessarily may confuse consumers and retailers in EU markets where you are legally entitled to sell.

7. Northern Ireland: The Dual Market Access Zone

Northern Ireland occupies a unique position in the post-Brexit food labelling landscape. Under the Windsor Framework (which replaced the Northern Ireland Protocol), Northern Ireland remains aligned with EU food law for goods. This means:

• Food products sold in Northern Ireland must comply with EU FIC, not GB FIR 2014
• Labels must carry a Northern Ireland or EU business address
• EU health claims register applies (not the GB register)
• EU food additive and novel food permitted lists apply
• Products of animal origin from GB require "Not for EU" labelling before entering NI

The Windsor Framework also created the "Dual Market Access" scheme, which allows registered businesses in Northern Ireland to sell goods meeting either GB or EU standards within Northern Ireland. This makes Northern Ireland a valuable distribution hub for businesses that sell in both markets.

8. Key Ingredient-Level Divergences Affecting Food Supplements

Beyond labelling rules, the permitted ingredient lists for food supplements are diverging between the UK and EU. The following are the most significant current divergences for food supplement manufacturers:

9. Practical Guidance: Selling in Both Markets

For food supplement businesses that sell in both Great Britain and the EU, the most efficient approach is to design labels that satisfy both sets of requirements simultaneously, rather than maintaining entirely separate label versions. The following strategies minimise compliance risk and label management overhead:

Dual-Address Format

Include both a UK business address and an EU distributor or importer address on the same label. This satisfies the GB requirement for a UK address and the EU requirement for an EU member state address.

Use EU-Compliant Ingredients Throughout

Where possible, formulate products using ingredients that are authorised in both the UK and EU. This avoids the need for "Not for EU" labelling and simplifies market access. Avoid ingredients on the EU banned list (such as E171) unless you are exclusively selling in Great Britain.

Check Both Health Claims Registers

Before making any health or nutrition claim, verify that the claim is authorised on both the GBNHC Register (for GB sales) and the EU Register (for EU sales). Do not assume that a claim valid in one market is valid in the other.

Monitor Regulatory Divergence Actively

The UK and EU are updating their food laws independently and at different speeds. Subscribe to FSA and EFSA update services, and review your labels at least annually against both sets of requirements. The FSA website and EFSA website both publish regulatory updates and guidance.

Use Automated Compliance Checking

Manual label reviews across two regulatory systems are time-consuming and error-prone. label-checker.com checks your food supplement labels against both UK and EU requirements simultaneously — including allergen declarations, health claims, mandatory elements, and ingredient authorisation status — in a single workflow. With 30+ years of food industry expertise built into our AI engine, we catch the divergences that manual review misses.

Frequently Asked Questions

Do all UK food products need a "Not for EU" label after Brexit?

No. The "Not for EU" label is only required in two specific circumstances: (1) when a product contains ingredients that are permitted in Great Britain but not authorised in the EU (such as titanium dioxide E171), or (2) when a product of animal origin (meat, dairy, fish, eggs, honey, or composite products containing these) is shipped from Great Britain to Northern Ireland. Products using only EU-compliant ingredients and sold directly to EU member states (not via Northern Ireland) do not require "Not for EU" labelling.

Can I use the same label for UK and EU markets?

In many cases, yes — if you design the label carefully. You can include both a UK and EU business address, use ingredients authorised in both markets, and make only claims that appear on both the GBNHC Register and the EU Register. The main areas where separate labels are typically needed are: business address (if you only have a UK address), health claims that differ between registers, and products containing ingredients permitted in one market but not the other.

Are the 14 allergens the same in the UK and EU?

Yes. Both the UK and EU require the same 14 major allergens to be declared and emphasised in the ingredient list. The only current divergence is a 2024 EU amendment that exempts certain highly refined mustard-derived derivatives from allergen declaration — Great Britain has not yet adopted this exemption, so UK labels must still declare these.

Are UK and EU health claims registers the same?

They started as identical (the UK adopted all EU-authorised claims as of 1 January 2021) but are now diverging. New claims approved by EFSA after Brexit are not automatically valid in Great Britain, and any claims approved by the UKHNCC are not automatically valid in the EU. Always check both registers before making claims on products sold in both markets.

Does Northern Ireland follow UK or EU food labelling rules?

Northern Ireland follows EU food labelling rules under the Windsor Framework. Products sold in Northern Ireland must comply with EU FIC, carry a Northern Ireland or EU business address, and use ingredients authorised under EU law. Products of animal origin shipped from Great Britain to Northern Ireland must carry "Not for EU" labelling.

What happens if I sell a product in the EU that contains titanium dioxide (E171)?

Titanium dioxide (E171) has been banned as a food additive in the EU since August 2022. Selling a product containing E171 in the EU is illegal and may result in product seizure, recall, and regulatory enforcement action. In 2025, the EU's RASFF system flagged UK food supplements containing E171 as non-compliant. If your products contain E171, they must not be sold in the EU or in Northern Ireland without reformulation.

Check Your Labels for UK and EU Compliance

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