Skip to content

New EU Labeling Law: Omission of Food Additives and Enzymes from the List of Ingredients under Regulation (EC) No. 1169/2011

Sonja Schulz

Food additives and food enzymes were not regarded as ingredients under the Labeling Directive 2000/13/EC if they were a carry-over substance or used as processing aids and were therefore not allowed to be included in the list of ingredients. With the new EU labeling law, that has been introduced by the Food Information Regulation (EU) No. 1169/2011, this rule has been changed. Since 13 December 2014, it is generally admitted to inform the consumer about the presence of such substances – at least if it is not misleading in the specific circumstances of the case. Also, the traditional difficulty of the delimitation of food enzymes and food additives from processing aids has developed. A Guidance Document tackles the categorization of food enzymes and allows conclusions for the delimitation of food additives and processing aids, as well. At least with regard to degraded or denatured substances, the Guidance Document contributes to more legal certainty.

Sonja Schulz, LL.M. is partner at ZENK Rechtsanwälte in Hamburg, Germany, a law firm specialised in food industry. She advises in all areas of national and European food and competition law. E-mail:


Lx-Number Search

(e.g. A | 000123 | 01)

Export Citation