The producer must be clearly identified – new labelling requirements for food products

On 5 August 2026, a draft regulation by the Minister of Agriculture and Rural Development was submitted for review and public consultation, amending the regulation on the labelling of specific types of foodstuffs. The draft introduces significant changes for businesses marketing products under their own brands.

What is the current situation?

Under Regulation (EU) No 1169/2011, mandatory information on food labelling includes the name or business name and address of the food business operator. The Regulation specifies that the entity responsible for food information is the entity under whose name or business name the foodstuff is placed on the market or – if that entity does not operate within the EU – the importer of the foodstuff into the EU.

In practice, this means that the labelling of a food product may include the details of the owner of the retail chain under whose brand the food product is placed on the market. In such cases, the retail chain bears responsibility for the labelling.

What does the proposed regulation change?

The aim of the amendment to the regulation is to establish a national obligation in an area not yet regulated at EU level.

If a prepackaged food product is labelled with the business name of a food business operator who did not manufacture the product but placed it on the market through retail trade, the labelling must additionally state: the business name and address of the actual manufacturer or – if the manufacturer does not operate within the EU or the EEA – the business name and address of the importer placing the product on the market within the EU’s territory.

This information must be preceded by the term ‘Producer’ or ‘Importer into the EU market’. The draft also sets out the graphic requirements for the information’s presentation: a white background, a black font no smaller than that used for the distributor’s details, and the whole space enclosed in a black rectangular box covering at least 50% of the area of the food product’s trademark.

Exemptions: The new obligation will not apply to foodstuffs placed on the market under regulations in force in another EU Member State or in Turkey, nor to products originating from an EFTA/EEA country and placed on the market under regulations in force in that country.

When will the draft come into force and who is most affected by it?

The draft is currently undergoing public consultation and the opinion-gathering process; this is due to conclude in early September 2026.

According to the draft, the regulation is due to enter into force six months after the date of its publication.

Please note that the draft has direct implications for retail chains selling own-brand products, contract manufacturers (including manufacturers of food supplements), private-label brand owners, and packaging designers. Given the risk of challenges at EU level, the further course of the legislative process requires close monitoring. Should you have any questions regarding the impact of the proposed changes on your business, please do not hesitate to contact our Life Sciences team.