Short answer: most food markets ask for the same core on a prepacked label: the name of the food, ingredients with allergens identified, net quantity, a lot mark, a date, storage and use instructions where needed, and a responsible business's name and address. What changes between destinations is shorter: language, how the date is expressed, the nutrition panel, which allergens must be named and how, whose name and address appear, and which claims are allowed. Those fields set how many artwork versions you need, their cost and lead time. Design the core once, keep the variables in a per-market zone, and check each version before print.
The mandatory categories most markets require in some form
The common baseline is the Codex Alimentarius General Standard for the Labelling of Prepackaged Foods (CXS 1-1985), marked amended in 2026. Its mandatory section has eight headings: name of the food; list of ingredients; net contents and drained weight; name and address; country of origin; lot identification; date marking and storage instructions; and instructions for use Codex Alimentarius, CXS 1-1985, section 4.
Codex is a reference; national law decides. Regulation (EU) No 1169/2011 lists twelve mandatory particulars, including "a nutrition declaration" EUR-Lex, Regulation (EU) No 1169/2011, Article 9. In the US, 21 CFR Part 101 applies; nutrition labelling covers "all products intended for human consumption and offered for sale unless an exemption is provided" eCFR, 21 CFR 101.9. The Gulf states have GSO 9:2022, Labeling of prepackaged food stuffs, listed as active GSO, GSO 9:2022.
The stable core: identity, ingredients, allergens, net quantity, batch
Five elements barely vary by market and belong in the master artwork:
- Product identity. A true name of the food, not only a brand. Codex's general principle is that a label must not be "false, misleading or deceptive" Codex Alimentarius, CXS 1-1985, section 3.1.
- Ingredients. The recipe does not change by market; the list's language may.
- Allergen presence. Whether it contains milk or sesame is a recipe fact; how that is shown varies.
- Net quantity. Codex requires metric units; the figure is stable, its position varies.
- Lot mark. Coded at filling, it links the pack to production records and should match the lot references in the document set behind one shipment.
Codex also asks that labels stay attached and be "clear, prominent, indelible and readily legible" Codex Alimentarius, CXS 1-1985, section 8.1. The EU sets a minimum x-height of 1.2 mm, or 0.9 mm where the largest surface is under 80 cm² EUR-Lex, Regulation (EU) No 1169/2011, Article 13.
The variables: language, date, allergens, nutrition and additives
The table compares four reference points, not any market's full law.
| Field | Codex CXS 1-1985 | EU, Regulation 1169/2011 | United States, federal | Dubai, UAE |
|---|---|---|---|---|
| Language | Supplementary label allowed where the original language is not acceptable (8.2) | Language "easily understood" where marketed; member states may require official languages (Art. 15) | English; if any foreign language is used, required information also in that language (21 CFR 101.15) | Arabic mandatory, English optional (Dubai Municipality) |
| Date | Competent authority decides the day-month-year sequence (4.7.1) | Minimum durability or "use by" date (Art. 9) | Quality dates ("Best if Used By") voluntary; infant formula must carry a "Use by" date; check state rules (FDA) | Day/month/year, or month/year above three months' shelf life (trade.gov, secondary) |
| Allergens | Named foods always declared; others by national risk assessment (4.2.1.4–5) | 14 Annex II entries, emphasised in the ingredients (Art. 21) | Nine major allergens, "Contains" statement or parentheses (FDA) | Recheck against UAE.S 9 |
| Nutrition | Separate Codex guideline | Energy and six nutrients per 100 g or 100 ml (Arts. 30, 32) | "Nutrition Facts", per serving (21 CFR 101.9) | Recheck |
| Responsible party | Manufacturer, packer, distributor, importer, exporter or vendor (4.4) | Marketing operator, or the EU importer (Art. 8) | Manufacturer, packer or distributor, e.g. "Distributed by" (21 CFR 101.5) | Recheck |
| Net quantity position | Not fixed | Legibility rules apply | Principal display panel, bottom 30 percent (21 CFR 101.7) | Recheck |
"Recheck" means not confirmed from a primary source for this article.
Language most often forces a separate version. In the US, adding Arabic to a US pack means giving all required US information in Arabic too eCFR, 21 CFR 101.15; Dubai Municipality's guidance makes Arabic the mandatory language Dubai Municipality, IRS food label assessment guide.
Date expression. Where only numbers are used, Codex leaves the order of day, month and year to the competent authority and suggests keys such as DD/MM/YYYY Codex Alimentarius, CXS 1-1985, section 4.7.1, so "03/04/2027" means different days in different places. In the US, FDA states that "Except for infant formula, manufacturers are not required by Federal law or regulation to place quality-based date labels on packaged food", and that "Best if Used By" marks best flavour and quality, not safety FDA, cutting food waste and maintaining food safety. Infant formula is the product-specific exception: its label must include a "Use by" date Federal Register, FSIS and FDA, food date labeling, 4 December 2024. That notice asks about local or state requirements, so check the destination state and the buyer's specification. The date is coded at filling; its wording and format key are artwork.
Allergens. Codex always requires cereals containing gluten, crustacea, egg, fish, peanut, milk, sesame and specified tree nuts, and leaves mustard, soybean, celery, lupin and others to national risk assessment. The EU's Annex II has 14 entries, including mustard, celery, lupin, molluscs and sulphites, emphasised in the ingredients list EUR-Lex, Regulation (EU) No 1169/2011, consolidated text, Annex II. Food Standards Agency guidance for England, Wales and Northern Ireland says "only the 14 allergens are required to be declared as allergens by food law" and they "must be emphasised each time they appear in the ingredients list" GOV.UK, allergen guidance for food businesses. The US names nine major allergens, sesame included from 1 January 2023, declared in parentheses such as "flour (wheat)" or in a "Contains" statement FDA, food allergies. Mustard therefore needs emphasis in the EU and UK but is not a US major allergen.
Codex's precautionary ("may contain") labelling guidelines state that "The decision to use PAL should be based on the findings of a risk assessment" Codex Alimentarius, CXS 1-1985, precautionary allergen labelling annex. National rules differ; do not use it as a blanket disclaimer.
Nutrition and additives. The same analysis supports an EU panel per 100 g EUR-Lex, Regulation (EU) No 1169/2011, consolidated text, Articles 30 and 32 and a US panel per serving: different artwork. Codex names additives by functional class plus specific name or International Numbering System number Codex Alimentarius, CXS 1-1985, section 4.2.4.3; markets apply their own conventions, so the words can change when the additive does not.
Importer and responsible-party details
Every market wants a responsible party on the label, usually a local one. In the EU it is the operator under whose name the food is marketed or, if that operator is outside the Union, "the importer into the Union market" EUR-Lex, Regulation (EU) No 1169/2011, Article 8. In the US the label must "specify conspicuously the name and place of business of the manufacturer, packer, or distributor", qualified with a phrase such as "Distributed by" where that company did not make the food eCFR, 21 CFR 101.5.
One country's distributor cannot appear on another's pack, so keep this block out of the shared design and have each importer confirm in writing its legal name and address, consistent with the shipping documents; see reading a bill of lading.
Claims: the field most likely to be refused
Mandatory fields are defined by lists; claims by permission. In the EU, nutrition claims "shall only be permitted if they are listed in the Annex", and health claims are prohibited unless authorised and included in the lists of authorised claims EUR-Lex, Regulation (EC) No 1924/2006, Articles 8 and 10. Claims also sit on the front panel, in colour, beside the brand: the costliest place to change. Treat every claim, including "natural", "no additives" and wording about body functions, as market-specific until checked.
Over-labelling and stickering: when it is acceptable
Codex allows a sticker where the original language is not acceptable: "a supplementary label containing the mandatory information in the required language may be used instead of relabelling", reflecting the original label fully and accurately Codex Alimentarius, CXS 1-1985, section 8.2. A US government country guide reports that in the UAE "Arabic stickers are accepted", adding that stickers must be approved by UAE authorities before use ITA, UAE labelling and marking requirements; confirm with the authority before relying on it.
Stickers suit adding a language or local importer details. They tend to fail when they hide or contradict original information such as a claim or date, can peel off, or where the original carries a claim or format the market rejects or printed text is required.
Each label version can have its own print minimum and plate cost; include these in the packing and landed-price comparison.
An artwork workflow with an approval gate before print
- Freeze the recipe and purchasing specification. If the formulation moves, ingredients, allergens and nutrition move with it.
- Build the master artwork with the stable core, laid out to the strictest type size and net quantity position among your markets.
- Reserve a per-market zone for language text, date wording, nutrition panel, responsible party and any claims.
- Write a market variable sheet for each market: languages, date format, allergen list and emphasis, nutrition format, responsible party, permitted claims and sticker acceptability, each with its source and date checked.
- Draft and check each version against its market, recording who checked it, against what and when.
- Approval gate. No plate, cylinder or print order until every version has passed and the brand owner has signed off in writing.
- Compare the printed proof with the approved file, define any inspection scope, then archive the evidence.
Getting a label checked before a print run
A check before print changes only files. Checkers include destination labelling consultants, the importer's regulatory team and, in some markets, the authority. Dubai Municipality's registration system includes a food label assessment: the applicant uploads the label artwork, non-compliance with the UAE standard is written as a remark, and the guide gives "5 working days" for registration and label assessment Dubai Municipality, IRS food label assessment guide. The guide cites UAE.S 9:2019 while the current Gulf regulation is GSO 9:2022; ask which edition applies. A check covers that version on that date; recheck if the importer, recipe or claim changes.
Worked example: one spice pack, three markets
Hypothetical teaching example. Names, costs and timings are invented; no market's full requirements are represented.
A brand owner prepares a 200 g pouch of curry blend containing mustard seed for an English-language EU member state, the United States and Dubai. The pouch uses shared colour plates, carrying the brand, photograph and a front badge reading "supports healthy digestion", plus one text plate per market.
| Element | Shared or per market | Why |
|---|---|---|
| Brand, photograph, English product name | Shared | Stable core |
| Net quantity at the bottom of the front | Shared | Placed to suit the US position rule everywhere |
| Ingredients with mustard | Per market | Emphasis in the EU; not a US major allergen; Arabic for Dubai |
| Nutrition panel | Per market | Per 100 g versus per serving |
| Date wording and format key | Per market | Sequence and wording differ |
| Responsible party | Per market | Different importer or distributor |
| Front badge claim | Shared, by mistake | Printed in the colour plates |
| Planned item | CU |
|---|---|
| Master artwork | 1,500 |
| Three market adaptations at 400 | 1,200 |
| Shared colour plate set | 1,800 |
| Three text plates at 250 | 750 |
| Three pre-print checks at 350 | 1,050 |
| Total | 6,300 |
Planned lead time: 10 working days of artwork, 5 of checks, 7 for plates and 10 for print, 32 in all.
Suppose the checks are skipped. After printing, the EU importer's adviser rejects the badge as an unauthorised health claim. Sitting in the shared colour plates, it alone forces a full re-print: redesign 300 CU, a new colour plate set 1,800 CU and 10,000 EU pouches scrapped at 0.09 CU, 900 CU. That is 3,000 CU extra, 1,950 CU more than the checks. Time: 27 days, plus 3 for redesign, 7 for plates and 10 for print, is 47 working days, 15 later than planned.
An error in a per-market field, such as the importer's address, costs 100 CU of redesign, one 250 CU text plate and the same 900 CU of scrap: 1,250 CU. The delay is similar; the cost is not.
Common mistakes
- Treating Codex as the destination's law.
- Putting a claim, importer name or date format in the shared design.
- Assuming one allergen list works everywhere.
- Adding a second language without checking what it triggers in each market.
- Using a sticker to cover a problem rather than add information.
Limits and what to recheck
This compares a few named sources rechecked on 17 October 2026; markets not named here have their own rules. Labelling law is amended often; the latest consolidated EU text found for this review is dated 1 April 2025. Product-specific standards, halal, organic and origin marks are outside scope. Before print, confirm current requirements with the destination authority, the importer's regulatory team or a labelling specialist. More in Product Quality & Food Trade.
FAQ
What must be on a food label? Under the Codex baseline: name, ingredients, net contents, a responsible business's name and address, country of origin where omission would mislead, a lot mark, date marking and storage instructions, and instructions for use where needed. National law sets the detail.
Are allergen labelling rules the same in every country? No. The EU and the UK (under retained or applicable food information law) name 14 allergens and require emphasis in the ingredients; the US names nine and accepts a "Contains" statement or parentheses. Other markets differ.
Can I use a sticker instead of reprinting? Often, to add a language or local details where the market accepts it. A sticker should not hide original information and does not cure a non-compliant claim.
Next step
Create a market-variable sheet before artwork approval: one row per destination, with source, check date and named approver for language, dates, allergens, nutrition, responsible party, claims and stickers. Do not release plates or print until the importer or a labelling specialist confirms the version in writing.
Resources
- Codex Alimentarius (FAO/WHO) — General Standard for the Labelling of Prepackaged Foods, CXS 1-1985 (amended 2026) — https://www.fao.org/fao-who-codexalimentarius/sh-proxy/fr/?lnk=1&url=https%3A%2F%2Fworkspace.fao.org%2Fsites%2Fcodex%2FStandards%2FCXS+1-1985%2FCXS_001e.pdf (accessed 23 September 2026)
- EUR-Lex — Regulation (EU) No 1169/2011 on the provision of food information to consumers — https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32011R1169 (accessed 17 October 2026)
- EUR-Lex — Regulation (EU) No 1169/2011, consolidated text of 1 April 2025 — https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02011R1169-20250401 (accessed 17 October 2026)
- EUR-Lex — Regulation (EC) No 1924/2006 on nutrition and health claims made on foods — https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32006R1924 (accessed 17 October 2026)
- eCFR — 21 CFR 101.5, Food; name and place of business of manufacturer, packer, or distributor — https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.5 (accessed 17 October 2026)
- eCFR — 21 CFR 101.7, Declaration of net quantity of contents — https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.7 (accessed 17 October 2026)
- eCFR — 21 CFR 101.9, Nutrition labeling of food — https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.9 (accessed 17 October 2026)
- eCFR — 21 CFR 101.15, Food; prominence of required statements — https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.15 (accessed 17 October 2026)
- US Food and Drug Administration — Food allergies — https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/food-allergies (accessed 17 October 2026)
- US Food and Drug Administration — How to Cut Food Waste and Maintain Food Safety — https://www.fda.gov/food/consumers/how-cut-food-waste-and-maintain-food-safety (accessed 17 October 2026)
- Federal Register (FSIS and FDA) — Food Date Labeling, request for information, 4 December 2024 — https://www.federalregister.gov/documents/2024/12/04/2024-27810/food-date-labeling (accessed 17 October 2026)
- GOV.UK (Food Standards Agency) — Allergen guidance for food businesses — https://www.gov.uk/government/publications/allergen-guidance-for-food-businesses/allergen-guidance-for-food-businesses (accessed 17 October 2026)
- GCC Standardization Organization — GSO 9:2022 Labeling of prepackaged food stuffs — https://www.gso.org.sa/store/standards/GSO:810825/GSO%209:2022?lang=en (accessed 17 October 2026)
- Dubai Municipality — How to apply for Food Label Assessment on the IRS system — https://www.dm.gov.ae/wp-content/uploads/2023/12/IRS-eng.pdf (accessed 23 September 2026)
- International Trade Administration (US) — United Arab Emirates labeling/marking requirements — https://www.trade.gov/knowledge-product/united-arab-emirates-labelingmarking-requirements (accessed 17 October 2026)
