Dutch lawyers for food product Labelling

Published on 30 August 2022 · Last updated 28 October 2026

Having a food label checked by a Dutch lawyer makes sense before you launch a product in the Netherlands, change a recipe or receive a finding from the Netherlands Food and Consumer Product Safety Authority (NVWA). Food labels must meet Regulation (EU) No 1169/2011 on food information to consumers and Dutch rules that require, among other things, the Dutch language (Article 3 Food Information Commodities Decree).

This page is for food producers, brand owners, private label suppliers and importers that sell prepacked or non-prepacked food on the Dutch market. It explains who is responsible for the label, which particulars are mandatory, how allergens must be shown, which claims are allowed and what the NVWA can do. Planning a launch or relabelling in the Netherlands? Have your label reviewed by our food and product lawyers.

Who is responsible for a food label in the Netherlands?

The food business operator under whose name the food is marketed. If that operator is not established in the EU, the importer into the Union market is responsible (Article 8(1) Regulation 1169/2011). That operator must ensure the information is present and accurate (Article 8(2)).

Distributors and retailers that do not affect the food information must not supply food they know or presume to be non-compliant, and may not change the information in a way that misleads consumers (Article 8(3) and (4)). For a private label product this means the retailer whose brand is on the pack is usually responsible, even if the manufacturer designs the label. Your supply agreement should say who drafts, checks and pays for corrections.

Which particulars must a food label contain?

Twelve mandatory particulars apply to prepacked food, from the name of the food to the nutrition declaration. They must be easily visible and clearly legible, with a minimum x-height of 1.2 mm, or 0.9 mm on packs whose largest surface is under 80 cm² (Articles 9 and 13 Regulation 1169/2011).

Mandatory particular	Article 9(1)
Name of the food	(a)
List of ingredients	(b)
Allergens listed in Annex II	(c)
Quantity of certain ingredients or categories of ingredients	(d)
Net quantity	(e)
Date of minimum durability or “use by” date	(f)
Special storage conditions or conditions of use	(g)
Name or business name and address of the responsible operator	(h)
Country of origin or place of provenance, where Article 26 requires it	(i)
Instructions for use where needed	(j)
Alcoholic strength for drinks above 1.2% by volume	(k)
Nutrition declaration	(l)

The nutrition declaration covers energy value and the amounts of fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1)). Each food must also carry a lot marking that identifies its batch, unless the label shows a date with at least day and month; in the Netherlands this EU rule is laid down in Articles 4 and 5 of the Food Information Commodities Decree.

Must a food label in the Netherlands be in Dutch?

Yes. Member States may require the mandatory information in one or more official EU languages, and the Netherlands requires at least Dutch for the mandatory food information (Article 15 Regulation 1169/2011; Article 3 Food Information Commodities Decree).

A label in English or German alone is therefore not enough on the Dutch market, even if Dutch consumers understand it. Multilingual labels are allowed (Article 15(3)). Importers often solve this with a Dutch sticker, which must still meet the legibility rules and may not hide other mandatory information (Article 13(1)).

How must allergens be shown on food labels?

The 14 groups of substances in Annex II, such as cereals containing gluten, milk, eggs, nuts, peanuts and sesame, must be named in the list of ingredients and emphasised by a typeset that clearly distinguishes them, for example bold text (Article 21(1) Regulation 1169/2011).

For non-prepacked food, such as products sold loose in a bakery or served by a caterer, allergen information is always mandatory (Article 44(1)(a)). In the Netherlands it must be available in writing or electronically, or may be given orally if staff can always provide it correctly, it is available in writing for staff and the NVWA, and a visible notice tells consumers to ask (Articles 2 and 3 Commodities Regulation on allergen information for non-prepacked food). “May contain” statements are voluntary information and may not mislead (Article 36).

Which nutrition, health and origin claims are allowed?

Only claims that are not misleading and that comply with the specific EU rules. Nutrition and health claims must meet Regulation (EC) No 1924/2006, and the Netherlands prohibits acting contrary to its provisions (Article 2(4) Food Information Commodities Decree).

General food information may not mislead about the nature, composition, origin or method of production, or attribute effects the food does not have (Article 7 Regulation 1169/2011). If you state an origin that differs from the origin of the primary ingredient, you must also give the origin of that ingredient or state that it is different, under the implementing rules (Article 26(3)). Sustainability claims on food are also subject to the Dutch rules on green claims; see our page on greenwashing under Dutch law.

What happens if a label does not comply?

The NVWA supervises food labelling. The Food Information Commodities Decree prohibits acting contrary to the EU labelling rules (Article 2(6)), so breaches are enforced under the Commodities Act, which allows administrative fines of up to the sixth category per violation (Article 32a Commodities Act).

In practice the consequences include an order to correct or relabel stock, a fine, and in case of an undeclared allergen often a withdrawal or recall, because the food may then be unsafe for allergic consumers. The fine procedure and your right to give your view are explained on our page on NVWA enforcement and administrative fines; recalls on our page on recalls under Dutch law.

Practical example: a Belgian snack brand entering Dutch supermarkets

Suppose a Belgian producer supplies crisps under the producer’s own brand to a Dutch supermarket chain. The pack has French and Dutch text, but one flavour adds a mustard seasoning that is not emphasised in the ingredient list.

The Belgian producer is the responsible operator (Article 8(1)). Before delivery, a review finds the missing allergen emphasis (Article 21) and a nutrition table without salt (Article 30(1)); both are corrected on a reprint. The supply agreement with the chain states who bears relabelling costs and who handles any NVWA questions, so a later finding in store does not lead to a dispute about responsibility.

When do you need a lawyer for food labelling?

Before a launch or recipe change in the Netherlands, when you make health, nutrition or sustainability claims, when a retailer or importer asks for warranties on the label, and when the NVWA finds a labelling issue or announces a fine.

MAAK Advocaten in Amsterdam reviews labels and claims for food companies, drafts the labelling clauses in supply and private label agreements, and assists with NVWA findings, objections and appeals. Martin Krüger is your contact for product regulation; see our product regulation attorney page, our page for food safety lawyers in the Netherlands and our page on food and commodity law violations.

Frequently asked questions about food labelling in the Netherlands

Does a food label in the Netherlands have to be in Dutch?

Yes. The mandatory food information must be given at least in Dutch (Article 3 Food Information Commodities Decree, based on Article 15(2) Regulation 1169/2011). Other languages may be added.

How many allergens must be declared on a food label?

The 14 groups listed in Annex II of Regulation 1169/2011, emphasised in the list of ingredients, for example in bold (Article 21).

Who is responsible for the label of imported food?

The operator under whose name the food is marketed or, if that operator is not established in the EU, the importer into the Union market (Article 8(1) Regulation 1169/2011).

Must allergen information be given for food sold loose?

Yes. For non-prepacked food, allergen information is always mandatory. In the Netherlands it may be given in writing, electronically or orally under the conditions of the Commodities Regulation on allergen information for non-prepacked food.

What is the minimum font size on a food label?

An x-height of at least 1.2 mm, or 0.9 mm if the largest surface of the pack is smaller than 80 cm² (Article 13(2) and (3) Regulation 1169/2011).

Primary sources

Dutch statutes are only officially available in Dutch, on wetten.overheid.nl. Judgments can be found on rechtspraak.nl by their ECLI number. Legal position checked on 28 October 2026.