Multi-market food product labels – one size DOES NOT fit all

13 November 2025 | Corani Jankowitz, Regulatory Affairs Advisor and Sharon Morey, Regulatory Affairs Manager

In today’s manufacturing landscape optimisation is key, especially with sustainability being at the forefront of emerging legislation. When supplying a global market or looking to simply lift-and-shift food products, the question always arises of whether a single label can be used across multiple markets or which countries can be grouped together on a product label or packaging. All to manage minimum order quantities and simplify the supply chain.

However, individual approaches to multi-market labelling do not fit all food products in all markets. Reasons for this include, for example, that harmonised and agglomerated legislation is not always universal, and there can also be cross market clashes between EU harmonised legislation, the UK and other markets outside of the EU.

Harmonised legislation – not always universal

Although some markets follow agglomerated legislation, like the Gulf Cooperation Council (United Arab Emirates, Oman, Bahrain, Qatar, Kuwait and Saudi Arabia), and in the European Union there is harmonised legislation for areas such as regulated products, nutrition and health claims and food information, there may also be some additional national legislation that is unique to a specific market within that legislative framework.

Although the vast majority of food information labelling requirements are harmonised at an EU level by the Food Information to Consumers Regulation (FIC), it allows for national measures to be implemented in several areas not specifically covered by the EU legislation.

For example:

• Poland has specific regulations for voluntary claims such as ‘suitable for vegetarians’, ‘GMO free’, or ‘Polish product’, with the latter two requiring particular graphic symbols on the label.
• Germany requires the milk fat percentage to be declared for products with specific dairy designations, such as yoghurt and butter, whereas Austria does not have an equivalent requirement.
  • Similar rules apply in Sweden and Denmark for cheese and cheese products, including pre-packaged cheeses, which must be labelled with the total fat content stated as a percentage either as part of the product name or directly connected to it.
• Italy requires all pre-packaged foods to display packaging disposal information, including material identification codes and collection instructions.
• Spain regulates “handcraft made” or “artisanal” claims at the regional level, meaning compliance depends on the requirements in each autonomous community (e.g., Galicia, Aragón, Andalucía).

The area of nutrition information labelling or indications of nutritional content can vary a lot. For example, in Abu Dhabi, United Arab Emirates (UAE), a public health initiative introduced the Nutri-Mark to address rising obesity and diet-related diseases. The Nutri-Mark became mandatory in Abu Dhabi from June 2025, similar to the Nutri-Score mark in some EU Markets, and aims to provide clear nutritional information to consumers. This currently applies only to breads and pastries, food targeted to children, cooking oil, beverages and dairy products, and is in addition to the standard Gulf Cooperation Council (GCC) requirements.

These examples are provided for illustrative purposes only and are by no means a definitive list.

Cross market clashes

When considering labelling compliance for the UK and other markets outside of the EU, some of the requirements may be misaligned to a degree that would make dual market packaging challenging.

GCC requirements include mandatory allergen 'contain' statements, production and expiry dates, source declarations for emulsifiers and gelatine (halal compliance), prohibition of alcohol references, specific flavour naming, country of origin, and explicit labelling of oil type and hydrogenation status. In addition, if you have English on pack, it needs to be identical to the Arabic.

China has the same requirement that any foreign language on pack needs to correspond with the mandatory Mandarin text. Only eight of the EU-recognised allergens require labelling in China. Malaysia on the other hand only requires nutritional declarations for specified food products. In contrast, India requires the logo from the Foods Safety and Standards Authority of India (FSSAI) and the license number of the importer to be positioned on the principal display panel of the food package. There is also a requirement to indicate a product’s non-vegetarian or vegetarian status.

In South America, each country must transpose regional requirements into its national law. In Brazil, for instance, the nutrition information table must include added sugars, trans fats and sodium. Whilst in Chile it has been mandatory to include warning labels on food products that are high in sugar, salt, saturated fat or calories. These black octagonal “stop sign” labels must be placed on the front of food product labels as part of a comprehensive public health initiative introduced in 2016.

English-speaking markets – English is not always the same

A common misconception exists that all English-speaking countries follow the same labelling requirements. This is however not always the case.

South Africa sub-classifies vegetarian claims (e.g., lacto, ovo, strict vegetarian, vegan) and has its own specific requirements for nutrition claims such as 'source of' and 'high in', with defined percentage thresholds. The compulsory nutrition table also differs slightly from the UK and EU, with dietary fibre being a mandatory nutrient of which the method of analysis needs to be indicated.

US requirements differ significantly from the UK and EU with regards to prescribed placement of certain mandatory label information elements. For example, the principal display panel must display the food name, whereas the EU FIC Regulation does not dictate this. There are also specific ingredient naming conventions, detailed net weight declaration rules (with both metric and imperial units), an absence of a mandatory date, and storage instructions and nutrition information must be displayed per serving size not per 100g, and the serving size for product types is determined by regulation.

Food labelling regulations in Australia differ from those in the UK in terms of both format and scope. From basic differences such as no requirement to use the heading ‘Ingredients’, to the key risk communication aspect of labelling (allergen declaration) which needs to be provided in two prescribed ways. Crucially, the list of declarable allergens also varies compared to the EU and UK and includes pinenuts but not mustard for example. There are different approaches to nutrition and health claims, too, with Australia having its own list of permitted claims and conditions for making them, including a requirement that any product making health claims must achieve a minimum score calculated based on its nutritional profile.

The bottom line

These examples, as well as language requirements that may be needed for labels in different markets, place a lot of pressure on the available space of any given food product label. So, whilst there may be some areas of label information or synergistic markets that would allow for simplifying and reducing the number of product labels needed for a global brand, a food business operator must take into consideration any additional or specific requirements for all target countries or regions to ensure compliance and avoid issues when placing the product onto their markets. Therefore, one size cannot fit all markets, and one approach to multi-market labelling does not fit all food products.

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