A food label is not just packaging. It is a legal document. In both the United States and the European Union, the rules about what must appear on a food label, where it must appear and how it must be worded are detailed, and they are different from each other. A label that is perfectly legal in Paris can be unsellable in Dallas, and the reverse is also true.
This is one of the most common and most expensive problems for food producers selling across the Atlantic. Labels have to be redesigned, stock has to be relabelled or reprinted, and shipments can be held or refused. The good news is that the differences are predictable. If you know where the two systems diverge, you can plan for them from the start, and often at very little cost.
This guide compares US and EU food labelling for pre packaged food, explains the differences that cause the most trouble, and gives you a checklist for adapting a label. It is a practical overview and not legal advice. Labelling law is detailed and changes over time, and different products have special rules, so always confirm the current requirements with the relevant authorities or a qualified adviser before you print.
Why labels cause so many problems
There are three reasons.
First, the two systems were built on different principles. US rules are set mainly by the Food and Drug Administration (FDA), with the US Department of Agriculture covering meat, poultry and some egg products. EU rules are set at European level, mainly through the Food Information to Consumers Regulation, and then applied in each member country, which can add language and national requirements.
Second, labels are checked at different moments. In the US, a label problem often shows up when the importer or a retailer reviews your product, or when the FDA inspects. In the EU, your importer is legally responsible as the business placing the food on the market, so they will check carefully before agreeing to buy.
Third, most producers design one label for their home market and only look at export rules later. By then the artwork, the packaging and often the stock have already been produced.
The mandatory information at a glance
Both systems require a set of core information, but the details differ. This list summarises the main items for pre packaged food.
Name of the food. United States: Statement of identity on the front of the pack. European Union: Legal name of the food, or a customary or descriptive name.
Net quantity. United States: Required, in US customary units and metric. European Union: Required, in metric units.
Ingredient list. United States: Required, in descending order by weight. European Union: Required, in descending order by weight, with allergens emphasised.
Allergens. United States: Nine major allergens must be declared. European Union: Fourteen allergens must be emphasised.
Nutrition information. United States: Nutrition Facts panel in the US format. European Union: Nutrition declaration per 100 g or 100 ml, in the EU format.
Business name and address. United States: Manufacturer, packer or distributor. European Union: Food business operator, or the importer for non EU food.
Country of origin. United States: Required for imported food. European Union: Required in specific cases, such as meat, honey and where its absence would mislead.
Date marking. United States: Not generally required by federal law for most foods, except infant formula. European Union: "Use by" or "best before" date required.
Language. United States: English (other languages may be added). European Union: Language of the country of sale.
Lot number. United States: Not generally required on the label but needed for traceability. European Union: Lot identification required.
Use this as a map, not a final answer. The exact rules for your product may differ, so check the current legislation for your category.
Difference 1: the nutrition panel
This is the difference most producers notice first, because the panels look very different.
The US Nutrition Facts panel is built around servings. It states the number of servings per container, a serving size in household measures such as cups or pieces with the metric weight alongside, and then the calories and nutrients per serving. It shows total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fibre, total sugars, added sugars and protein, along with certain vitamins and minerals, and percentage Daily Values. Serving sizes are set by regulation and based on amounts people typically eat, so you cannot simply choose your own.
The EU nutrition declaration is built around a standard quantity of 100 g or 100 ml. It must show energy in both kilojoules and kilocalories, fat, saturates, carbohydrate, sugars, protein and salt. It may also show amounts per portion, and other nutrients such as fibre, in addition to the per 100 g figures. Trans fat and added sugars are not part of the standard EU declaration, and the EU expresses sodium as salt.
What this means for you: you cannot convert one panel into the other with a simple copy and paste. Serving sizes differ, nutrients are different, and the values have to be calculated or tested against each system's rules. Rounding rules also differ. Budget for a recalculation of every product you plan to export.
Difference 2: allergens
Allergens are a safety issue, and both systems treat them seriously, but the lists are not the same.
The US list includes nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame was added more recently, so labels that predate that change may need updating.
The EU list includes fourteen allergens: cereals containing gluten (wheat, rye, barley, oats and related grains), crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites above a set threshold, lupin and molluscs.
The consequence is that a product can be fully compliant in one market and miss a required declaration in the other. A European product containing celery or mustard, for example, must highlight these in the EU, while a US label focuses on the US list. In the other direction, a US product must make sure its labels for Europe highlight every item on the EU list.
The way allergens are shown also differs. In the EU the allergens must be emphasised within the ingredient list, for example in bold, capitals or a different colour. In the US the producer can either show the allergen in the ingredient list in parentheses or add a separate "Contains" statement. Check which format works for your product, and make sure the cross contact wording ("may contain") is accurate and not used as a substitute for good practice.
Difference 3: units and measurements
Most of the visible differences here are straightforward.
Net quantity: the US requires both US customary units (ounces, pounds, fluid ounces) and metric. The EU requires metric.
Serving sizes: US panels use household measures with metric alongside. EU declarations use 100 g or 100 ml.
Energy: the EU requires kilojoules and kilocalories. The US uses calories.
Sodium versus salt: the US panel shows sodium in milligrams. The EU shows salt in grams.
Dates: formats and wording differ, and the US does not generally require best before dates for most foods.
Getting these wrong rarely looks serious, but a wrong unit or a missing conversion is one of the most common reasons a label is rejected at review.
Difference 4: nutrition and health claims
Both the US and the EU regulate claims such as "high in fibre", "low fat", "reduced sugar" or "supports the immune system", but they do it very differently.
In the US, nutrient content claims such as "low fat" or "good source of" must meet definitions set by the FDA, and health claims need authorisation or must meet specific rules. Claims like "natural" are not strictly defined for most foods, but are still checked for being misleading.
In the EU, claims are regulated more tightly. Nutrition claims must be on an approved list with set conditions, and health claims must be on a list of authorised claims. Many claims that are common on US packs, particularly health claims, are not permitted in the EU in the same form.
Take care with front of pack wording and marketing copy. A phrase that is acceptable on a US label can be illegal on a EU label, and the other way round. Review claims for each market separately, and remember that the claim also applies to your website and promotional material.
Difference 5: ingredients and additives
Rules on what you can put in food, and how you name it, are not identical.
In the EU, additives are identified by E numbers and the ingredient list must show their function group, such as "colour" or "preservative", alongside the name or number. Some food colours, including a group of azo dyes, must carry a warning on the label in the EU. In the US, additives are regulated separately, with their own approved lists and labelling conventions. Colours certified by the FDA have specific names, and some ingredients that are commonly used in one market are restricted or not permitted in the other.
If your recipe uses colourings, preservatives, sweeteners or processing aids, check each one against the destination market's rules before you commit to a label. A reformulation can be much more costly than a label change, so find this out early.
Difference 6: language and layout
EU rules require mandatory information in a language that consumers in the country of sale can easily understand, which generally means the official language of that country. A pack for sale in several countries may need multiple languages, and a pack in a country with more than one official language may need more than one. Minimum character sizes also apply to mandatory information on EU labels, so small packs can be a real design challenge.
The US requires English for the mandatory information, and other languages may be added. US rules also set specific placement and type size requirements for the statement of identity and net quantity, and require the Nutrition Facts panel to follow a set format.
For both markets, the practical advice is the same: involve the designer early and give them the rules before the artwork starts, not after.
Difference 7: origin and the responsible business
Both systems require the name and address of a responsible business on the label.
In the US, the name and place of business of the manufacturer, packer or distributor must appear. Imported food is also generally required to show its country of origin, which is enforced at the border by US Customs and Border Protection.
In the EU, the name and address of the food business operator responsible for the food must appear. For food produced outside the EU, this is generally the importer established in the EU. Country of origin labelling is required for certain products, such as meat, honey, fruit and vegetables, and in any case where leaving it out would mislead the consumer.
This is one reason you need a clear understanding with your importer about who appears on the label.
How labels fit with the rest of your compliance
Labelling is one piece of a larger set of requirements. For US shipments you also need FDA facility registration, Prior Notice for each shipment (see our guide to FDA Prior Notice), a US agent, and an importer who meets the Foreign Supplier Verification Program requirements (see our guide to FSVP). For EU shipments you need an importer who takes responsibility under EU food law, correct certificates for animal and plant products, and accurate customs classification. Our food export compliance guide brings these together in one checklist for both directions.
Labelling also affects your numbers. Reprinting, relabelling, extra stickers, new packaging and testing for nutrition values all add cost. Build these into your landed cost model before you commit to a market, as we explain in our guide to food market feasibility studies.
A label adaptation checklist
Use this list when you adapt a label from one market to the other.
Name of the food. Does the product name meet the legal naming rules of the destination market?
Ingredients. Are all ingredients listed in descending order, using the right names and additive categories?
Allergens. Have you checked against the destination market's full allergen list and used the right format?
Nutrition information. Has the panel or declaration been recalculated in the destination format, with the correct units?
Net quantity. Is it shown in the right units and in the right place?
Dates and storage. Do you have the date marking and storage instructions the market expects?
Business details. Is the responsible business and its address correct, including the importer where required?
Origin. Is country of origin shown where required?
Claims. Has every claim been checked against the market's rules?
Language and size. Is the mandatory information in the right language and legible at the required size?
Additives and ingredients. Is every ingredient permitted in the destination market?
Final review. Has someone qualified, such as your importer, a consultant or a labelling specialist, reviewed the final artwork before printing?
Common mistakes
Copying the home market panel. The panel and its figures need recalculating for the destination market.
Missing allergens from the other list. Celery, mustard, lupin, molluscs and sulphites matter in the EU. Sesame and the US format matter in the US.
Using claims freely. A claim that sells well at home may not be allowed abroad.
Forgetting stickers are an option. For a first shipment, an overlay sticker can be a practical, low cost way to meet destination requirements, if the rules allow it for your product and the sticker is applied properly. Check with your importer before relying on this.
Printing before checking. A pre print review is far cheaper than a reprint.
When to get help
You can adapt a simple label yourself if you take the time to read the current rules. Many producers prefer a second opinion, particularly for a first export, for a product with health claims, or when the product contains additives that differ between the two markets. A short label review before printing costs far less than relabelling a pallet.
At VC Agriculinary Consulting we help food producers and distributors prepare compliant exports between the US and Europe, including label compliance, import documentation and regulatory planning. You can see the full range on our food trade consulting services page.
If you have a label you want checked before it goes to print, contact us with your product, your target market and your current artwork, and we will tell you what to look at first.
Frequently asked questions
Can I use the same label in the US and the EU?
Rarely. Nutrition panels, allergen lists, units, claims and language rules differ, so most products need a market specific label.
How many allergens must be declared in the US and in the EU?
The US requires nine major allergens, including sesame. The EU requires fourteen, including celery, mustard, lupin, molluscs and sulphites.
Do I need to translate my EU label for the US?
The mandatory information must be in English for the US. You may keep other languages in addition.
What is the difference between sodium and salt on a label?
The US panel shows sodium in milligrams. The EU declaration shows salt in grams, which is calculated differently.
Can I use an overlay sticker instead of reprinting?
Often yes for a first shipment, if the sticker carries all the required information accurately and is permitted for your product. Confirm with your importer.
Who is responsible for the label being correct?
The business placing the food on the market carries legal responsibility. In practice, the producer, the importer and the designer all need to check it.