This guide explains EU food labelling and allergen requirements for microgreens under Regulation (EU) 1169/2011, including prepacked rules and enforcement practice.
Across the European Union, food labelling law is harmonised. The core legal framework is the same whether you are producing in Spain, Germany, France, Italy or elsewhere. Enforcement, however, happens locally, which is why advice sometimes feels inconsistent.
This guide explains how EU food labelling and allergen rules actually apply to microgreens. It covers classification, mandatory information, allergen triggers, enforcement practice, and what inspectors typically expect from small producers.
Start With Classification: How Is the Food Sold?
Most confusion disappears once classification is clear.
Under Regulation (EU) No 1169/2011, food placed into packaging before sale, where the packaging encloses the product so it cannot be altered without opening it, is considered prepacked food.
For microgreens, this typically includes:
- Sealed punnets or clamshells
- Bags packed in advance
- Live trays sold as complete packaged units
If microgreens are sold loose, or packed at the customer’s request (for example at a market stall), they are treated as non-prepacked food. Allergen obligations still apply.
Unlike the UK, the EU does not operate a separate PPDS category. Instead, allergen communication rules for non-prepacked foods are implemented at member-state level, meaning the method of communication may vary slightly by country.
Correct classification resolves most downstream labelling questions.
Core EU Labelling Requirements for Packaged Microgreens
The governing framework is Regulation (EU) No 1169/2011 on the provision of food information to consumers.
For most packaged microgreens, the following mandatory particulars apply:
Name of the Food
The product must have a clear legal or customary name. Examples include “Broccoli Microgreens” or “Pea Shoots.”
Marketing names are permitted but cannot replace an accurate description.
Ingredients List
If the product contains more than one ingredient, all ingredients must be listed in descending order by weight at the time of packing.
Single-ingredient microgreens generally do not require an ingredients list.
An ingredients list becomes mandatory if you sell:
- Mixed microgreen blends
- Products with added oils or dressings
- Packs containing seeds or toppings
Net Quantity
Net weight must be declared in metric units, typically grams.
Date Marking and Storage
Where specific storage conditions are required, they must be stated.
Date marking must use either:
- Use by for highly perishable foods from a safety perspective
- Best before for quality-based durability
The decision must align with your shelf-life assessment and food safety management system.
Name and Address of the Responsible Food Business Operator
The label must identify the responsible food business operator established in the EU.
Language
Mandatory information must be provided in a language easily understood in the member state where the product is sold.
Allergens Under EU Law
Regulation (EU) No 1169/2011 mandates declaration of 14 allergens:
- Cereals containing gluten
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk
- Tree nuts
- Celery
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites above threshold
- Lupin
- Molluscs
When present, allergens must be declared within the ingredients list and emphasised through clear typographical distinction such as bold text.
What This Means for Microgreens
Plain, single-variety microgreens typically contain no allergens.
Allergen obligations are triggered when:
- Blends include celery, mustard or sesame
- Dressings or toppings are added
- Mixed products incorporate allergenic ingredients
Celery and mustard are particularly significant within the EU framework and frequently overlooked by small producers.
For non-prepacked foods, allergen information must still be provided. The format depends on national implementation rules.
How Enforcement Works in Practice
The European Commission sets the framework, but enforcement is carried out by national authorities within each member state.
Inspection style and penalty thresholds may vary, but the legal basis remains harmonised.
Inspectors typically assess:
- Clarity and legibility
- Correct allergen emphasis
- Consistency of naming
- Accuracy of declared information
They are generally looking for control and understanding rather than perfection.
A Practical EU Label Structure
A compliant microgreens label typically includes:
Main panel:
- Name of the food
- Net quantity
Secondary panel:
- Ingredients list (where required)
- Allergens emphasised
- Storage conditions
- Durability date
- Name and address of responsible operator
- Lot or batch code
All information must be clear, legible and indelible.
Common EU Labelling Mistakes
- Missing allergen emphasis
- Forgetting celery or mustard in blends
- Missing responsible business address
- Incorrect language for destination market
- Inconsistent product naming across batches
These are routine enforcement triggers across member states.
Simple EU Compliance Check Before Sale
- Is the product correctly classified?
- Is the food name clear?
- Is net quantity declared?
- Are storage instructions appropriate?
- Is the correct durability date used?
- Is the responsible food business operator identified?
- Are all applicable allergens declared and emphasised?
- Is information in the correct language?
- Is batch traceability established?
If each answer is documented, you are aligned with the core requirements.
References and Official EU Guidance
- Regulation (EU) No 1169/2011 on food information to consumers
- European Commission – Food information to consumers guidance
- European Food Safety Authority – Scientific opinions on allergens
- National food safety authorities within each member state
- European Commission guidance on allergen labelling