Further Changes Ahead for Food and Alcohol Labelling
Incoming requirements for front-of-pack labelling are to be informed by the results of scientific studies on food and alcoholic-beverage labels.


Food nutrition labels are likely to gain a new appearance due to the European Commission's (Commission) intended introduction of a mandatory front-of-pack nutrition labelling proposal in the second quarter of 2023. This plan, which is the latest development in a series of proposed changes previously discussed here, forms part of the EU's "Farm to Fork strategy", which aims to improve the food chain for consumers, producers, climate, and the environment.  

The Commission has confirmed that the results of four scientific studies related to the provision of food information to consumers and carried out by the Commission's Joint Research Centre (JRC), are an indication of possible future developments. 

Key Expected Changes 


  1. Front-of-pack nutritional information labelling may become mandatory 
    The JRC's first study found that consumers value a simple, colourful and evaluative summary on front-of-pack labels to help quickly gain nutritional information when making purchases. The study also noted the influential impact front-of-pack labels have on leading consumers to choose healthier diets while simultaneously encouraging food businesses to improve the nutritional quality of their products.

    In Ireland, almost all prepacked foods must have nutritional labelling, including a declaration of the Energy (kJ/kcal), Fat (g), Saturates, Carbohydrates (g), Sugars (g), Protein (g) and Salt (g) per 100g/ml of the final product on its packaging. Presently, placing this nutrient content on front-of-pack labels is voluntary. However, the results of this study indicate that a move towards a more prescriptive mandatory labelling scheme is likely.
  2. Adding ingredients to alcoholic beverages labels may become mandatory
    The second study highlighted that currently, there is no obligation for alcoholic beverages containing more than 1.2% alcohol by volume to display nutritional information or a list of ingredients, and also that labels re-directing consumers to off-label ingredients and nutritional information are not prevalent in the marketplace. This has resulted in discrepancies in the information displayed on different types of alcoholic drinks, with beers commonly displaying nutritional information, spirits doing so less frequently, and wine products rarely, if at all.

    However, attempts to address inconsistencies in wine labelling have already begun. Regulation 2021/2117, which comes into effect from 1 January 2023, introduces the mandatory inclusion of ingredients lists and nutrition declarations on wine products. These measures are discussed in more detail here.
  3. Alternative means of displaying nutritional information to consumers
    The JRC's third study considered alternative means (other than via food labels) by which consumers might obtain nutritional information. The study found that consumers are often guided towards healthier diets by direct access to food information in the marketplace, i.e., via menu labels, shelf-labels and point-of-sale signs. The study found that information should be directly visible in the marketplace to inform consumers, if not provided on the food package. It was acknowledged that a more detailed analysis is needed to compare the effectiveness of digital information against information on labels.

    Depending on the outcome of further research, this may give rise to greater choice in how food and beverage businesses provide nutritional information via alternative means. Such a development may lead to greater freedom to utilise technology, for instance, via the application of QR codes. This, in turn, may give rise to further creative expression on product packaging. It will be interesting to see where the Commission's proposal lands in this regard.
  4. Mandatory origin labelling
    The final study found that consumers care about the origins of the food they buy, viewing this as an indicator of quality and eco-friendliness. The study also found that consumers also prefer to "support local" where possible. However, the study found that when shopping, origin information affects consumers' choices less than they would like, as other factors like branding and time pressures take precedence when in the moment.

    Again, the results of this study suggest the inclusion of origin information on packaging may be mandatory in the future. Food and beverage businesses that do not display such information voluntarily at present should begin to consider how best to incorporate this information into their existing packaging designs.


Based on the JCR's findings, it is likely that the Commission's proposal for front-of-pack food labels will involve the requirement to set out the nutritional information of a product and its origins. The studies highlight the presentation of this information is so influential for consumers that a standard format may be introduced for the labels to ensure they are clear and easy to evaluate. Alcoholic beverages may also be subject to more stringent requirements in relation to the display of ingredients and nutritional qualities. 

Food businesses should be cognisant of these incoming changes and how they may affect the production, marketing and distribution of their products. 

We will keep you abreast of any updates as and when they arise in this regard. In the meantime, for further information on how this development might impact your food and alcoholic-beverage labelling, please contact any member of our Food Beverage & Agribusiness group or your usual William Fry contact.

Contributed by Laura Casey, Louisa Muldowney


Key Contacts

Colette Brady Partner

Ciarán Herlihy Partner