What it covers
The review works on three levels. The first is mandatory information: the name of the food, the list of ingredients with the required emphasis on allergens, the net quantity, the date of minimum durability or the use-by date, storage conditions and conditions of use, the nutrition declaration in the prescribed format and units, the legibility requirements of Annex IV of Regulation (EU) No 1169/2011, and the sectoral rules that apply to the product, including marketing standards, origin labelling and distance selling.
Where the product is a food supplement, the label is also checked against the specific particulars required by Directive 2002/46/EC: the name “food supplement”, the categories of nutrients or substances that characterise the product, the portion of the product recommended for daily consumption, a warning not to exceed the stated recommended daily dose, a statement that food supplements should not be used as a substitute for a varied diet, and a statement that the product should be stored out of the reach of young children — as transposed in the Member State of marketing.
The second level is voluntary information and presentation: reserved names, quality terms, organic and geographical indication terms, environmental claims, and the overall impression conveyed by text, images and design.
The third is interpretation. On every contestable point we apply the case law of the Court of Justice, the communications and guidance of the European Commission, and the criteria published by the enforcement authority of the country of sale.
For an operator established outside the Union, two points deserve particular attention. Under Article 8(1) of the Regulation, if the operator under whose name the food is marketed is not established in the Union, responsibility for the food information lies with the importer into the Union market. And under Article 15, Member States may require the mandatory particulars to be given in their official languages, so a label prepared for one market is not automatically valid for another.
What you receive
A report with an executive summary and each finding located on the label itself, stating the provision concerned, the interpretative criterion behind it and a specific proposal for corrected wording. Each finding is ranked by risk, distinguishing purely formal non-compliance from issues that materially affect the information given to the consumer or the consumer’s safety. A review of the corrected version is included.
What a finding looks like
Fictitious product, created to illustrate the method.
Product
“Bosque Rojo” cereal bar. Front of pack with the words “Red berries” in large type and pictures of strawberries and raspberries. Name of the food on the back: “Red berry flavour cereal bar”. Ingredients: oat flakes, glucose syrup, dried apple (3%), sunflower oil, natural flavouring, colour (anthocyanins). Neither strawberry nor raspberry appears among the ingredients.
Finding
The front of pack suggests the presence of strawberry and raspberry, which the product does not contain. The name of the food and the list of ingredients are, in themselves, correct.
Provision concerned
Article 7(1)(a) of Regulation (EU) No 1169/2011, read with Article 7(4)(b), which extends the prohibition on misleading information to the presentation of the food.
Interpretative criterion
A correct list of ingredients does not cure a misleading overall presentation. The Court of Justice held that “the list of ingredients, even though correct and comprehensive, may in some situations not be capable of correcting sufficiently the consumer’s erroneous or misleading impression concerning the characteristics of a foodstuff that stems from the other items comprising its labelling” (Case C-195/14, Teekanne, paragraph 40, decided under Directive 2000/13/EC, the predecessor of Article 7 of the Regulation). The reference consumer reads the front before the back, and here the front says fruit.
Risk
High. Information liable to be considered misleading in an official control. Correction requires changing the front of pack, not just the text on the back.
Proposed correction
Two alternatives: add strawberry and raspberry to the recipe, stating their percentage under Article 22 of the Regulation; or remove the fruit pictures from the front of pack and present “red berry flavour” in a size and position that leave no doubt as to the nature of the product.
Operator data
The “natural” status of the flavouring is taken as declared; verifying it is not part of the review.
Every report sets out all the findings on the label in this same structure, ranked by risk.
The basis of our work
The review is a legal analysis, not a laboratory one. We take the data declared by the operator — composition, quantities, nutrition values — as accurate and examine whether their presentation complies. We do flag inconsistencies that appear on the face of the label, such as an energy value that does not match the declared nutrients. Analytical verification of the data is a matter for a laboratory and complements this service.
Markets
By default the review covers the Spanish market and can be extended to other Member States, taking in their national rules and the enforcement criteria published by their authorities. In that case the timeframe depends on the markets involved.
Nutrition and health claims
The report identifies each claim and checks that its wording is authorised and that the conditions of use are met on the basis of the data on the label itself. Substantive assessment of doubtful or borderline claims is carried out through the nutrition and health claims review.
What it does not include
It does not include graphic design or layout: the review covers the content and presentation of the label from a regulatory standpoint. Nor does it include analytical verification of the declared data.
Legal framework
Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, and the Union and national rules applicable to the product category. For food supplements, Directive 2002/46/EC on the approximation of the laws of the Member States relating to food supplements and the national transposing rules of the Member State of marketing; in Spain, Royal Decree 1487/2009, as amended by Royal Decree 130/2018.
Process
The company sends its request through the quote form and provides the label in the form in which it will be marketed: the label design in PDF, final or draft, if the product has not yet been launched, or photographs taken following the instructions we provide if it is already on the market, together with a short questionnaire on the product and its sales channels. For the Spanish market the report is delivered in 3–5 working days, at a price fixed from the first contact; the timeframe runs from the date the file is complete.
When this is not the right service
If the question is specifically whether a particular statement on the label is legally covered, the right service is the claims review.
If the status of the product or of one of its ingredients is still unresolved — novel food, borderline product — that question should be settled first, through the novel food status assessment or the borderline products assessment, since it may determine what the label can lawfully say.