Regulations for

Sandwich Labels

The labelling of sandwiches which are pre-packed by retailers, wholesalers or manufacturers for retail sale, or for sale to a catering establishment need to address a certain criteria, regarding the information displayed to customers on the products label. To learn more about what information you need to include on your product labels please choose from one of the below articles.

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EU FIC Regulations

This piece of European legislation is called the EU Food Information for Consumers Regulation (EU FIC) came into force on 13 December 2014. It changes the way allergen information appears on labels and on food that is prepacked, sold loose or served when eating outside of the home.


• Any of the 14 allergens that are on the regulatory list must be emphasised on the label, if they are used as ingredients in your pre-packaged food. You can choose what method you wish to emphasise these allergens, for example, by listing them in bold, italics, highlighted or underlined, to help identify them to potential customers.


• Information about allergenic ingredients is to be located in a single place, i.e. the ingredients list on prepacked food. Meaning that the voluntary use of the previous types of allergy boxes such as: ‘Contains nuts’ that provide a short cut to allergen ingredients information also given in the ingredients list is no longer allowed. The use of voluntary precautionary allergen labelling such as ‘may contain’, to indicate the risk of unintentional presence of allergens in a food, is still permitted and has not been affected by this regulation.


• Previously, loose foods for example in supermarkets, delis, cafes and restaurants; didn’t have to provide information you need about food allergens. However, since 13 December 2014, information on any of the 14 allergens used as ingredients should be provided for these foods.


What are the 14 allergens that have to be identified?


The 14 allergens are:

• Eggs

• Milk

• Fish

• Crustaceans (for example crab, lobster, crayfish, shrimp, prawn)

• Molluscs (for example mussels, oysters, squid)

• Peanuts

• Tree nuts (namely almonds, hazelnuts, walnuts, cashews, pecans, brazils, pistachios, macadamia nuts or Queensland nuts)

• Sesame seeds

• Cereals containing gluten (namely wheat (such as spelt, Khorasan wheat/Kamut), rye, barley, oats, or their hybridised strains).

• Soya

• Celery and celeriac

• Mustard

• Lupin

• Sulphur dioxide and sulphites (at concentration of more than ten parts per million)



Advisory Labelling

Food labelling is very important to those with food allergies as there can be potentially serious consequences from eating food that they are allergic to. Manufacturers often use phrases such as 'This Product May Contain Nuts’ to show that there could be small amounts of an allergen in a food product because it has entered the product accidentally during production. It is not a legal requirement, to say on the label that a food might accidently contain a small amount of an allergen, but many manufacturers label their products in this way to warn their customers of the potential risk.


However there is a concern that the term 'may contain' is used too much in food labelling, sometimes when it isn’t really required and therefore undermining the valid warnings on products and restricting peoples choices unnecessarily. As a result The Food Standards Agency (FSA) is working towards reducing the unnecessary use of 'may contain' in food labelling to provide more clarity to the public on why these labelling terms are used and what they mean. This includes working with regulators in other countries across the EU within the food industry, with the support of consumer organisations to agree how management thresholds can be derived for the common food allergens. The outcome of these meetings resulted in the new food labelling rules. For more information on this subject please refer to the FIC EU regulations on food labelling.

Required Information

The labelling required depends on how the sandwiches are sold and whether or not they are sold at a catering establishment. They can be separated into the following 3 categories. However if the sandwiches or their ingredients have been irradiated, this fact must always be labelled or declared.


Sandwiches which are not pre-packed or are pre-packed for direct sale (other than at catering establishments). These sandwiches must be labelled with:


a) the name of the food and:

b) the category names of any of the following additives which they contain; Antioxidants; Flavourings; Sweeteners; Preservatives; Colours; and Flavour Enhancers e.g. “Contains colour and flavouring”.


‘Pre-packed for direct sale’ means pre-packed by the retailer and sold on the premises from a vehicle or stall used by him. It does not include sandwiches produced at a central site and distributed for sale at other retail premises – these are covered by category 3 below.


‘Catering establishments’ includes restaurants, pubs, sandwich bars, canteens, or similar premises.’


Sandwiches sold at a catering establishment which are not pre-packed or are pre-packed for direct sale.

No information is required to be labelled on these sandwiches (unless they have been irradiated as stated above). However, any description of the sandwiches or their fillings must be accurate and must not mislead the customer.


All other pre-packed sandwiches. Must be labelled with the following information: c) the name of the food d) a list of ingredients. e) A date mark and storage conditions. f) Name and address of the manufacturer. g) Indication of the place of origin. h) Instructions for use (if necessary) e.g. “consume on the day of purchase” These requirements are explained in more detail below: The name of the food.


a) This is a key labelling provision and the name applied must. · be sufficiently precise to indicate the true nature of the food. · enable the food to be distinguished from foods with which it could be confused; and… · indicate any treatment to which the food has been subjected if failure to declare this could mislead the consumer.


b) Generally the name of a sandwich will include an accurate description of the filling, the type of bread and where appropriate, the fat spread e.g low fat sunflower spread.


c) The description of the filling should include its main and characterising ingredients e.g. “roast ham with mustard”, “mature cheddar cheese and tomato mayonnaise”.


d) For meat ingredients which themselves contain non-meat ingredients e.g. “chicken roll with cereal”, or “ham with added water and gelatine” etc, these non-meat ingredients must be indicated in the name to distinguish it from similar products with no added ingredients e.g. “whole chicken pieces” or “roast ham”.


e) If the meat has been reformed this must be stated in the name of the meat e.g. reformed ham with added water and gelatine.


f) If descriptions are used which indicate a process or method of cooking, such as “smoked” or “roast”, these descriptions must be accurate i.e. if only smoked flavouring is used or if a product has been steamed and flash roasted, then that is how it should be described e.g. “smoke flavour ham”, pork-steamed and flash roasted”.


g) For meat ingredients, care should be taken when using terms such as burgers and sausages, as these are required to contain a minimum meat content.


h) Care should be taken to ensure that other mis-descriptions are not applied e.g. · Brown bread must not be described as “wholemeal” unless it is wholemeal. · Margarine or other fat spreads must not be described as butter. · Cooked pork shoulder must not be described as ham. · Processed cheese must be described as such and not simply as cheese · Analogues and cheese substitutes which are usually made from vegetable oil and milk protein must not be described as ‘cheese’.


A List of Ingredients:


a) All the ingredients, including water and additives, must be listed in descending order of weight determined at the time of their use in the preparation of the food.


b) The list of ingredients must have a heading which consists of or includes the word “ingredients”


c) The name used for the ingredients must be a name that would be used if it was sold as a food.


d) Additives, except flavourings and modified starch, must be listed by their category name and, the serial (E) number or extract name e.g “Colour (E102) or “Colour (tartazine)”. Flavourings and modified starch may be listed simply by these category names.


e) Sandwiches usually contain compound ingredients to which specific labelling requirements apply. Compound ingredients are those which themselves are made up of a number of ingredients, such as bread, chicken roll, sausage, mayonnaise, tomato ketchup etc. Normally the constituents of a compound ingredient must be listed unless: · The compound ingredient constitutes less than 25% of the finished product; or · The name used for the compound ingredient is a generic name which is permitted by the regulations e.g. cheese. In which case only the name of the compound ingredient is required. However if the compound ingredient constitutes less than 25% of the finished product, but contains an additive which performs a specific function in the sandwich (such as a colour or preservative), the presence of the additive will need to be shown e.g. “tomato ketchup (contains colour E102)” The constituents of compound ingredients can be listed in one of two ways: · By stating the constituents individually in the appropriate places in the list of ingredients (without the name of the compound ingredient); or · By stating the name of the compound ingredient (in the appropriate place) followed in brackets by a list of its constituents e.g. “mayonnaise (pasteurised egg, com oil, salt, pepper)”


f) Water should be included in the list unless it is less than 5% of the finished product.


g) If the ingredient has been subject to a significant treatment e.g. “dried” or “smoked” this must be stated. In particular if an ingredient has been “irradiated” or the words “treated with ionising radiation”.


h) If special emphasis is given to the presence or low content of a particular ingredient in the sandwich (e.g. by means of a picture or by emphasising certain words) then a declaration must be made in the ingredient list of the:


· Minimum percentage (when emphasising the presence of an ingredient); or


· Maximum percentage (when emphasising the low content of an ingredient).


A Date Mark and Storage Instructions:


a) The Date Mark must state the words “Use By” or “Best Before” and the date up to and including which the food will remain in good condition. The date must state at least the day and the month.


b) “Use By” dates are required for fillings which are highly perishable and likely to cause food poisoning if not eaten with a short periods e.g. pate, cooked meats, mayonnaise, cheeses etc. “Best Before” dates should be used for other fillings eg peanut butter. In practice most sandwiches will require a “Use By” date.


c) IF food as been stored in a particular manner to remain in good condition until the expiry date of the date mark then storage instructions must accompany the date mark. Food marked with a “Use By” date should include a maximum storage temperature eg “Keep refrigerated at 8C or colder”.


Name and Address:


The name and address of the manufacturer, packer or seller must be given on the label.



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