The UK back-of-pack nutrition declaration, explained (Regulation 1169/2011)

If you sell packaged food in the UK, most products owe a mandatory nutrition declaration — the back-of-pack table — under assimilated Regulation (EU) No 1169/2011 (the Food Information Regulations that carried the EU FIC into UK law after exit). What surprises many founders is how much of it is decided from the recipe, before you print or pay for anything. This guide covers what the declaration requires and why calculation from your recipe is a recognized basis for the values.

The seven values, per 100g, in a fixed order

The mandatory declaration is energy plus six nutrients, given per 100g or per 100ml, in this order: energy, fat, of which saturates, carbohydrate, of which sugars, protein, and salt. Energy must appear in both kJ and kcal. You may voluntarily add mono-unsaturates, polyols, starch, fibre, and vitamins or minerals present in significant amounts — but the seven above are the floor, and the order is not yours to rearrange.

The practical consequence: whether your product meets a claim threshold, and what the table says, is a calculation over composition — not something only a laboratory can produce. You can work it out while you are still adjusting the recipe.

Calculation is named in the law, not tolerated as a shortcut

This is the point most worth knowing. Article 31(4) of 1169/2011 states that the declared values are average values based, as appropriate, on the manufacturer's calculation from the known or actual average values of the ingredients used, or on generally established and accepted data. Calculation from the recipe is written into the regulation as a legitimate route. There is no UK office that pre-approves a label; be wary of any tool implying its numbers are "approved" — that status does not exist here, and the final labelling decision rests with the food business operator.

Two traps: salt (not sodium) and energy in two units

• Salt, not sodium. The UK table declares salt, calculated as sodium × 2.5. Declaring sodium, or forgetting the conversion, is a common formatting error.
• Energy in kJ and kcal. Both units are mandatory, computed from the Atwater-style energy contributions of protein, fat, carbohydrate (and where present, fibre, polyols, alcohol).

Tolerances and rounding

The declared value is an average, so enforcement compares a market sample against it within tolerances — the EU/UK guidance on tolerances for nutrition labelling sets how far an analysed value may sit from the declaration before it is non-compliant, and it differs by nutrient and level. Rounding follows the same guidance (for example, energy and macronutrients round to defined increments). Declaring an unrounded or out-of-tolerance value is itself a defect, independent of whether the recipe maths was right.

What defends the label — and when a lab still earns its cost

There is no pre-market gate; verification happens afterward, on the product in the market. What holds up is documentation: the composition database and its version, the match chosen for each ingredient, the yield and retention adjustments, the salt-from-sodium and energy calculations, the rounding applied to each line, and the provision each step relied on. Budget a confirmatory lab analysis where your process shifts composition unpredictably (frying, fermentation, heavy browning), where a value sits on a claim or tolerance boundary, or where a retailer requires one — and recalculate, rather than re-test, on every reformulation in between.

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FoodFact calculates the UK back-of-pack declaration from your recipe using food-composition data, applies the salt conversion, dual-unit energy, ordering and rounding above, and issues a report that cites the provision behind every value. You can build it free and see what one order produces on the United Kingdom page, or open the nutrition calculator directly.

This article is general information about UK labelling rules, not regulatory advice. The final labelling decision, and responsibility for the finished product, rests with the food business operator.