Guides · updated 18 August 2026
One label, two rulebooks — EU and UK in 2026
The short answer: the two rulebooks were carbon copies on 1 January 2021 and have been drifting apart ever since — slowly. Food information is still near-identical, because the UK kept Regulation (EU) No 1169/2011 as assimilated law. The gaps that actually change what you print are the operator address, wine, the conformity mark and green claims. Design to the stricter side, put two addresses on the pack, and one label usually serves both markets.
Food
Food information: the rules are still twins — except one line
The UK did not write a new food labelling law at Brexit. It kept the EU one: Regulation (EU) No 1169/2011 — « FIC » — carried over as assimilated law (the successor to « retained EU law ») and applied through The Food Information Regulations 2014 in England, with parallel regulations in Scotland, Wales and Northern Ireland. So the substance matches, line for line, with one exception that matters on every pack: the address.
| Topic | EU market | Great Britain |
|---|---|---|
| Legal base | Regulation (EU) No 1169/2011 | The same text, kept as assimilated law and enforced via The Food Information Regulations 2014 |
| Allergens | 14 allergens, emphasised inside the ingredients list | The same 14, the same emphasis rules |
| Minimum text size | x-height 1.2 mm — 0.9 mm below 80 cm² | Identical |
| Nutrition declaration | Mandatory, in the set order | Identical |
| Operator address | Name and address of a food business operator established in the EU — or of the EU importer | A UK, Channel Islands or Isle of Man address — or of the UK importer |
| New rules | Amendments apply across all member states automatically | Only when the UK legislates — the two texts drift a little further each year |
| Northern Ireland | Follows the EU food rulebook under the Windsor Framework | |
The address rule is the one that catches exporters: an EU-only address is not valid for food sold in Great Britain, and a UK-only address is not valid for food sold in the EU. The standard fix is two addresses on the same label. The twelve mandatory particulars behind this table are unpacked in the food labelling guide.
Conformity marks
CE, UKCA — and the « Not for EU » stamp
This is where the divergence ran backwards. UKCA was announced as the mandatory replacement for CE in Great Britain; after several postponements, the government said in August 2023 that CE would stay accepted indefinitely for most regulated goods, and in 2025 revoked the June 2025 UKCA deadline for construction products too.
| Mark | EU market | Great Britain | Northern Ireland |
|---|---|---|---|
| CE | Required, product rules unchanged | Accepted indefinitely for most regulated goods — electrical, machinery, PPE, measuring equipment and more | Required |
| UKCA | Not recognised | Valid, sits alongside CE — mandatory only in a few niches | UKNI is added next to CE when a UK body did the assessment |
| « Not for EU » | Never used | The planned GB-wide rollout was cancelled in September 2024 | Required on retail meat and dairy moving from GB under the retail movement scheme — the product list widened on 1 July 2025 |
Practical consequence: for most products a CE-marked label still covers the EU, Great Britain and Northern Ireland at once. Any future change to CE recognition in GB has a promised transition of at least two years — enough to relabel without scrapping stock.
Wine
Wine: the biggest split on any label we print
Since 8 December 2023, Regulation (EU) 2021/2117 requires an ingredients list and a nutrition declaration on wine sold in the EU. The UK chose not to follow — and went the other way, simplifying its own wine rules in 2024. The result is the widest gap between the two markets on a single product:
| On the label | EU market | Great Britain |
|---|---|---|
| Ingredients list | Mandatory — may sit behind a QR code (« e-label ») with no marketing around it | Not required |
| Nutrition declaration | Mandatory — the energy value must be printed on the physical label, the full table may be electronic | Not required — only the alcoholic strength and nominal volume |
| Allergens | On the physical label | On the physical label too |
| Importer line | « Importer: » plus a name and EU address | Since the 2024 wine reforms, an FBO or importer name with a UK address — the word « importer » is no longer required |
The asymmetry is useful: an EU-compliant wine label with a UK address added generally satisfies Great Britain, while the reverse is never true. That is also why back labels grew — the sizes that absorb the new text are in bottle and jar label sizes, and the full EU detail in the wine rules guide.
Environmental claims
Green claims: two paths, one direction
Both sides are converging on the same standard — prove it or remove it — by different routes.
EU: Directive (EU) 2024/825, the « empowering consumers » directive, applies from 27 September 2026. Generic claims — « green », « eco », « environmentally friendly » — are banned unless the performance is demonstrated, carbon-neutral claims built on offsetting are banned outright, and sustainability labels are only allowed when they come from a certification scheme. The separate Green Claims Directive proposal was withdrawn in June 2025; the 2024/825 rules stand.
UK: the Green Claims Code from the competition regulator, backed since April 2025 by the Digital Markets, Competition and Consumers Act 2024 — the regulator can now fine a misleading claim directly, up to 10 % of worldwide turnover, without going to court first.
For what survives on a printed label — and the wording that does not — see environmental claims on labels.
- EU rule
- Directive (EU) 2024/825
- Applies from
- 27 September 2026
- UK rule
- Green Claims Code + DMCC Act 2024
- UK fines since
- April 2025, direct
- Safe test
- evidence in hand, or leave it off
In practice
What it means for your label
Selling into both markets does not need two labels for most products. It needs one label designed against the stricter rule of each line:
- Two addresses, one label. An EU operator or importer address and a UK one, side by side — the food rule that bites first, and the easiest to fix at artwork stage.
- Wine: print the EU set. Ingredients or QR, energy value, allergens — then add the UK address line and the same bottle sells on both sides.
- Keep the CE mark. It still covers the EU, Great Britain and Northern Ireland for most goods; add UKCA only if your product area demands it.
- Treat every green word as a claim to evidence. On both sides of the Channel, from 2025-2026 the burden is on the pack, not on the regulator.
- Order in smaller runs. Rules now drift a little every year; a run of 100 to 1 000 labels reprinted in 2 to 10 working days costs less than a pallet of stock scrapped by one new line of text. For dates, lots and per-market variants, variable data changes one line without touching the design.
Unsure which lines apply to your product? Describe it on the custom request form — we print for both markets daily, and delivery is quoted with the order — DDP, on either side of the border.
FAQ
EU vs UK labelling — what customers ask us
Can one label really serve both the EU and the UK?
For most products, yes. Food information is near-identical, so a label with both an EU and a UK address on it satisfies both markets. Wine works one way only: an EU-compliant label plus a UK address sells in Great Britain, but a GB-only label lacks the ingredients and nutrition lines the EU requires. The clean method is to design against the stricter rule of each line.
Do I need the UKCA mark in 2026?
For most product areas, no — the UK accepts the CE marking indefinitely, and UKCA sits alongside it as a valid alternative rather than a replacement. A few niches still have their own regime, so check the rules for your product category. Any future change has a promised transition of at least two years.
Will UK food labelling stay aligned with Regulation 1169/2011?
The starting text is the same — the UK kept the regulation as assimilated law — but the two versions no longer move together. EU amendments apply across the member states automatically; Great Britain changes only when it legislates. Nothing dramatic has split food information yet, which is exactly why small print runs are the sensible hedge: you reprint when a line changes instead of predicting it.
What about Northern Ireland?
Northern Ireland follows the EU rulebook for food and goods under the Windsor Framework, so an EU-compliant label works there. The one extra: retail meat and dairy moving from Great Britain into Northern Ireland under the retail movement scheme must carry a « Not for EU » marking — a requirement whose planned extension to all of Great Britain was cancelled in September 2024.
Who actually polices green claims on a label?
In the EU, national consumer authorities, applying Directive (EU) 2024/825 from 27 September 2026. In the UK, the competition regulator under the Green Claims Code — and since April 2025 it can impose fines of up to 10 % of worldwide turnover directly. In both systems the test is the same: a claim on the label must have evidence behind it before it is printed, not after a complaint.
This guide is a practical summary written by a label printer, not legal advice. Check the current texts or your trade body before printing.
Official texts: Regulation (EU) No 1169/2011 — EUR-Lex · The Food Information Regulations 2014 — legislation.gov.uk · Packaging and labelling — Food Standards Agency · Regulation (EU) 2021/2117 (wine) — EUR-Lex · Directive (EU) 2024/825 (empowering consumers) — EUR-Lex · Using the UKCA marking — GOV.UK
Still unsure?
Ask the person who makes them
The guide covers the general case — your label lives on a real product. Describe it in two lines and a label specialist (not a bot) answers within 2 working hours.
All guides
Everything else we have written down
- Choosing your label material
- Choosing your label adhesive
- Bottle and jar label sizes
- EU food labelling — the INCO rules
- EU wine label rules
- Environmental claims and sorting labels
- Preparing print-ready files
- Variable data, explained
- Label material comparison chart
- EU vs UK labelling requirements — you are here
- What drives the price of a label
- Label glossary
Printing for both markets?
Every stock and size in the configurator, delivered on either side of the border — DDP.