Article 13 of EU 1169/2011: font size, legibility and how mandatory information is presented
By the Menulta editorial team · Facts checked 15 October 2026 · Updated 15 October 2026
The short answer
Article 13 of Regulation (EU) No 1169/2011 says mandatory food information must be marked in a conspicuous place, easily visible, clearly legible and, where appropriate, indelible, and must not be hidden or interrupted by other material. On prepacked food, mandatory particulars must be printed in characters with an x-height of at least 1.2 mm, or 0.9 mm where the largest surface of the package is less than 80 cm². Certain particulars must also appear in the same field of vision.
The general rule: visible, legible, not hidden
Article 13(1) applies to all mandatory food information. It must be marked in a conspicuous place, so that it is easily visible, clearly legible and, where appropriate, indelible. It must not be hidden, obscured, detracted from or interrupted by any other written or pictorial matter. This principle applies in spirit to non-prepacked food too: allergen information in a restaurant should not be buried in small print or behind a sticker.
The 1.2 mm x-height rule
Article 13(2) sets a minimum size for mandatory particulars on packages and labels: characters with an x-height of at least 1.2 mm. The x-height is the height of a lowercase 'x' in the chosen font, defined in Annex IV. Because different fonts have different proportions, the same nominal point size can produce different x-heights, so designers must measure the x-height rather than rely on the point size.
Article 13(3) allows a smaller x-height of at least 0.9 mm on packages or containers whose largest surface has an area of less than 80 cm².
| Package size (largest surface) | Minimum x-height |
|---|---|
| 80 cm² or more | 1.2 mm |
| Less than 80 cm² | 0.9 mm |
| Less than 10 cm² | Only certain particulars required (Article 16(2)), allergens still required |
Very small packages
For packages whose largest surface is less than 10 cm², Article 16(2) reduces the mandatory particulars on the package to the name of the food, the allergens, the net quantity and the date of minimum durability or use-by date. The full ingredients list must still be provided by other means or made available on request. Allergens are never dropped.
Same field of vision
Article 13(5) requires the name of the food, the net quantity and, for drinks above 1.2% alcohol by volume, the actual alcoholic strength to appear in the same field of vision, meaning they can all be read from a single viewing point without turning the package. This helps consumers compare products quickly on the shelf.
What 'legibility' covers
Article 2 defines legibility as the physical appearance of information, by which it is visually accessible to the general population. It is determined by several factors, including font size, letter spacing, spacing between lines, stroke width, colour, typeface, the width-height ratio of the letters, the surface of the material and significant contrast between print and background. A label that meets the x-height but uses pale grey text on a silver film can still fail the legibility requirement.
Applying the principles to menus and digital information
The 1.2 mm rule is written for packages, but the same principles make menus and digital allergen information usable. Allergen information on a printed menu should be in a size and contrast guests can read in restaurant lighting. On a digital menu, allergen text should be readable without zooming, use strong contrast and not be hidden behind decorative elements. Guests with an allergy are often reading anxiously; clear presentation is part of keeping them safe.
Common legibility mistakes on labels
Most legibility problems come from design choices rather than the text itself. Thin, condensed fonts that technically meet the x-height but are hard to read; low contrast such as white text on pale backgrounds or dark text on dark red; text printed over images or patterns; text running across folds, seams or crimps; and reflective films that make text unreadable under shop lighting. Allergens are emphasised within the ingredients list under Article 21, but if the list itself is illegible the emphasis does not help.
Sources
This guide is general information, not medical or legal advice. Guests with an allergy should follow their doctor's advice. Operators should confirm their own setup with their food safety adviser or local authority.