In what order must ingredients be listed?

In descending order of weight at the time of use, with some exceptions in Annex VII, such as ingredients under 2% of the final product.

What is a compound ingredient?

An ingredient made from more than one ingredient, such as chocolate in a biscuit. It can be listed with its own ingredients in brackets.

How must additives be listed?

By functional class followed by the specific name or E-number, for example 'emulsifier: soya lecithin'.

Which foods do not need an ingredients list?

Article 19 exempts some single-ingredient and simple foods, such as fresh unpeeled fruit and vegetables and carbonated water. Allergens must still be declared where relevant.

Do restaurants need full ingredient lists?

Not under EU rules for non-prepacked food, unless national rules require it. Allergen information is mandatory.

The ingredients list under EU 1169/2011: Articles 18 to 20 explained

By the Menulta editorial team · Facts checked 15 October 2026 · Updated 15 October 2026

The short answer

Articles 18 to 20 of Regulation (EU) No 1169/2011 set the rules for the list of ingredients. It must be headed 'ingredients', list every ingredient in descending order of weight at the time of use, name each by its specific name, show additives by their function and name or E-number, and mark engineered nanomaterials with '(nano)'. Compound ingredients can be listed with their own ingredients in brackets. Some foods and substances are exempt from the list, but allergens must always be declared.

The basic rules in Article 18

The list is headed or preceded by a suitable heading that consists of or includes the word 'ingredients'.
It includes all ingredients in descending order of weight, as recorded at the time of their use in manufacture.
Ingredients are designated by their specific name, in line with the rules for the name of the food in Article 17 and Annex VI.
Ingredients present as engineered nanomaterials are indicated with the word 'nano' in brackets after the name.

Order of weight and Annex VII exceptions

The main rule is descending order of weight at the time of use. Annex VII sets out exceptions. Added water and volatile products are listed by their weight in the finished product. Ingredients making up less than 2% of the finished product may be listed in a different order after the other ingredients. Ingredients used in concentrated or dehydrated form and reconstituted during manufacture can be listed by their weight before concentration or dehydration.

Annex VII also allows category names for some ingredients, such as 'vegetable oil' followed by the specific origin, for example 'vegetable oils (palm, rapeseed)', and generic names such as 'cheese' or 'spices' in certain conditions.

Compound ingredients

A compound ingredient is an ingredient that is itself made of more than one ingredient, such as chocolate in a biscuit or mayonnaise in a sandwich. It can be listed under its own name, followed immediately by a list of its own ingredients in brackets. The list of the compound ingredient's ingredients is not required where the compound ingredient makes up less than 2% of the finished product and its composition is defined in EU law, among other conditions. Allergens within compound ingredients must still be declared in every case.

Food additives

Additives and food enzymes must be designated by the name of their functional class, such as 'preservative', 'emulsifier' or 'colour', followed by their specific name or E-number, for example 'emulsifier: soya lecithin' or 'preservative: E202'. Where an additive is derived from an allergen, such as lecithin from soy, the allergen must be named and emphasised.

What does not need to be listed

Article 20 lists constituents that are not ingredients for labelling purposes, including carry-over additives that serve no technological function in the final food, processing aids, and solvents or carriers used in strictly necessary quantities. Article 19 lists foods that do not need an ingredients list at all, such as fresh fruit and vegetables that have not been peeled or cut, carbonated water, fermentation vinegars from a single basic product, and cheese, butter and fermented milk and cream with no added ingredients other than those needed for manufacture.

The essential caveat: none of these exemptions removes the duty to declare allergens. A processing aid derived from an Annex II allergen that remains in the food must still be declared under Article 9(1)(c) and Article 21.

Ingredient lists and restaurants

Restaurants serving non-prepacked food do not need a full ingredients list under the EU regulation unless national rules require it. But bought-in ingredient lists are the raw material for a restaurant's allergen record. Reading them correctly, including compound ingredients and additives with allergen origins, is how a kitchen builds an accurate dish-level record. When a guest asks about an ingredient that is not an allergen, such as pine nuts or coconut, the full ingredients list on the bought-in product is where the answer lies.

Sources

Regulation (EU) No 1169/2011, consolidated text (EUR-Lex)

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.