Are peel-off labels allowed on food products?

Many producers find it impossible to put all the mandatory information visibly on the label. This is especially difficult when multiple languages must be printed on the label. One possible solution is a peel-off label. But is a peel-off label actually allowed?

A peel-off label is a label that is folded together like a booklet. Some of the mandatory information can be seen on the front, but the rest of the label information requires the consumer to open the label. Peel-off labels are mainly used for products that require multiple languages to be printed on them. You also find them on products - such as dessert glasses - where there is very limited space to put a label. There are currently no legal rules established for the use of peel-off labels. For cosmetics and medicines, a peel-off label is a commonly used solution.

Visibility mandatory information

Article 12(2) of Regulation (EU) 1169/2011 states that mandatory food information must appear directly on the package or on a label attached to it. Article 13(1) states that all legally required information must be displayed in a clearly visible place and in clearly legible and indelible letters. When using a peel-off label, all legal information is not immediately visible, as the consumer must first perform an action. The European Commission indicated in its communication that in the case of peel-off labels, compliance with the legal requirements must be assessed on a case-by-case basis. In the English version of this communication, the word "removable labels" has been translated into "peel-off labels.

Points of attention peel-off label

Thus, the law does not prohibit the use of peel-off labels. In principle, peel-off labels should only be used in exceptional cases when it is really impossible to include all the mandatory information on the label. This should be assessed on a case-by-case basis. If peel-off labels are used, however, there are a number of points of attention. These points of attention correspond to the mandatory information for a label whose largest surface area is less than 10 cm². These points of interest are as follows:

The legal name, net quantity, expiration date and allergens must be listed on the front of the peel-off label in each language appropriate to the countries where the product is sold.
It is important to have a clear logo listed from which the consumer can tell how to open the peel-off label.
There should also be further instructions for consumers on the front that clearly state what they need to do to find the other information, such as the ingredient list, on the peel-off label. This can be done, for example, by means of an arrow. This information should also be listed in each language associated with the countries where the product is sold.

Products where peel-off labels are common

The use of peel-off labels is legally regulated for cosmetic products in Article 19 paragraph 2 of Regulation (EU) 1223/2009. This states that mandatory indications may also appear on a leaflet, attached label or strip, together with a reference to the other information by means of a brief indication. The logo that can be used is legally defined in Annex VII, part 1 of that Regulation. A peel-off label is also often used for medical products. As with food products, this is not established by law, but there are many guideline documents establishing rules on the use of peel-off labels for medical products.