Food label language requirements in Germany

German is mandatory on food labels in Germany — with one narrow derogation for food placed on the market in air traffic, and even there the ingredients must still be in German.

The rule: German for everything 1169 makes mandatory

Germany's national measure is the Lebensmittelinformations-Durchführungsverordnung (LMIDV). It is the German implementing regulation for Reg. (EU) 1169/2011; we cite it for what we read in it, and we do not characterise which Article of Reg. 1169/2011 it was made under, because we have not read a statement to that effect. Its § 2(1) requires food to be labelled in German wherever the labelling is mandatory under the LMIDV itself, under Reg. (EU) 1169/2011, or under EU legal acts based on Reg. 1169/2011.

That phrasing matters: the duty attaches to whatever those instruments make mandatory. It is not a rule about the product name — it reaches the ingredient list, the allergens, the nutrition declaration, the dates, the operator and the rest.

The air-traffic derogation, and its limit

LMIDV § 2(2) contains a derogation an exporter would never guess. Food placed on the market IN AIR TRAFFIC may be labelled in another easily understood language instead of German.

But the derogation stops short of the whole label: the information on ingredients and processing aids under Art. 9(1)(c) of Reg. 1169/2011 must ALWAYS also appear in German. So an airline-catering pack may carry English throughout — and still has to carry its ingredients in German alongside.

If you supply airline catering into Germany, this is the clause that decides your artwork. For every other channel, § 2(1) applies in full.

Nutri-Score in Germany is voluntary — and it is a trade mark

Germany is the market most associated with Nutri-Score, and the legal position is widely misstated. LMIDV § 4a(2) is explicit: the use of the Nutri-Score mark is VOLUNTARY.

§ 4a(1) permits the responsible operator under Art. 8(1) or 8(4) of Reg. 1169/2011 to place food on the market bearing the Nutri-Score mark shown in the LMIDV's Annex — a mark registered as an EU COLLECTIVE TRADE MARK at the European Union Intellectual Property Office.

That registration is the practical catch. Under § 4a(3), using the mark requires the operator to have obtained the trade mark proprietor's consent AND to comply with the proprietor's conditions of use. You cannot simply add Nutri-Score to a pack because it appears on a competitor's; it is licensed. § 4a(4) lets the federal ministry publish model forms and a forwarding address in the Bundesanzeiger for obtaining that consent.

What else Reg. 1169/2011 makes mandatory

Language is one requirement among many, and the language rule applies to ALL of them. Reg. (EU) 1169/2011 Art. 9(1) sets the mandatory particulars: the food name, the ingredient list, allergens, QUID where it applies, net quantity, the date, storage and use conditions, the responsible operator, origin where required, instructions for use, alcoholic strength above 1.2% vol, and the nutrition declaration. Every one of them has to appear in German.

German is the compliance language for the whole of that list, not for the product name alone — and the air-traffic derogation below is the only place the LMIDV lets any of it appear in another language.

Art. 13(2)-(3) sets how small they may be: an x-height of at least 1.2 mm, or 0.9 mm where the largest surface of the pack is under 80 cm². X-height is the height of a lower-case x — not the nominal point size, which is the mistake that puts a label under the floor while the artwork file says otherwise.

Allergens, QUID and the nutrition table

Art. 21(1)(b) and Annex II require every one of the 14 allergen groups to be emphasised INSIDE the ingredient list by a distinguishing typeset — a different font, style or background. The 14 include the gluten cereals, sulphites above 10 mg/kg, lupin and molluscs. An ingredient list set entirely in capitals emphasises nothing, because nothing distinguishes the allergen from the rest.

Art. 22(1) requires the QUID percentage whenever an ingredient appears in the food's name, is emphasised in words or pictures, or characterises the food.

Arts 30(1), 32(2) and 34(1)-(2) with Annex XV require the full nutrition declaration — energy plus fat, saturates, carbohydrate, sugars, protein and salt — per 100 g or 100 ml, in the Annex XV order, tabular where space permits and linear where it does not.

Dates, the operator and net quantity

Art. 24 and Annex X set the date form, and the two are not interchangeable. “Best before” (with the day shown) or “Best before end” (month and year) is quality dating; “Use by” is safety dating, and after that date the food is deemed unsafe. Using one where the other belongs carries different legal consequences.

Art. 8(1) and Art. 9(1)(h) require the responsible operator's NAME AND ADDRESS — the operator under whose name the food is marketed, or the importer where that operator is not established in the market. A website, an e-mail address or a phone number is not an address.

Art. 23 and Annex IX set net quantity: volume in l, cl or ml, mass in kg or g, with drained weight where the food is glazed or packed in liquid. The ℮ mark is optional — an average-system guarantee — and where it is used it must be at least 3 mm and in the same field of vision.

Building a German pack

For the ordinary retail channel the requirement is straightforward: German across every mandatory particular. Additional languages may sit alongside it.

LabelYog builds the German declaration from your recipe, so the same product data drives the German column as every other language you select.

At a glance

• German present for every particular Reg. 1169/2011 makes mandatory
• Not just the product name — ingredients, allergens, nutrition, dates, operator
• Air-traffic supply: another language permitted under LMIDV § 2(2)
• ...but Art. 9(1)(c) ingredients and processing aids ALWAYS also in German
• Nutri-Score is VOLUNTARY (LMIDV § 4a(2)) — never assume it is required
• Nutri-Score use needs the trade mark proprietor's consent and conditions
• All Art. 9(1) particulars present, x-height >= 1.2 mm (0.9 mm under 80 cm2)
• Annex II allergens emphasised INSIDE the ingredient list
• Operator NAME AND POSTAL ADDRESS -- not a website or e-mail

Questions

You can try the free tools without an account, read what a paid plan adds on pricing, or see how we compare with other label software before deciding anything. Every market we build for has a rule-book page of its own.