Food label language requirements in Italy

Italy's explicit Italian-language duty covers vending machines and non-prepacked foods. For prepacked foods the Union rule applies directly — a distinction almost nobody states.

What the Italian decree actually says

Italy implemented Reg. (EU) 1169/2011 through Decreto Legislativo 15 dicembre 2017, n. 231. Reading it end to end, the explicit Italian-language duty appears in two places, and both are narrower than the general rule exporters assume.

Art. 18(2) covers foods sold through vending machines and automated retail premises: the particulars required by Art. 18(1) must be given in Italian, clearly visible and legible. Art. 22 attaches an administrative penalty of 1,000 to 8,000 euro where those particulars are not in Italian.

Art. 19(10) covers foods sold without prepackaging — loose, packed at the point of sale at the consumer's request, or prepacked for direct sale: the particulars of that article must likewise be in Italian, clearly visible and legible.

Prepacked foods run on the Union rule

D.Lgs. 231/2017 makes no equivalent stipulation for prepacked foods. We have not identified a further Italian instrument stipulating a language for them.

That does not leave prepacked food unregulated. Reg. (EU) 1169/2011 Art. 15(1) applies directly — it is a Regulation, not a Directive, so it binds without any national implementing text — and it requires the mandatory particulars in a language easily understood by consumers in the Member State where the food is marketed. In Italy that is Italian.

The practical answer is therefore the same: put Italian on the pack. What differs is the legal route, and it matters if you are citing an authority in a compliance file — citing D.Lgs. 231/2017 for a prepacked language duty would be citing the wrong thing.

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 Italian.

For vending and non-prepacked sales that duty is stated expressly in the Italian decree; for prepacked it follows from Art. 15(1) directly.

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 an Italian pack

For ordinary prepacked retail, build in Italian and treat the Union rule as the basis. If you sell through vending machines or supply non-prepacked food, the Italian decree names your duty expressly and attaches a penalty to it.

LabelYog builds the Italian declaration from your recipe alongside any other language you select.

At a glance

• Italian present for all mandatory particulars
• Vending / automated retail: expressly required by D.Lgs. 231/2017 Art. 18(2)
• Non-prepacked foods: expressly required by Art. 19(10)
• Prepacked: the basis is Reg. 1169/2011 Art. 15(1), applying directly
• Do not cite D.Lgs. 231/2017 as the authority for a prepacked language duty
• 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

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