Food label language requirements in Luxembourg
Luxembourg accepts French, German or Luxembourgish -- at least one of them. English alone is never sufficient.
Any one of three, but not English
The Règlement grand-ducal du 25 août 2015 Art. 2 is Luxembourg's Art. 15(2) national measure. It requires the mandatory particulars in at least one of French, German or Luxembourgish.
The important half of that rule is what it excludes. English is widely used in Luxembourg commercially, but it does not satisfy the labelling requirement on its own -- an English-only pack is not compliant.
Why exporters get this wrong
Luxembourg's multilingual business environment makes an English pack feel safe. The national measure is explicit that at least one of the three named languages must be present, so English can accompany but never substitute.
A French or German pack built for a neighbouring market usually satisfies Luxembourg without additional translation, which makes this a cheap gap to close once you know about it.
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 French, German or Luxembourgish.
English may sit alongside, but each particular below must be readable in whichever of the three you have chosen.
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 Luxembourg pack
If you already produce a French or German pack for France, Belgium, Germany or Austria, that pack generally answers Luxembourg's language rule.
LabelYog builds the declaration in each language you select from one recipe, so adding French or German alongside English is a selection, not a rewrite.
At a glance
- At least one of French, German or Luxembourgish present
- That language carries ALL mandatory particulars
- English alone is NOT sufficient -- it may only accompany
- An existing French or German pack usually satisfies the rule
- All Reg. 1169/2011 mandatory particulars present
- 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
Can I sell an English-only label in Luxembourg?
No. The Règlement grand-ducal du 25 août 2015 Art. 2 requires at least one of French, German or Luxembourgish; English alone never suffices.
Do I need all three languages?
No -- at least one of the three is enough.
Does my French pack for France work in Luxembourg?
On the language point, yes -- French is one of the three permitted languages.
Which law sets this?
The Règlement grand-ducal du 25 août 2015 Art. 2, Luxembourg's Art. 15(2) national measure under Reg. (EU) 1169/2011.
Does the language rule apply to every mandatory particular?
Yes. Reg. 1169/2011 Art. 9(1) lists the mandatory particulars and the language requirement applies to all of them, not to the product name alone.
How small can the mandatory text be?
Art. 13(2)-(3) sets a minimum x-height of 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.
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