Before finalizing packaging artwork for EU markets, this checklist covers the specific points where FMCG and CPG labels most commonly create compliance exposure — drawn from the requirements covered in the Food & FMCG Allergen and Packaging Labeling guide. Work through each section against the SKU or product family under review, and confirm the deadlines listed against your current production and stock timelines.
This checklist is a working reference, not a substitute for the full regulatory text. Verify specific requirements against EU Regulation 1169/2011, national PAL guidance, Commission Regulation (EU) 2024/3190, and Regulation (EU) 2025/40 (PPWR) before finalizing any label.
Allergen Declaration
☐ All fourteen EU-regulated allergens (Annex II, Regulation 1169/2011) present in the formulation are declared in the ingredient list
☐ Declared allergens are emphasized through consistent typography (bold or equivalent) distinguishing them from the rest of the ingredient list
☐ Allergen highlighting has been verified in every language version — not just the source language
☐ Allergens present in compound or composite ingredients are declared, even where the compound ingredient's name doesn't obviously indicate them
☐ Ingredient list order reflects current formulation — not a previous version carried forward after a reformulation
Precautionary Allergen Labeling (PAL)
☐ "May contain" or equivalent statements are based on a documented risk assessment, not applied defensively without cross-contamination risk data
☐ If selling into the Netherlands: PAL wording and thresholds meet the national policy in force since January 1, 2026
☐ PAL wording has been checked per target market — a single EU-wide PAL approach may not meet all national requirements, since EU-wide harmonization is not yet in force
☐ PAL statement names the specific allergen(s), not a vague generic reference
☐ PAL is not used as a substitute for declaring an allergen actually present in the formulation
Food Contact Material — BPA and Bisphenols
☐ Packaging material has been checked against Commission Regulation (EU) 2024/3190's list of restricted bisphenols (BPA, BPS, BPAF, TBBPA, and others)
☐ Single-use food contact materials comply by July 20, 2026
☐ Reusable food contact materials comply by July 2027 (or the applicable extended deadline for specific categories)
☐ A current Declaration of Compliance is on file confirming BPA has not been used in the material's manufacture
☐ Any "BPA-free" or similar on-pack claim has been verified against the regulation's actual defined scope
Food Contact Material — PFAS
☐ Packaging has been tested or verified against the PPWR PFAS limits: below 25 ppb for any single targeted substance, below 250 ppb for the sum of targeted substances, below 50 ppm for total PFAS including polymeric compounds
☐ Compliance is documented through analytical verification and a Declaration of Compliance — a non-use declaration alone is not sufficient under PPWR
☐ PPWR PFAS compliance is confirmed for August 12, 2026 (no grandfathering — non-compliant stock cannot be placed on market after this date, regardless of manufacture date)
☐ If using paper or cardboard packaging: checked separately against the PFHxA restriction under REACH, effective October 11, 2026
☐ Packaging supplier has confirmed which PFAS substances, if any, are used as production aids or additives
PPWR — Broader Requirements
☐ Packaging design meets applicable recyclability criteria under Regulation (EU) 2025/40
☐ Restricted substance limits (lead, cadmium, mercury, hexavalent chromium, and PFAS) are met
☐ Recyclability labeling, where required, is present and accurate
☐ Compliance documentation (third-party testing, certification, or periodic audit records) is on file
☐ General PPWR applicability from August 12, 2026 has been factored into production and stock timelines
Front-of-Pack Nutrition Labeling
☐ FOP treatment (Nutri-Score, national scheme, or none) has been confirmed per target market, not assumed consistent across the EU
☐ Nutritional declaration format meets Regulation 1169/2011 requirements regardless of whether an FOP scheme is also displayed
☐ UK-market versions have been checked separately against the current UK framework where it diverges from the EU approach
Multilingual and Multi-Market Verification
☐ Every language version required for the target market(s) is present and current
☐ Allergen declarations and highlighting have been cross-checked across all language versions against each other, not just individually against the master
☐ Barcode (EAN-13, GS1-128, or QR) has been decoded and verified against the approved GTIN
☐ Barcode has been graded to ISO/IEC quality standards before the file reaches the print vendor
☐ Net content declarations use correct units for the target market
Documentation and Audit Trail
☐ The comparison or review process used to verify this label produces a timestamped, documented record
☐ Each artwork revision is traceable to the specific regulatory driver that prompted it (allergen update, BPA/PFAS reformulation, PPWR compliance, etc.)
☐ Sign-off is tied to a specific, identifiable document version, not a file name that could apply to more than one revision
☐ Records are retrievable without reconstruction in the event of a regulatory inquiry or audit
If any item above is unchecked or uncertain, that is the specific point to resolve before the label is finalized. The most consistent source of FMCG/CPG labeling exposure is not any single regulation in isolation — it's a packaging or artwork revision made for one requirement (a BPA-driven material change, a PPWR recyclability update) that isn't verified against everything else on the same label, in every market and language version affected.
↗ Content Compare verifies allergen declarations, INCI names, barcodes, and layout against your approved master — across every SKU, every language, and every market version, in a single session. Request a demo at informait.com.