Reading the Label with Confidence: Chapter IV and the Labelling of Food Additives
How the EU guarantees your right to know which additives are in your food – a guide by InfoCons
Transparency is the heart of consumer protection – InfoCons Consumer Protection
An additive can be perfectly safe and fully authorised, yet consumer protection is incomplete unless the information reaches the person who buys and eats the food. Chapter IV of Regulation (EC) No 1333/2008, covering Articles 21 to 25, is dedicated entirely to labelling. It ensures that additives are not hidden but declared, in clear terms, so that consumers and professional buyers alike can make informed decisions. For InfoCons – Consumer Protection, this chapter expresses a right that lies at the core of our mission: the right to know.
Labelling of additives not intended for the final consumer – InfoCons Consumer Protection
Article 21 deals with food additives that are not intended for sale to the final consumer – for example, additives sold from one business to another. Whether sold singly or mixed with each other and/or with food ingredients, such additives may be marketed only with the labelling set out in Article 22, which must be visible, clearly legible and indelible. The information must be given in terms easily understood by purchasers. Member States may require that this information be provided in one or more official languages of the Union.
Article 22 then lists, in detail, the information that must appear on the packaging or containers of such additives. This includes: the name and/or E number laid down by the regulation for each additive, or a sales description including that name and/or E number; the statement for food or for restricted use in food, or a more specific reference to the intended food use; if necessary, the special conditions for storage and/or use; a batch identification mark; instructions for use, where their omission would lead to improper use; the name or business name and address of the manufacturer, packer or seller; an indication of the maximum quantity of each component or group of components subject to a quantitative limit in food, and appropriate information enabling the purchaser to comply with the regulation or other relevant Union law; the net quantity; the date of minimum durability or the use-by date; and, where relevant, information on any additive or other substance listed as a potential allergen under the applicable labelling rules.
Where additives are sold mixed with one another and/or with other food ingredients, the packaging must show a list of all ingredients in descending order of their percentage of the total. Where substances are added to additives to facilitate storage, sale, standardisation, dilution or dissolution, the packaging must list all such substances in descending order of their proportion of the total. Certain details may, by way of derogation, appear only on the accompanying trade documents supplied with or before the delivery, provided the words not for retail sale appear in an easily visible place.
Labelling of additives sold to the final consumer – InfoCons Consumer Protection
Article 23 covers food additives intended for sale to the final consumer. Without prejudice to other Union labelling rules, such additives, sold singly or mixed with each other and/or with other food ingredients, may be marketed only if the packaging displays: the name and E number laid down by the regulation for each additive, or a sales description including the name and E number for each additive; and the statement for food or for restricted use in food, or a more specific reference to the intended food use.
The regulation adds specific rules for table-top sweeteners. Their sales description must include the words based table-top sweetener, completed by the name of the sweetening substance or substances used in their composition. The labelling of a table-top sweetener containing polyols and/or aspartame and/or the aspartame-acesulfame salt must carry the following warnings: for polyols, excessive consumption may produce laxative effects; for aspartame or the aspartame-acesulfame salt, contains a source of phenylalanine. Manufacturers of table-top sweeteners must also make available, by appropriate means, the information needed for their safe use.
The warning for certain colours: a landmark for consumer information – InfoCons Consumer Protection
Article 24 introduces an additional labelling requirement for foods containing certain food colours. Without prejudice to other Union labelling law, the labels of foods containing the food colours listed in Annex V must include the additional information set out in that annex. This provision is the legal basis for one of the best-known consumer warnings in Europe: certain colours must be accompanied by a statement that they may have an adverse effect on activity and attention in children.
This requirement shows how labelling can go beyond the mere naming of a substance to actively communicate a potential effect, empowering parents in particular to make choices for their children. Article 24 also provides that Annex V may be amended in the light of scientific and technical progress.
Other labelling requirements and how they fit together – InfoCons Consumer Protection
Article 25 clarifies that Articles 21 to 24 apply without prejudice to more detailed or more extensive laws and administrative provisions on weights and measures or on the presentation, classification, packaging and labelling of dangerous substances and preparations, or on the transport of such substances or preparations. In other words, the additive labelling rules coexist with, and do not override, other specialised legal requirements.
It is also essential for consumers to understand how additive declarations appear in the ingredient list of ordinary retail foods. As a rule, an additive is indicated by the name of its functional class – for example preservative, colour or antioxidant – followed either by its specific name or by its E number. So a label may read preservative E 202 or colour curcumin. This standardised approach means the information you need is always legally required to be present.
Functional class plus name or E number: decoding the ingredient list – InfoCons Consumer Protection
The genius of the European labelling approach lies in its dual naming system. Every additive in an ingredient list is introduced by its functional class, which tells you what the substance does, and then identified either by its specific name or by its E number, which tells you exactly which substance it is. So antioxidant ascorbic acid and antioxidant E 300 convey the same information in two interchangeable forms. This means that even if you do not recognise a particular chemical name, the functional class already tells you its role, and the E number lets you look it up precisely.
This system also defeats a common fear – that E numbers are a way of hiding information. In fact, the opposite is true. The E number is a transparent, standardised, cross-border identifier. It is arguably clearer than a long chemical name, because it is unambiguous and language-independent. A consumer in Bucharest, Berlin or Barcelona can read E 330 and know it refers to citric acid, regardless of the language on the rest of the pack.
Understanding functional classes therefore multiplies the value of every label you read. Once you know that the 100-series generally denotes colours, the 200-series preservatives, the 300-series antioxidants and acidity regulators, and the 400-series thickeners, stabilizers and emulsifiers, an ingredient list stops looking like a random code and starts telling a coherent story about how the product was made and preserved.
Why the children colours warning is a milestone – InfoCons Consumer Protection
The additional labelling requirement introduced by Article 24 for certain colours deserves special attention because it goes further than simply naming a substance. For the colours listed in Annex V, the label must carry a specific statement warning that they may have an adverse effect on activity and attention in children. This transforms the label from a passive list into an active communication of a potential effect, aimed squarely at helping parents make choices for their children.
For InfoCons – Consumer Protection, this provision is a template for what consumer information can achieve. It shows that transparency is not only about disclosure but also about meaningful, actionable guidance. A parent scanning a brightly coloured sweet or drink is given, right on the pack, the information needed to decide whether that product belongs in the family basket. It is precisely this kind of clear, targeted communication that empowers everyday decisions.
From business-to-business labels to the family kitchen – InfoCons Consumer Protection
A striking feature of Chapter IV is that it protects information at every stage of the supply chain, not only at the supermarket shelf. The detailed requirements of Articles 21 and 22 for additives that are not intended for the final consumer ensure that food manufacturers themselves receive precise, complete data about the additives they buy: names and E numbers, conditions of storage and use, batch identification, quantitative limits, durability dates and more. This upstream transparency is what makes downstream transparency possible.
In other words, the label a family reads in the kitchen is the last link in a chain of information that began between businesses. If a manufacturer did not know exactly which additive it was using, at what maximum quantity and under what conditions, it could not correctly declare that additive to the consumer. Chapter IV therefore builds transparency into the entire journey of an additive, from producer to processor to shopper.
For InfoCons – Consumer Protection, this end-to-end logic is important to highlight, because it shows that consumer protection is not a single sticker on a pack but a continuous discipline of accurate information. Every actor in the chain is bound by rules designed, ultimately, so that the person eating the food can know what is in it.
Turning your right to know into a daily habit – InfoCons Consumer Protection
Chapter IV guarantees that additives are declared, that professional buyers receive detailed technical information, that table-top sweeteners carry safety warnings, and that certain colours come with a specific caution about children. The information is there, by law. The remaining challenge for consumers is practical: reading and understanding it quickly, in the few seconds spent in front of a shelf. That is precisely where modern tools can transform a legal right into an everyday advantage.
The deeper lesson of Chapter IV is that a right you cannot easily exercise is only half a right. European law does its part by requiring additives to be declared clearly and consistently. Consumers complete the picture by learning to read those declarations – and by using practical aids that translate E numbers instantly and add up how many additives a basket or a meal really contains. Information plus interpretation equals genuine, everyday consumer protection.
The InfoCons Additives Calculator: how many additives are really in your basket? – InfoCons Consumer Protection
Understanding the law is one thing; seeing what it means for your own shopping basket is another. A single processed product can contain several additives at once, and an ordinary weekly shop can add up to dozens or even hundreds of additive occurrences once you sum every product together. What is more, the same additive can appear in many different products in the same basket, which means it enters the consumer’s diet repeatedly.
To answer this, InfoCons – Consumer Protection offers consumers the Only Additives Calculator for the food products bought or consumed. It is the only calculator for food shopping that shows the number of additives present and how many times a given additive is found in the shopping basket. Instead of looking at each product in isolation, the consumer gets a complete picture of the whole basket, seeing the real, cumulative number of additives being purchased.
The same logic applies to a single meal. A breakfast, a lunch or a dinner can bring together several processed products, each with its own set of additives. When these products are eaten together, the additives add up. A seemingly simple meal can, in reality, mean the simultaneous consumption of a surprisingly large number of food additives – colours, preservatives, emulsifiers, flavour enhancers, stabilizers and more. That is why the question “how many additives do I consume at one meal?” is just as important as “how many additives am I buying?”
As a practical solution, the InfoCons application helps consumers identify additives quickly. By scanning the barcode of an agri-food product, the app identifies the product and shows the food additives it contains, turning the “E” codes on the label into clear, easy-to-understand information. In this way, consumers can see how many additives are cumulated in their shopping basket or even in a single meal, and can make informed choices for themselves and their families – right there, in front of the shelf.
Signed:
InfoCons Consumer Protection Department of Studies and Comparative Testing