EU tea labeling is governed by one primary regulation with a web of category-specific requirements underneath it. Get a label wrong and a German retailer's QA team holds the shipment. For a tea co-packer producing in Kosovo and shipping to 15+ EU countries, label compliance is not optional final-mile paperwork - it is a production-stage specification that must be locked before the print plate is made. This guide covers every mandatory field under FIC Regulation 1169/2011, multi-language rules, allergen handling for herbal blends, and what changed after Brexit.

FIC Regulation 1169/2011: the framework

The Food Information to Consumers (FIC) Regulation came into force on 13 December 2014. It replaced earlier directives 2000/13/EC and 90/496/EEC and applies directly across all 27 EU member states without national transposition. Imported food sold in the EU must comply.

For tea, FIC intersects with Regulation 1308/2013 (agricultural product naming), Regulation 1924/2006 (if any health or nutrition claims appear), and national language requirements in France, Germany, Belgium, and the Netherlands.

The mandatory fields: complete list

All mandatory information must appear in a location that is conspicuous, clearly legible, and indelible. Minimum font height for mandatory information is 1.2mm (x-height). On packaging with a largest surface area below 80cm², the minimum is 0.9mm.

Country of origin rules for tea

Country of origin for the primary ingredient is mandatory under FIC Article 26. For tea, this means:

• Single-origin tea: Declare the country (e.g., "Origin: India" or "Country of origin: Sri Lanka")
• Multi-origin blend: If origins change seasonally, "Blend of teas from..." with the countries listed, or the general statement permitted under Article 26(2)(b): "Origin: [country] and/or [country]"
• EU blends with non-EU component as primary ingredient: Must declare non-EU origin
• Herbal infusions with multiple botanicals: Country of origin for the primary ingredient by weight

For co-packed products produced in Kosovo, where we source herbs from our own network and provide them to the co-packing client, the origin of the herb material is documented by lot and can be included verbatim on the label.

Nutrition declaration: what tea bags must show

The nutrition declaration is mandatory for all pre-packed foods. There is no category exemption for tea. The declaration must include all eight values:

The reference quantity for tea is typically 100ml of prepared beverage. Some brands present the nutrition declaration per 100ml of infusion and additionally per serving (one tea bag, typically 200ml cup). The per-100ml presentation is sufficient for compliance but per-serving is increasingly expected by German and UK retailers.

For tea bags, all nutrient values are effectively zero at brewed concentrations. The regulation permits "less than 1 kcal" type declarations where values fall below quantification thresholds. However, the table must still be present.

Allergen rules for herbal blends

Standard black, green, white, and oolong teas contain no scheduled allergens under Annex II of FIC. Herbal blends are different.

The 14 allergen categories in Annex II include celery and celeriac, mustard, sesame seeds, nuts (listed individually), and sulphites above 10mg/kg. Herbal blends incorporating any of these must:

1. List the allergen in the ingredients list
2. Highlight it visually (bold typeface, contrasting color, or underlining)
3. May optionally use the cross-contamination advisory "May contain traces of..." only if cross-contamination is a genuine production risk

Common allergen risks in herbal tea blends:

• Celery seed in digestive blends (a scheduled allergen)
• Sesame in some Asian-inspired blends
• Tree nuts (almond pieces in some wellness blends - must declare by specific nut species)
• Mustard in some spiced chai formulations

At the co-packing stage, if you are supplying herbal material, the allergen content of each ingredient must be declared in your raw material specification. If we are sourcing for full production runs, our recipe development process includes allergen mapping before any formulation is finalized.

Multi-language labeling requirements by market

FIC sets minimum standards. Member states can require their official language(s) for mandatory information. Voluntary information can be in any language.

For brands distributing to multiple EU markets on a single SKU, the label must carry all required languages for all target markets. This is standard practice for private label brands in the DACH region and Benelux. The physical label area implications must be factored into artwork at the specification stage - not as an afterthought.

Our 36-year history of exporting to Germany, Austria, and Switzerland means DE-language label compliance is familiar territory. When you work with Balkan Tea on a co-packing project targeting DACH markets, we review German-language mandatory information as part of the pre-production compliance check.

UK labeling requirements post-Brexit

Since 1 January 2021, Great Britain operates under UK food law, which retained most EU FIC requirements with two key modifications: the food business operator address must be a UK (GB) address, and labels sold in GB must carry the UKCA mark (food is exempt, but the operator address requirement is not). Northern Ireland remains under EU rules under the Windsor Framework.

All 14 allergen categories, the 1.2mm font minimum, lot marking, nutrition declaration format, and country of origin rules are unchanged from FIC. The practical difference is that an EU-address-only label is not compliant for GB retail. For brands selling into both EU and UK markets, the standard solution is a dual-address label (EU operator + UK importer/distributor address) or a separate GB SKU. We can produce the same batch with two label variants when artwork is confirmed at specification stage.

Batch/lot coding and traceability

The lot mark (required under Directive 2011/91/EU) must appear on the label and link to the production record. Format is typically "L" followed by an alphanumeric code, or the production date in YYMMDD format. At Balkan Tea, every PT-2.33 production run generates a batch record with the lot code, raw material lot references, weight QC results, and COA references - the full ISO 22000 traceability chain.

Label review as part of co-packing service

A common co-packing scenario: the brand owner provides pre-designed artwork and assumes the label is compliant. A retailer QA reviewer in Hamburg flags a missing lot code format or an incorrect nutrition table column header after production. The batch goes on hold.

We avoid this by building a label compliance review into the pre-production checklist for every EU-bound run: mandatory fields, font size, languages for target markets, allergen highlighting, nutrition declaration format, country of origin specificity, operator address, and lot code format. The check happens before the print plate is made.

For questions on label requirements for your target markets, contact us directly.

See also: Tea pesticide MRL limits EU buyers enforce, MOSH and MOAH in tea bags, audit a tea co-packer, IFS vs BRC for tea certification, our certifications.