UK Food & Drink Labelling Address Requirements

Key Requirement:

Food and drink products placed on the UK market must include on the label either:

• the name and address of a UK-based Food Business Operator (FBO); or
• where the FBO is not established in the UK, the UK importer.

This cannot simply be a ‘post-box’ or forwarding address, it must be a genuine operational contact point where your business can:

• be contacted by consumers and regulators; and
• meaningfully respond, in a timely manner, to complaints, enquiries and enforcement action.

What the Address Must Enable:

In practice, the address appearing on the label is expected to be one at which the responsible entity can:

• receive and deal with consumer complaints (including allergen or safety concerns);
• engage directly with Trading Standards or other competent authorities;
• respond promptly to information requests or improvement notices; and
• manage product-related issues such as investigations, withdrawals or recalls.

Simply forwarding correspondence is not sufficient for these purposes.

When We May Be Able to Offer Use of Our Address:

In some cases, where there is genuine UK substance in the UK, we may be able assist you by providing the use of our office address.
In order to be able to use our address we will generally require that you have:

• an established UK operational presence; and
• at least one individual based in the UK who is authorised and equipped to:
  • respond to consumer queries;
  • liaise directly with Trading Standards and other regulators; and
  • manage product issues, including complaints, investigations, withdrawals and recalls.

If you do not have the above, the use of our address is not appropriate as the address on the label would not meet the purpose of the legislation.

In cases where we can offer use of our address:

• responsibility for compliance and engagement will sit with your UK business;
• your UK individual will be responsible for dealing with queries, issues and general responses; and
• our address is used only as an administrative location, and not as the operational hub for food law compliance.

Other Options:

Where you are not a registered FBO, and we can’t offer the use of our address, you can instead consider:

• the address of your UK-based importer, distributor or other member of your supply chain; or
• another UK-based third party who can act as an agent, such as an import agent or FBO with real operational capability.

Enforcement and Penalties:

Failure to comply with food labelling and consumer information requirements can result in:

• improvement notices and fines (including under the Food Information Regulations); and
• in serious cases (for example, allergen or safety breaches), unlimited fines.

There may also be exposure under wider consumer protection legislation where complaints or safety concerns are not handled appropriately, potentially resulting in significant penalties.