Food Labelling Translation for the FASFC in Belgium

Importing or distributing a food product in Belgium without compliant labelling exposes the company to severe administrative penalties from the AFSCA. Belgium is a trilingual market with labelling obligations in French and Dutch that apply to the entire national territory. This guide explains what the law requires and the most common mistakes to avoid.

The AFSCA and the Belgian regulatory framework for food labelling

The AFSCA (Federal Agency for the Safety of the Food Chain) is the competent authority in Belgium to control the compliance of food products placed on the market. It inspects food sector operators, controls imports and can order the withdrawal or recall of a non-compliant product.

The main regulatory framework is EU Regulation No. 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers, directly applicable in all Member States. It requires that mandatory particulars appear in a language easily understood by the consumers of the country of marketing. In Belgium, this translates into a labelling obligation in the two official languages of the region where the product is sold, in practice a labelling in French and Dutch for products distributed across the entire Belgian territory.

Which particulars must be translated into FR and NL?

Regulation 1169/2011 defines an exhaustive list of mandatory particulars. All must be translated into the required languages:

• Name of the product: the legal or customary sales name of the product, which cannot be replaced by the brand name alone.
• List of ingredients: with the indication in bold characters of the 14 major allergens (gluten, crustaceans, eggs, fish, peanuts, soy, milk, tree nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin, molluscs).
• Nutritional values: table of the 7 mandatory values (energy, fats, saturated fatty acids, carbohydrates, sugars, proteins, salt).
• Storage and use conditions: instructions for storage after opening, storage temperature, directions for use if necessary.
• Durability date: distinction between the use-by date ("use by") and the date of minimum durability ("best before"). The exact terminology must appear in both languages.
• Country of origin: mandatory for certain categories (fresh meats, honey, olive oil, fresh fruits and vegetables).
• Details of the responsible operator: name and address of the company responsible for placing the product on the market in Belgium.

Allergens: an absolute priority in both languages

Allergen labelling is the obligation most controlled by the AFSCA during its inspections. Regulation 1169/2011 requires that the 14 major allergens be typographically highlighted (in bold, italics or underlined) in the list of ingredients. This highlighting must appear in each language version of the label.

A frequent mistake by importers is to highlight allergens in bold only in the French version, forgetting to do so in the Dutch version. The AFSCA considers this a non-compliance, even if the allergenic substance is indeed mentioned. Organic products do not benefit from any derogation to these rules: the "BIO/EKO" label and the European Organic Farming logo must also comply with the language requirements.

Common importer mistakes and how to avoid them

• Labelling only in French: illegal for products distributed in Flanders or across the entire Belgian territory. Dutch is mandatory in the Flemish Region.
• Poorly positioned translation stickers: the AFSCA accepts overlay labels (stickers), but these must fully cover the original particulars in the unauthorised language and cannot hide mandatory information in the other language.
• Automatic translation without verification: technical terminology errors (notably for nutritional values and allergens) are frequent grounds for withdrawal during AFSCA controls.
• Confusion between use-by and best-before dates: the two particulars have very different legal effects (the use-by date concerns safety, the best-before date concerns quality) and their translation must be precise in both languages.