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Business advice leaflet

Sandwich labelling

Sandwiches sold by catering establishments only need to be labelled with an indication of any irradiated or genetically modified ingredients. Any name given must be accurate. Sandwiches sold loose or pre-packed, and made on the premises for sale at those same premises, need the same and also a declaration of any additives present.

Pre-packed sandwiches need full labelling including name, ingredients, additives, percentage indication of certain ingredients (QUID - quantitative ingredient declaration), date mark, storage conditions, name and address of the manufacturer and country of origin. There is also a list of 14 specific allergens which must be listed if their presence is not clear in the ingredients list.

The term 'sandwich' includes a roll, bap, baguette, pitta, wrap, panini, bagel and similar products.

In the guide
Catering establishments
Sandwiches sold loose or pre-packed for direct sale
Sandwich manufacturers

Catering establishments
These are premises at which the sandwiches are prepared - they include pubs, restaurants, cafés, takeaways and sandwich bars.

Provided that no claims are made, no labelling at all is required on these sandwiches unless:

  • the sandwich or any ingredient has been irradiated
  • the sandwich contains any ingredient which contains genetically modified material

In these cases the sandwich must be appropriately labelled to the effect that it has been irradiated or treated with ionising radiation and/or that it contains genetically modified material.

Many caterers will want to give a name or description - it is important that this is accurate and correct in order to not be misleading. Areas that can cause problems are butter/margarine, ham/pork shoulder, reformed or chopped and shaped meats, seafood 'sticks'/crab and cheese substitutes.

If pre-packed sandwiches are brought in from another supplier, full labelling, as described below, must be given.

Sandwiches sold loose or pre-packed for direct sale
This means sandwiches sold loose or pre-packed, and made on the premises for sale at those same premises, for instance, bakers shops or mobile sandwich vans that make up their own sandwiches to sell. These are required to have limited labelling, as follows:

  • a name or description
  • a declaration of the category name of any of the following additives if present: preservative, antioxidant, colour*, flavouring, sweetener or flavour enhancer
  • a declaration if the sandwich or ingredients have been irradiated and/or contain genetically modified material, if relevant

[*Products containing the colours Tartrazine (E102), Quinolone Yellow (E104), Sunset Yellow (E110), Carmoisine (E122), Ponceau 4R Blue (E124), and Allura Red (E129) must be labelled with the warning: '(E number/name of colour) may have an adverse effect on activity and attention in children'. More information is available on the Food Standards Agency website.]

As for catering establishments, care must be taken with the description of the sandwich to ensure that it is accurate and not misleading.

While not a legal requirement, you may wish to consider providing information about any allergenic ingredients listed below.

If pre-packed sandwiches are brought in from another supplier, full labelling, as described below, must be given.

Sandwich manufacturers
This includes manufacturers who prepare pre-packed sandwiches and supply a number of other retail and catering outlets.

Pre-packed sandwiches of these types will require full labelling as follows:

  • a name or description (again, care must be taken with the description of the sandwich to ensure that it is accurate and not misleading)
  • a list of ingredients, in descending order by weight
  • should your product contain any additives (such as colours or preservatives) each name or 'E' number must be preceded by the category name of the additive in the ingredients list (see above for specific E numbers requiring full name and customer information)
  • a percentage declaration (QUID) (for named characterising ingredients which might affect consumer choice - for example, ham sandwich, ham 10%)
  • a date mark (durability indication - for sandwiches and similar products, this will be a use by date)
  • storage conditions (for example, keep refrigerated)
  • name and address of the manufacturer, packer or seller
  • origin (if by omitting it might be misleading)

Allergenic ingredients (listed below) and their deriviatives (for example, soy sauce from soya beans) must be labelled on the packaging if they are not mentioned in the name of the food. This only applies to those ingredients specified in the legislation, namely:

  • cereals containing gluten (namely wheat, rye, barley, oats, spelt, kamut or their hybridised strain)
  • crustaceans
  • fish
  • eggs
  • peanuts
  • soybeans
  • milk
  • nuts (namely almond, hazelnut, walnut, cashew, pecan nut, brazil nut, pistachio nut, macadamia nut, Queensland nut)
  • celery
  • mustard
  • sesame seeds
  • sulphur dioxide and sulphates at levels above 10mg/kg or 10mg/1 litre expressed as SO2
  • lupins
  • molluscs

Please also see our business leaflet 'Specified allergenic ingredients - commonly asked questions' for more information.

Also, if applicable:

  • an irradiation declaration
  • a genetically modified material declaration
  • a 'packaged in a protective atmosphere' declaration
  • specific declarations if sweeteners, sugars and sweeteners, aspartame or polyols are present

Also, if any nutritional claims are made (such as low fat or high fibre) nutritional information will be required in the prescribed format.

There are additional labelling requirements if any other claims are made.

Please note that in general van sales, where product is sold from the van, full labelling will not be required, but you are advised to discuss the precise supply route with your local trading standards service.

Please note
This leaflet is not an authoritative interpretation of the law and is intended only for guidance. Any legislation referred to, while still current, may have been amended from the form in which it was originally enacted. Please contact us for further information.

Relevant legislation
Food Labelling Regulations 1996

Last reviewed/updated: December 2012

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