Country of origin: when it is mandatory, and what it does not state
Origin is not always shown, and it is not always optional. The regulation names specific situations in which it becomes mandatory. Below we explain which those are and what the indication means.
The general rule
Article 26(2)(a) of Regulation (EU) No 1169/2011 states that the indication of the country of origin or place of provenance is mandatory where failure to indicate it might mislead the consumer as to the true origin, in particular where the information accompanying the food, or the label as a whole, would otherwise imply a different origin.
In practice a flag, a landscape or a name pointing to a place can trigger the obligation on its own.
What origin means
It is the country in which the food was wholly obtained, or in which the last substantial processing took place. Processing can therefore move the origin: a raw material from one country processed in another gives the second as the origin.
The meats with a standing obligation
Article 26(2)(b) makes the indication mandatory for fresh, chilled and frozen meat of swine, sheep, goats and poultry, with the detail set out in a separate implementing regulation. Beef is governed by its own, older Union rules.
The primary-ingredient rule
Article 26(3) covers the case where the origin of the food is given and the primary ingredient comes from somewhere else. The origin of the primary ingredient then has to be given as well, or at least indicated as being different.
This has applied since 1 April 2020, under Implementing Regulation (EU) 2018/775. On 30 January 2020 the Commission adopted a Notice on how the provision is to be applied.
How it is written on the pack
In one of two ways. Either by reference to a geographical area — EU, non-EU, EU and non-EU, a region, a member state or a third country — or by wording such as (name of the primary ingredient) does not originate from (the country given for the food), or any similar wording with the same meaning.
Two cases that do NOT trigger the rule
- geographic terms inside customary or generic names, which literally name a place but are not commonly understood as an origin claim
- protected geographical indications and trade marks
Sectors with their own rules
Beef, honey, olive oil, fishery products and fresh fruit and vegetables have their own Union rules on origin, older than or separate from Article 26. For those the pack follows the sector rules rather than the general one.
What origin does not state
The indication names a country or an area, not the conditions of production. It is not a statement about quality, about safety, or about the standards applied. It is geographical information and nothing more.
In a recall
Origin sometimes narrows the scope of a measure, for example where it concerns a plant in a particular country. The identification, however, always rests on the lot or the date. Origin on its own does not decide whether a given pack is covered.
If you have a label in front of you and cannot place the entries: VeraRead reads the label and names its fields, based on the official rules, in plain language.