Extra-virgin olive oil labels, where to position the sector-specific mandatory information

Regulation (EU) No. 29/2012, (1) provides that "The mandatory particulars described in the first paragraph of Article 3 (2) and, where applicable, those described in the first subparagraph of Article 4 (1) [designation of origin, as for virgin and extra-virgin olive oils], shall be grouped together within the principal field of vision, as defined by Article 2 (2) (l) of Regulation (EU) No 1169/2011 of the European Parliament and of the Council, either on the same label or on several labels attached to the same container, or directly on the same container. Those mandatory particulars must each be shown in full and in a homogeneous body of text "(Article 4b).

This provision aims to guarantee the visibility of some essential information about olive oils (ie product category and relevant explanation, production site and olives origin with regard to virgin oils) in the same field of vision. Those informations must therefore be grouped together, in the principal field of vision.

What is intended as 'the principal field of vision'? The Food Information Regulation doesn't mention the 'Front of Pack', while it provides that the food operator can choose amid 'several identical fields of visions' (3) (ie front, back, sides, top, bottom). The Olive oils Regulation provides further flexibility, by allowing to group the essential information either on the same label and on one of 'several labels attached to the same container'.

The mentioned flexibility is furthermore essential, taking into consideration that olive oil bottles are often labeled in view of being placed on several MS markets, within the European internal market. To this end, in line with European food law, mandatory information is offered in more than one 'principal field of vision', as to address the different official languages ​​requirements. Any different interpretation would breach the free movements of goods principle, as provided from the Treaty. (4)

Dario Dongo

Barrister, MBA, Ph.D. in food safety


(1) Commission Implementing Regulation (EU) No 29/2012, of 13 January 2012, on marketing standards for olive oil.   Consolidated text

(2) "The labeling of oils as referred to in Article 1 (1) shall bear, in clear and indelible lettering, in addition to the description referred to in the first paragraph of this Article, but not necessarily close to it, the following information on the category of oil:

(a) extra virgin olive oil: 'superior category olive oil obtained directly from olives and solely by mechanical means';

(b) virgin olive oil: 'olive oil obtained directly from olives and solely by mechanical means';

(c) olive oil composed of refined olive oils and virgin olive oils: 'oil comprising exclusively olive oils that have undergone refining and oils obtained directly from olives';

(d) olive-pomace oil: 'oil comprising exclusively oils obtained by treating the product obtained after the extraction of olive oil and oils obtained directly from olives', or'oil comprising exclusively oils obtained by processing olive pomace and oils obtained directly from olives '. "

(3) "'principal field of vision' means the field of vision of a package which is most likely to be seen at first glance by the consumer at the time of purchase and that enables the consumer to immediately identify a product in terms of its character or nature and, if applicable, its brand name. If a package has several identical principal fields of vision, the principal field of vision is the one chosen by the food business operator; " (Reg. EU No 1169/2011, Article 2.2.l)

(4) See the link