- 05/06/2026
- Posted by: Marta
- Category: Questions and answers
Dear Dario good morning,
Our supermarket chain was charged with an administrative violation because the word "cheese" did not precede the word "Nostrano di Crodo" on the pre-packaged product. I therefore ask you if, applying the same logic, we should specify the cheese nature of products such as Parmigiano Reggiano, Grana Padano, mozzarella, mascarpone, and ricotta.
Thank you very much, [signed letter]
The lawyer Dario Dongo, Ph.D. in European food law, answers
The Food Information Regulation (EU) No 1169/11 indicates the name of the food First among the mandatory information to be included on labels (Article 9.1.a). The criteria for its indication are simple, at least on the surface:
'The name of the food is its legal name. Failing this, the name of the food is its usual name; where a customary name does not exist or is not used, a descriptive name is provided'(EU reg. no. 1169/11, article 17.1).
'The name of the food is not replaced with a name protected as an intellectual property, trademark or fancy name'(EU reg. no. 1169/11, article 17.4).
Legal name of cheeses
The CMO (Common Market Organisation) Regulation (EC) No. 1803/13, Annex VII, Part 3 reserves 'only to dairy products' a series of legal names including that of cheese.
In Italy, the Royal Decree-Law n. 2033/1925 still in force reserves the name of 'cheese' or 'cacio' to the 'product obtained from whole or partially skimmed milk, or from cream, following acid or rennet coagulation, even using ferments and cooking salt' (article 32).
Conclusions
A literal interpretation of Article 17 of Regulation (EU) No. 1169/11 implies that – given the existence of a legal cheese denomination – this wording must be included on the labels of foods so qualified. That is, in the cases reported, for Nostrano di Crodo, Parmigiano Reggiano, Grana Padano, the mozzarella cheese and mascarpone . Not even for the ricotta cheese, which does not qualify as cheese because it is made from whey and through thermal coagulation, rather than acid or rennet.
It is also recalled that the name of the food must be placed on the label in the same visual field as its quantity (EU regulation no. 1169/11, article 13.5).
Administrative sanctions
It is worth noting that Law No. 75/2026 reformed Legislative Decree 231/2017 by introducing draconian administrative pecuniary sanctions – up to 3% of total turnover of the operator in the financial year preceding the date of ascertainment of the violation, up to a limit of 100.000 euros, unless the act constitutes a crime – for violations of the provisions in question.
Cordially
Dario
Credit cover Bertolino
References
– Legislative Decree No. 231 of June 8, 2001. Regulation of the administrative liability of legal entities, companies, and associations, including those without legal personality, pursuant to Article 11 of Law No. 300 of September 29, 2000. Normattiva (last updated on January 9, 2026). https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2001-06-08;23
– Law No. 75 of April 21, 2026, Sanctioning Provisions for the Protection of Italian Food Products. Official Journal No. 110 of May 14, 2026 https://www.gazzettaufficiale.it/eli/id/2026/05/14/26G00089/SG
– Royal Decree-Law no. 2033 of October 15, 1925, converted by Law no. 562 of March 18, 1926. Suppression of fraud in the preparation and trade of agricultural substances and agricultural products. Legislation (last updated on February 19, 2011).
– Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers. Consolidated text: 04/01/2025 http://data.europa.eu/eli/reg/2011/1169/2025-04-01
– Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 establishing a common organization of the markets in agricultural products and repealing Council Regulations (EEC) No 922/72, (EEC) No 234/79, (EC) No 1037/2001 and (EC) No 1234/2007. Consolidated text: 03/18/2026. http://data.europa.eu/eli/reg/2013/1308/2026-03-18
