EU compliance5 min read
Abmahnung Nährwertangaben Online Shop: A Food Page Checklist
Worried about an Abmahnung over missing Nährwertangaben? A checklist of the Reg. (EU) 1169/2011 food information to review on each Shopify product page.
In this guide
You sell food through Shopify to customers in Germany, and you have read about shops receiving an Abmahnung over missing information on their product pages. You open a few of your own products: the nutrition table is a blurry photo of the pack, the allergens sit somewhere in a paragraph, and some products have the information while others do not. You are not sure where the gaps are.
This article helps you review your catalogue product by product. One note first: this is a practical checklist, not legal advice, and it does not guarantee that your shop complies with the law. For a conclusion about your specific obligations, ask a lawyer or an adviser who specialises in food law and e-commerce.
Why the product page matters
Regulation (EU) No 1169/2011 on the provision of food information to consumers also applies to distance selling. For prepacked food sold online, Article 14 says the mandatory food information, except the best before or use by date, must be available before the purchase is concluded, on the material supporting the sale or through other clearly identified means. For an online shop, that material is usually the product page. So a page with missing information is easy to notice, even when the pack itself is labelled in full.
Many small shops handle this with a photo of the label, or by building tabs, accordions and metafields in their theme by hand. Three problems come up again and again: label photos are hard to read on a phone, allergens are not emphasised inside the ingredient list, and every product is laid out differently, so it is hard to see which ones are incomplete.
Checklist: what to review on each product page
For each product, check the items below. Not every item applies to every food, so compare with the regulation or your adviser. Our guide to EU allergen and food information for online food shops lists the mandatory particulars of Article 9 in full.
- Name of the food. A clear name that says what the product is, not only a brand name.
- List of ingredients, with allergens emphasised inside it, for example in bold.
- Nutrition declaration: energy, fat, of which saturates, carbohydrate, of which sugars, protein and salt, per 100 g or per 100 ml. Our guide to the EU nutrition declaration format covers the layout.
- Net quantity, such as 250 g or 500 ml.
- Storage conditions and instructions for use, where the food needs them.
- Food business operator: the name or business name and address of the operator responsible for the information.
- Country of origin or place of provenance, where the product falls under the cases that require it.
- “May contain” wording, if you use it, written consistently across products.
- Language. If you sell into Germany, the information has to be in a language customers there easily understand, which in practice means German.
The best before or use by date is not needed on the page before purchase under Article 14, but it has to be available at delivery. If you are unsure how this applies to your products, ask your adviser.
How to review your shop step by step
- List your food products. Include every product you sell into the EU, also the ones that rarely sell.
- Open each page on a phone. Can you read the nutrition table? If it is an image, is it still sharp when you zoom in?
- Check the allergens. Are they named in the ingredient list and emphasised there, or do they only appear in a photo? The free EU allergen checker shows which of the 14 Annex II allergens a list contains, as an aid to that check.
- Check the operator details. Do the name and address appear, and are they the same on every page?
- Write down what is missing for each product in a simple sheet, one row per product and one column per checklist item, then fill the gaps in order of priority.
- Repeat the review whenever you add products or a recipe changes.
For ten products this is a quick job by hand. With a few dozen, steps 2 to 5 are where things get missed, because every page has to be opened and read.
Keep the information in one structured place
Gaps are easiest to see when every product holds its food information in the same fields, rather than in free-form descriptions or images. Then a missing value is an empty field you can spot, not a sentence you have to look for.
A structured editor helps you find empty fields. It does not tell you whether what you entered is correct or whether your shop complies. You still need to check the values against the real product and its packaging.
What Etiketto: EU Nutrition Labels does for your product pages
Etiketto: EU Nutrition Labels is an app for food shops selling into the EU. It shows the food information Regulation (EU) No 1169/2011 requires on your product pages: a nutrition table, ingredients with allergens in bold, and the operator.
- One editor per product. Nutrition per 100 g, ingredients, the 14 EU allergens, net quantity, storage, origin and the operator sit on one screen, so a product with an empty field stands out when you open it.
- Allergens in bold where you mark them. Wrap an allergen in asterisks in the ingredient list, such as
*milk*, and the product page shows it in bold. The app does not detect allergens; only the words you mark are emphasised. - A theme block, no Liquid. Add the Food information block to the product template of an Online Store 2.0 theme. The nutrition table and ingredients show as text on the page, not as an image.
The values come from you. The app shows them; it does not calculate them, and it does not make a page compliant by itself. What you enter decides what the buyer sees.
For the theme side in more detail, see how to show a nutrition table and bold allergens without Liquid.
Start with your catalogue
If an Abmahnung worries you and you do not yet know which products are incomplete, start by getting the whole catalogue into the same structure. Install Etiketto: EU Nutrition Labels from the Shopify App Store, fill in your first products from the checklist above, and check the live pages against the packs.
This article is general information, not legal advice.