Chocolate business

Chocolate Labeling Rules: US, EU and the Gulf

By Oliver BennettPublished October 15, 2026Updated October 15, 202614 min read

A chocolate label has to meet the rules of the market where the bar is sold. The EU, the US and the Gulf each have a general food labeling law with a chocolate standard on top, and the Gulf adds three things an EU or US designer won’t expect: Arabic text, a production date printed next to the expiry date, and paperwork behind any halal claim. What follows is a reading of the legal texts as they stood on October 13, 2026, and it isn’t legal advice.

Labeling is one step in starting a chocolate factory. Registration comes first and is covered in chocolate factory regulations.

Three markets, three rulebooks

Each market splits the work between a general law for every packaged food and a chocolate standard for names and composition. In the EU that means Regulation (EU) No 1169/2011, consolidated April 1, 2025, and Directive 2000/36/EC on cocoa and chocolate products, consolidated November 18, 2013. In the US it means 21 CFR Part 101 for labeling and Part 163 for cacao products, with allergens written into the FD&C Act itself, section 403(w). In the Gulf it means GSO 9 for labeling prepackaged food and GSO 567 for chocolate, both checked at clearance by Saudi Arabia’s food authority, the SFDA.

The table puts the same questions to all three. Gulf cells marked “2013 ed.” come from the 2013 edition of GSO 9; the Gulf section explains why.

What every chocolate label must carry in the EU

Article 9(1) of Regulation 1169/2011 lists twelve mandatory particulars, (a) to (l), and a chocolate bar needs most of them: name, ingredients, allergens, quantity of certain ingredients, net quantity, best-before date, storage conditions, the operator’s name and address, and a nutrition declaration. Country of origin, point (i), applies where Article 26 provides for it, for example when leaving it out could mislead the buyer. Origin wording on chocolate is covered in how to read an origin label.

The operator named on the pack is the business under whose name the food is marketed, or the importer into the EU if that business is outside the Union (Art. 8(1)). A brand or fancy name can sit on the front, but it can’t replace the legal name (Art. 17(4)).

Size matters on small packs. Mandatory text needs an x-height of at least 1.2 mm, or 0.9 mm when the largest surface of the pack is under 80 cm² (Art. 13(2) and (3)). On a pack whose largest surface is under 10 cm², only the name, allergens, net quantity and date have to be on the pack itself, and the ingredient list can be given another way or on request (Art. 16(2)).

A member state may require one or more official EU languages on its territory (Art. 15). Selling online adds a timing rule: everything mandatory except the date has to be available before the purchase is concluded, at no extra cost, and all of it at delivery (Art. 14(1)(a)). For a web shop, that puts ingredients, allergens and the nutrition declaration on the product page.

The nutrition declaration gives the energy value and the amounts of fat, saturates, carbohydrate, sugars, protein and salt (Art. 30(1)). Packs under 25 cm² are exempt (Annex V, point 18), and so are small handcrafted makers selling direct, as set out in chocolate factory regulations. How to write the best-before date is in chocolate shelf life. Health and nutrition claims have their own rules, and Article 7(3) bars any claim that a food prevents, treats or cures a human disease.

The lines only chocolate has

The EU’s chocolate directive reserves the product names and adds two statements no other food carries. Article 3(1) of Directive 2000/36/EC says the sales names in its Annex I “shall apply only to the products referred to therein and must be used in trade to designate them.” The compositions behind “chocolate”, “milk chocolate” and “white chocolate” are compared in real vs compound chocolate. Member states can’t add national rules on top (Art. 4).

Chocolate, milk chocolate, family milk chocolate and the other products listed in Article 3(3) must state their total dry cocoa solids with the words “cocoa solids: … % minimum”. White chocolate, filled chocolate and pralines are not on that list.

If the recipe uses vegetable fats other than cocoa butter, which the directive caps at 5% of the finished product (Art. 2(1)), the label needs “a conspicuous and clearly legible statement: ‘contains vegetable fats in addition to cocoa butter’.” Article 2(2) also fixes the layout: same field of vision as the ingredient list but clearly separated from it, lettering at least as large and in bold, with the sales name nearby. The six permitted fats are listed under compound chocolate.

Quality wording carries its own thresholds. A quality descriptor on “chocolate” needs at least 43% total dry cocoa solids, including at least 26% cocoa butter; on “milk chocolate”, at least 30% total dry cocoa solids and 18% dry milk solids, including at least 4.5% milk fat; on “couverture chocolate”, at least 16% dry non-fat cocoa solids (Art. 3(5)). The directive doesn’t list which words count as quality descriptions.

Filled products have their own floors. In filled chocolate the outer chocolate must make up at least 25% of the total weight, and the names don’t apply when the inside is a bakery product, biscuit or ice cream (Annex I(A)(7)). “A chocolate” or “praline” means a single mouthful with chocolate at no less than 25% of the total weight (Annex I(A)(10)). A box mixing these products can be sold as “assorted chocolates” or “assorted filled chocolates” under one ingredient list (Art. 3(2)).

A few names carry recipe conditions. “Gianduja” chocolate needs 20 to 40 g of hazelnuts per 100 g, or 15 to 40 g in the milk version (Annex I(A)(3)(b) and (4)(b)). Swapping “milk” for “cream” in the name means at least 5.5% milk fat (Annex I(A)(4)(c)).

In the ingredient list, Regulation 1169/2011 lets press, expeller or refined cocoa butter appear simply as “cocoa butter”, and every type of sucrose as “sugar” (Annex VII, Part B, points 15 and 11).

Allergens in three markets

The EU lists 14 allergen groups, the US nine, and the 2013 edition of GSO 9 a list close to the EU’s, and all three put the declaration in or right next to the ingredient list. In a chocolate recipe, milk, soy lecithin and nuts such as hazelnuts all fall under these lists.

In the EU, each allergen from Annex II of Regulation 1169/2011 is named in the ingredient list and set apart by font, style or background color (Art. 21). Selling loose doesn’t remove the duty: for food that isn’t prepacked, such as bonbons from the counter, allergen information is still mandatory (Art. 44(1)(a)). Voluntary information, including “may contain” wording, must be neither misleading nor ambiguous (Art. 36(2)).

US law, in section 403(w) of the FD&C Act, gives two ways to declare a major allergen: a “Contains” statement immediately after or next to the ingredient list, in type no smaller than the list, or the allergen’s source in parentheses after the ingredient’s name. Tree nuts are named by type, such as almond or hazelnut. The requirement also covers allergens in flavorings, colors and incidental additives.

Sesame became the ninth major allergen on January 1, 2023, under the FASTER Act. The FDA’s food allergies page says precautionary lines such as “may contain” are “not required by law” and “should not be used as a substitute for adhering to current good manufacturing practices.” Controlling cross-contact in the plant is covered in chocolate food safety.

FDA guidance changed two points in January 2025. Edition 5 of the allergen labeling guidance, announced on January 6, says that “Coconut is no longer one of the tree nuts considered a major food allergen”, and that milk covers milk from cows, goats, sheep and other domesticated ruminants, according to the FDA’s questions and answers on the guidance. A coconut-filled bar can drop coconut from its “Contains” line, and a goat milk chocolate declares milk. The FDA allows a transition period for the coconut change.

The 2013 edition of GSO 9 lists, in clause 5.2.5, gluten cereals, crustaceans, eggs, fish, peanuts and soy, nuts, milk and lactose, sulfites at 10 ppm or more, celery, mustard, sesame, clams and lupin. Its English translation says “walnuts” where the EU says tree nuts; the Gulf reviewer should check the Arabic.

US labels: panels, names and the nutrition box

A US chocolate label is built around two panels and a standard name. The principal display panel is the part most likely to be seen on the shelf, the information panel sits immediately to its right, and the ingredients, business address and Nutrition Facts go on one of the two (21 CFR 101.1 and 101.2). Required text can’t be smaller than one-sixteenth of an inch (101.2(c)).

The statement of identity goes on the principal display panel in bold type (101.3(d)), and for chocolate it’s the name set in 21 CFR Part 163: “sweet chocolate”, “semisweet chocolate”, “bittersweet chocolate”, “milk chocolate” and “white chocolate”, each with a “coating” form. Vegetable fat coatings have their own names; see real vs compound chocolate.

If the cocoa was treated with alkali, the label says “Processed with alkali” or “Processed with ______” (163.123(c)(1), 163.130(c)(1)). Added spices and flavorings get their own line, such as “Flavored with ______”, and these statements go immediately before or after the name with no other text in between (163.123(c)(3) and (5)). Cocoa treated this way is also sold as Dutch-process cocoa.

Ingredients are listed by common name in descending order of weight (101.4(a)(1)), and a standardized ingredient, such as milk chocolate in a bar with inclusions, is followed by its own ingredients in parentheses (101.4(b)(2)(i)). Certified colors are declared by name, without “FD&C” or “No.”, and lakes as such, for example “Blue 1 Lake” (101.22(k)(1)). Permitted colors by market are in how to make bonbons.

The label names the manufacturer, packer or distributor and its place of business; a business that didn’t make the product uses “Manufactured for” or “Distributed by” (101.5). A private label buyer goes on that line; co-packing is covered in scaling up chocolate production.

Net weight goes on the principal display panel in ounces, as in “Net wt. 6 oz”, with pounds in parentheses from 1 pound up (101.7(j)); metric “may also appear” (101.7(p)).

Nutrition Facts reference amounts are 30 g for “All other candies”, 15 g for baking candies such as chips and 10 g for after-dinner confectioneries (101.12(b)). Besides the small retailer exemption in chocolate factory regulations, a low-volume exemption covers a business with fewer than 100 full-time equivalent employees that sold fewer than 100,000 units of the product in the US over the previous 12 months. It needs an FDA notice unless a non-importer has fewer than 10 such employees and sells fewer than 10,000 units a year (101.9(j)(18)).

If any other language appears next to the English, every required word must appear in it too (101.15(c)), so an English and Arabic pack built for the Gulf needs all US information in both languages.

Selling into the Gulf: Arabic, two dates and halal proof

In Saudi Arabia a food label has to be in Arabic, and another language can sit alongside it as long as it says exactly the same thing. The SFDA’s own answer, updated July 18, 2024, rules out English-only labels on that basis.

GSO 9:2022 is the edition in force. It cancelled and replaced GSO 9:2013, and its Arabic text is the authoritative one, according to the GSO project page. Its full text was not read for this article, so the clauses below come from the 2013 edition and are marked that way.

Under the 2013 edition (cl. 7.2.2), Arabic can be added by a single sticker provided by the manufacturer only, which can’t cover mandatory information, contradict the original or come off in normal handling. Dates can never go on a sticker.

The 2013 edition (cl. 5.7.1 and 5.7.2) asks for both a production date and an expiry date: day, month and year for a shelf life under three months, month and year above that. Even when the second date reads “Best before date”, the production date is still mandatory. Both are embossed, printed or written in indelible ink directly on the pack or the original label, by the producer only, and one pack carries one production date and one expiry date at most (cl. 5.7.3). Chocolate isn’t on the list of foods exempt from dating (cl. 5.7.4). Expiry periods themselves are the subject of a separate paid standard, GSO 150-1, “Mandatory expiration dates”.

Beyond the metric quantity, maker and origin in the table, the 2013 edition asks for the animal source of any animal ingredient (cl. 5.2.12) and a factory and batch code on every pack (cl. 8.3). Any quality or organic logo needs proof that it’s valid (cl. 4.3).

Halal paperwork depends on what’s in the recipe. SFDA’s conditions for food clearance define the halal certificate as covering ingredients, additives and components “that include meat derivatives, rennet, gelatine, animal fats, oils, and their derivatives or any product that requires a halal certificate according to technical regulations.” A copy is required at clearance for those products and for any product carrying a “Halal” label or logo, and every logo on the label needs proof that it’s genuine. For chocolate, that points at fillings with gelatin and at emulsifiers or fats of animal origin; whether a given recipe needs a certificate is for SFDA and the importer to confirm.

The chocolate standard SFDA checks, “Cocoa and its products - chocolate”, is currently GSO 567:2021, amended in 2024. Its text is only available for purchase, so its minimums and naming rules aren’t covered here.

There is one exception to the Arabic rule. SFDA accepts English-only labels on ingredients going to licensed factories in Saudi Arabia for production, and on supplies for restaurants that aren’t offered to consumers directly, if a commitment is submitted through the Fasah platform that the label will be in English.

Packaging materials: what to ask your supplier

Most packaging duties sit with the supplier; the chocolate maker collects the documents and checks that they fit chocolate. The EU’s general rule for food contact materials, Article 3 of Regulation 1935/2004, is summarized in chocolate factory regulations.

Under Regulation (EC) No 1935/2004, consolidated March 27, 2021, packaging sold before it touches food carries “for food contact” or the Annex II symbol, the name and address of an EU-established maker or seller, and a traceability label (Art. 15). Plastics, like other materials under specific EU measures, come with a written declaration of compliance (Art. 16), and every business in the chain must show who it bought from and sold to (Art. 17).

For plastics, the declaration of compliance follows Annex IV of Regulation 10/2011, consolidated July 14, 2026 (Art. 15), and states the conditions it was tested for: the types of food, the time and temperature of contact, and the highest surface-to-volume ratio checked (Annex IV, point 8). Chocolate is a fatty food, and a tray filled at depositing temperature needs a declaration that covers that temperature. The overall migration limit is 10 mg of total constituents per dm² of contact surface (Art. 12(1)).

The new EU packaging regulation adds a PFAS limit. From August 12, 2026, under Article 5(5) of Regulation (EU) 2025/40, food-contact packaging can’t be placed on the market if it contains PFAS at or above 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of targeted PFAS, or 50 ppm for all PFAS including polymeric ones. Greaseproof papers, cups and interleaves are the obvious place to ask. Its harmonized sorting label won’t apply before August 12, 2028 (Art. 12(1)).

In the US there is no FDA approval for packaging. According to the FDA’s guidance on food contact materials, each component has to be covered by a listing in Title 21 of the CFR, GRAS status, a prior sanction letter, a Threshold of Regulation exemption or an effective Food Contact Substance Notification, and a notification covers only the notifier’s own substance. Ask the supplier, in writing, which of those five routes covers each component. Molds and BPA are covered in chocolate molds, and professional mold choice in chocolate molding.

For the Gulf, GSO 9 refers to two packaging standards, GSO 839 for food packages and GSO 1863 for plastic packages. Choosing a film for its oxygen and moisture barrier is a separate decision, covered in the packaging part of the chocolate production line and in chocolate shelf life.

A label checklist before you print

Run each wrapper through these checks, one market at a time.

1. Market, and any second language that pulls in another rulebook.
2. Legal name, and thresholds behind any quality word.
3. Allergens in that market’s format.
4. Chocolate lines: cocoa solids, vegetable fats, “Processed with alkali”.
5. Net quantity in the right units.
6. One date (EU) or printed production and expiry dates (Gulf).
7. The right business named.
8. Nutrition declaration or a documented exemption.
9. Every language complete and identical.
10. Packaging declarations, PFAS answers and US clearance routes on file.

Sources and open questions

EU texts: latest consolidated versions on EUR-Lex (dates above); 2025/40 as published in the Official Journal.

US texts: eCFR Parts 101 and 163 (up to date as of October 8, 2026); FD&C Act via Cornell’s Legal Information Institute.

Gulf texts: GSO 9:2022 read in its official preview only. GSO 567:2021 and GSO 150-1 are paid and were not read, nor were GSO 839, GSO 1863 or the halal standard GSO 2055-1.

Open for the reviewers: EU precautionary allergen rules under Article 36(3)(a); whether the cocoa solids statement satisfies the EU quantity declaration; mandatory US metric under the Fair Packaging and Labeling Act; which 10/2011 test conditions apply to chocolate.