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US vs EU nutrition declaration: Nutrition Facts compared with Regulation (EU) No 1169/2011

Short answer

A US Nutrition Facts panel (21 CFR 101.9) declares nutrients per serving, with calories and a percent Daily Value, and lists sodium in milligrams. An EU nutrition declaration under Regulation (EU) No 1169/2011 declares energy in both kJ and kcal plus fat, saturates, carbohydrate, sugars, protein and salt, expressed per 100 g or per 100 ml (Articles 30 and 32), and salt is calculated from sodium as sodium x 2.5. One panel cannot be relabelled as the other: the reference amount, the energy unit and the nutrient list all differ.

The main differences

  • Reference amount: the US panel is per serving, based on the reference amounts customarily consumed in 21 CFR 101.12. The EU declaration is per 100 g or 100 ml (Article 32); a per portion value may be added, not substituted (Article 33).
  • Energy: the US panel declares calories. The EU declares energy in kJ and kcal, calculated with the conversion factors in Annex XIV of Regulation (EU) No 1169/2011.
  • Sodium and salt: the US panel declares sodium. The EU declares salt, the salt equivalent of the sodium content (sodium x 2.5).
  • Mandatory nutrients: the EU mandatory set is energy, fat, saturates, carbohydrate, sugars, protein and salt (Article 30(1)). The US mandatory set in 21 CFR 101.9(c) also includes items such as cholesterol, dietary fiber, added sugars, vitamin D, calcium, iron and potassium.
  • Daily values: the US panel shows percent Daily Value. The EU allows a percentage of the reference intakes in Annex XIII Part B (energy 8 400 kJ / 2 000 kcal), with a statement about the reference intake of an average adult.

What the checks do

The EU nutrition declaration check calculates energy from macronutrients with the Annex XIV factors and formats the mandatory fields per 100 g. The US nutrient lookup check reads USDA FoodData Central, including the per serving label values a manufacturer submitted for a branded product. Neither check certifies a label; they give you the values and the rule they came from, so a regulatory specialist can sign off faster.

Sources

Frequently Asked Questions

Can I use a US Nutrition Facts panel on a product sold in the EU?
No. Regulation (EU) No 1169/2011 requires its own nutrition declaration: energy in kJ and kcal and the mandatory nutrients per 100 g or 100 ml, with salt instead of sodium. The US panel is per serving and declares calories and sodium, so it has to be redone, not translated.
How do I convert sodium to salt for an EU label?
Multiply sodium by 2.5. Regulation (EU) No 1169/2011 defines salt as the salt equivalent content calculated as sodium x 2.5, so 0.4 g sodium per 100 g is declared as 1.0 g salt.
Does the EU require percent Daily Value like the US?
No. The EU allows, but does not require, values expressed as a percentage of the reference intakes in Annex XIII Part B. If you use them, the label must carry the statement about the reference intake of an average adult (8 400 kJ / 2 000 kcal).
Which energy conversion factors does the EU use?
Annex XIV of Regulation (EU) No 1169/2011: for example 17 kJ (4 kcal) per gram of carbohydrate or protein and 37 kJ (9 kcal) per gram of fat. The EU nutrition declaration check applies these factors and shows its working.

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