An own-brand dried fruit line usually launches online before it launches anywhere else, which means the product page, not the pack, is where the product first meets a regulator's expectations. That inversion catches people out. A seller who has carefully approved artwork will often treat the listing as marketing copy, when in EU law it is carrying most of the same load as the label.
The rule that governs the page
Article 14 of Regulation (EU) No 1169/2011 deals with prepacked food offered for sale by distance communication. For those sales, mandatory food information must be available before the purchase is concluded. There is exactly one carve-out: the date of minimum durability or use-by date may be provided at the moment of delivery instead.
Read that the other way around and the practical instruction is clear. Everything else — the name of the food, the full ingredient list with allergens emphasised, net quantity, storage conditions and conditions of use, the food business operator's name and address, origin where it is required, and the nutrition declaration — belongs on the page, visible before someone clicks buy. The page is not a summary of the label. It is a second place the label has to exist.
Why a pack photograph does not discharge it
The common shortcut is to upload a high-resolution image of the pack and consider the information supplied. It is a weak position for reasons that have nothing to do with intent. Marketplace platforms resize, crop and recompress images, they swap the primary image for a lifestyle shot during a promotion, and they display at whatever size the template allows on a phone. Text that cannot be read at the size a consumer actually sees has not been made available in any useful sense.
There is a maintenance argument too. When a recipe changes or a supplier switches, a listing built on structured fields can be updated field by field; a listing built on a photograph needs new photography, which is slower and tends not to happen. Putting the particulars in the page's own fields is both safer and cheaper to keep true.
Where responsibility sits
The obligation belongs to the food business operator under whose name or business name the food is marketed. On an own-brand programme, that is the brand owner, not the packer. A supplier can and should provide ingredient composition, allergen data, nutrition values and a certificate of analysis, and can flag requirements they know about in a destination market — but the legal responsibility for what the listing says rests with the party whose name is on the front of the pack.
This is worth putting in writing rather than assuming, because the assumption runs in both directions and only becomes visible when something is wrong. A single sentence in the supply agreement setting out who supplies what data and who approves the final listing costs nothing and settles it.
The two fields that cause the most trouble
Nutrition declaration is the first. Values have to rest on a defensible basis — analysis of the actual product, or a calculation from established composition data for the ingredients used. A generic table for the fruit type is not that, and fruit is variable enough that the gap can be real. For a product that is a single ingredient dried down, the concentration effect on sugars is exactly where a careless number goes wrong.
Allergen wording is the second, and for dried fruit it has a specific edge: sulphur dioxide and sulphites are declarable above 10 mg/kg. Whether a product crosses that threshold is decided by the processing choice, not by the listing. It is another reason the sulphured-or-not question belongs in the specification at the brief stage, where it is a conversation, rather than at artwork stage, where it is a reprint.
The efficient approach is to treat the data set as a deliverable in its own right, requested at the same time as samples. Specification, ingredient declaration, allergen statement, nutrition values, shelf life and storage conditions, pack dimensions and weights, and a certificate of analysis. Assembled once, it feeds the label, the listing, the retailer's own form and the customs paperwork without being rebuilt each time.
TeraVella supplies that set as part of a private-label project. Our fruit crisps are dried at low temperature at our geothermal facility in Sındırgı and contain fruit only — no added sugar, preservatives or colourants — which has the practical effect of keeping the ingredient panel to one line and removing the sulphite question entirely. Shelf life runs to roughly twelve months in retail packs. Production is under ISO 9001 and ISO 22000 with batch-level traceability, and we claim no certification beyond those. Pack formats, volumes and prices are confirmed at quotation rather than published, because the honest figure depends on format, volume and destination.
