Labelling of milk and dairy products

The label of a food product has – first and foremost – an informative function: it is the meeting point between regulation, food safety, and consumer communication. In just a few lines, it must tell what the product contains, where the raw material comes from, how it was processed, and how it should be properly stored, all while complying with a complex framework of European and national regulations. In the case of milk and its derivatives, this aspect is even more delicate: these are highly perishable products, often consumed daily, with a strong link to local territories and to the issue of allergies and intolerances. For producers, having correct and well-designed labels means protecting the consumer, their brand, and the entire supply chain.

Applicable regulations in Europe and Italy

The starting point for the labelling of all foods, including milk and dairy products, is Regulation (EU) No. 1169/2011, which governs the information provided to consumers and establishes general principles such as clarity, legibility, and non-misleading content.
For the dairy sector, this framework has been supplemented by a number of specific rules. In Italy, the interministerial decree of 9 December 2016 introduced the obligation to indicate on the label the origin of the raw material for milk and dairy products, in implementation of Regulation 1169/2011. The rule applies to all types of milk, not only cow’s milk but also buffalo, goat, sheep, donkey, and other species, when intended for human consumption and pre-packed.
At the European level, Regulation (EU) No. 2018/775, which came into force in April 2020, governs the indication of the origin of the primary ingredient when it does not match the origin suggested by the overall product presentation.

Mandatory information on milk and dairy product labels

Most of the required information is the same as for all other foods, as per Regulation 1169/2011, but in the case of milk and dairy products there are some specific requirements.
First, the sales name must be indicated. For milk, this allows a distinction between fresh, pasteurized, UHT, microfiltered, whole, semi-skimmed, or skimmed milk, and must include the type of heat treatment the product has undergone.
For cheese, yogurt, butter, and other derivatives, the sales name describes the product category (e.g. aged cheese, fresh cheese, whole or low-fat yogurt), possibly accompanied by the fat content or other specifications provided by sector regulations.
Alongside the sales name, the list of ingredients must be shown in descending order by weight, and allergens must be highlighted, including milk and milk-based products, which are among the 14 categories of substances listed in Annex II of Regulation 1169/2011.
In practice, the word “milk” or any reference to dairy ingredients must be typographically highlighted from the rest of the text—for example, using a different font or bold.
The net quantity must be stated (by volume for liquid milk, by weight for cheese, butter, and others), along with storage instructions, which are crucial for perishable products that require refrigeration or specific handling.
For fresh milk and many dairy products, the use-by date is mandatory, while for certain aged cheeses, it is permitted to show a minimum shelf life instead. Additional required details include the lot number, nutrition declaration, the name or business name of the responsible operator, and for facilities subject to veterinary inspection, the health identification mark.

Milk origin and traceability information

One of the most sensitive aspects for consumers is the origin of the milk. Italian legislation requires that at least two key pieces of information appear on the label: the “Country of milking”, indicating where the milk was actually collected, and the “Country of processing or packaging”, meaning where the milk was bottled or processed into cheese, yogurt, butter, or other derivatives.
If milking and processing occur in the same country, a simplified statement can be used, such as “Origin of the milk: Italy.”
If the stages occur in different countries, the label can indicate specific states or—if the supply chain is more complex—use broader terms such as “EU countries” or “non-EU countries”, following the rules of the national decree and Regulation 2018/775 on the primary ingredient.
For PDO and PGI products, which follow production protocols recognized at European level, the indication of origin is linked to the system of protection for geographical names. In these cases, the label does not only communicate where the milk comes from, but also the product’s inclusion in a controlled and certified supply chain—an element that strengthens the perception of quality and connection to territory

Raw milk, pasteurized milk and cheeses: what changes on the label

Not all dairy products are equal from a hygiene and safety perspective, and this affects the labelling.
Raw milk intended for direct sale or cheese production is governed by Regulation (EC) No. 853/2004, which establishes specific requirements for microbiological quality, as well as for treatment and storage methods.
When a cheese is “made with raw milk”, this must be clearly indicated on the label, as it has implications both in terms of flavour and organoleptic properties, and in terms of food safety.
Pasteurized milk, microfiltered milk, or UHT milk, although all derived from the same raw material, require different label terms based on the heat treatment, which affects the shelf life and storage conditions.

Allergens and “lactose-free” claims

Milk and dairy products are among the main allergens listed in Annex II of Regulation 1169/2011. This means their presence—even when used as an ingredient in compound products—must always be clearly declared and highlighted in the ingredients list.
Products like butter, cream, yogurt, and most cheeses, although derived from milk, cannot be treated as “neutral” ingredients: they are also subject to allergen labelling requirements, because they fall within the category of “milk and milk-based products” defined by the regulation.
A separate issue involves “lactose-free” or “low-lactose” claims.
Such products are increasingly common on store shelves, but for this type of claim to be legal, it must meet specific thresholds and technical criteria defined at national and EU level, and must ensure consistency between label wording, technical documentation, and lab testing. Guidelines and interpretative documents emphasize the importance of not misleading consumers with ambiguous or deceptive wording.

Sanctions and responsibilities for companies

A non-compliant label may result in significant fines.
Legislative Decree No. 231 of 15 December 2017 sets out penalties for labelling violations, including fines that, in the most serious cases, can reach tens of thousands of euros—for example, in the case of missing mandatory information, incorrect expiry dates, or misleading statements about origin and product characteristics.
For a dairy company, this means that label accuracy must be part of a wider quality and food safety system: graphic design must be supported by strong legal oversight, verification procedures, and an organized archive of technical documentation that demonstrates compliance for each batch.

A good label is, above all, a tool of trust.
For milk and dairy producers, complying with the rules is not just a bureaucratic task—it’s a way to showcase their work, protect their brand, and access new markets in Italy and abroad.
For consumers, reading a clear and complete label means being able to assess milk origin, compare different products, make informed choices in case of allergies or intolerances, and more easily recognize products tied to territory and tradition.