Rise and shine: The European breakfast directive’s new year transformation

Directive (EU) 2024 / 1438, better known as the Breakfast Directive, is required to be transposed into Irish law by 14 December 2025. Businesses can avail of a transitional period up to 14 June 2026 before they will be required to comply with the new requirements under Irish law.

The Breakfast Directive seeks to amend four of the seven other EU “breakfast directives”. Its primary intention is to enhance food labelling and manufacturing standards for products such as honeys, juices, jams and milk, in order to avoid consumers being misled as to the quality of the products they purchase and / or consume.

For food and beverage manufacturers in Ireland, it is essential to understand the new EU labelling and composition requirements for products such as honey, juice, milk, and jam, prior to the enforcement in June 2026.

1. Un-bee-lievable changes

To assist consumers in making informed choices, the Breakfast Directive seeks to amend labelling requirements in respect of honey products.

Countries of origin must now be shown on the label of these products. If the honey consists of a mixture of honeys from different countries, all countries must be set out in the label, in decreasing order based on their weight and the percentage of each origin.

However, there is flexibility as to whether individual Member States allow honey products to indicate the percentage only of the four largest shares of origin, where those four parts of the blend represent more than 50% of the overall product.  On packages of less than 30g, the names of the countries of origin can be replaced by two-letter ISO codes.  It is intended that there would be an exemption for single portions of honey, such as those in breakfast packs.  

The Breakfast Directive also authorises the European Commission to establish methods of analysis to verify whether honey is compliant with the Breakfast Directive, as well as to detect adulterated honey.

2. Fresh squeeze on juice standards

To demonstrate a clear distinction between 'fruit juices' – which have not been permitted to contain added sugars since 2012 – compared to 'fruit nectars', the Breakfast Directive seeks to empower manufacturers to label their fruit juices with the statement: "fruit juices contain only naturally occurring sugars". 

This inclusion aims to provide truthful and accurate information to consumers, and to avoid consumer confusion by making it easier for them to distinguish between fruit juices and fruit nectars. Notably, research has shown that when it comes to making a choice between similar products, those with a nutrition claim, are preferred by consumers.  

Under the Breakfast Directive, in order for a fruit juice to bear the label “reduced-sugar fruit juice” or “reduced-sugar fruit juice from concentrate”, it should have a reduced naturally occurring sugar content of at least 30% compared to the average type of fruit juice it comes from. Similarly, in order to use the label “concentrated reduced-sugar fruit juice”, it should have a reduced sugar content of at least 30% compared to the average type of fruit juice it comes from, but where the product is intended for direct consumption, the removal shall be at least 50% of the water content. 

The Breakfast Directive also seeks to impose an obligation on manufacturers to label the following products as either “from concentrate” or “partially from concentrate”, in clearly visible characters close to the product’s name:

• Mixtures of fruit juices from concentrate
• Reduced-sugar fruit juice from concentrate with fruit juice or with reduced-sugar fruit juice
• Fruit nectar obtained entirely or partly from one or more concentrated products 

3. Jam-packed changes

The Breakfast Directive calls for an increase in the minimum fruit content requirement for jams and marmalades generally from 350g/kg to 450g/kg. 

For 'extra jams' (which differ from regular jams as they include the unconcentrated pulp of one or more kinds of fruit), the minimum fruit content requirement has increased from 450g/kg to 500g/kg. The term 'marmalade' which was previously only allowed for citrus jams, is now allowed for all jams (with citrus jams now having to be referred to as 'citrus marmalade'). If the product is to be called 'citrus marmalade' there must be a minimum citrus fruit content of 200g/kg. This change in terminology is an attempt to better align legal definitions with those terms commonly used by consumers.  

4. The dairy detox

In an attempt to respond to evolving consumer needs, the Breakfast Directive also seeks to allow modifications in the composition of milk (such as a reduction of the lactose content by conversion to glucose and galactose), provided these modifications are indicated on the packaging of the products and can be easily seen and read by consumers. 

Furthermore, manufacturers were previously only authorised to add vitamins, minerals, and raw materials for protein adjustment, to milk products. The Breakfast Directive seeks to expand this scope, by now allowing manufacturers to add authorised food enzymes and food additives to milk products, provided these additions are in accordance with Regulation (EC) No. 1333 / 2008 (the Food Additives Regulation). 

Lastly, the legal definition for 'evaporated milk' has also been revised so that it can be used interchangeably with the term 'condensed milk'. This change is an attempt to align with international standards for evaporated milks.

Scrambling into action

Member States must now adopt and publish laws and regulations in order to implement the Breakfast Directive into local law by 14 December 2025. The laws implemented in Ireland are then to be enforceable from 14 June 2026 onward. However, in order to take into account the economic interests of manufacturers, products which have been placed on the market or labelled before the Breakfast Directive becomes enforceable, may continue to be marketed until that stock runs out. 

It will be interesting to see how these changes, once implemented, will affect consumer perception of certain products and their purchasing behaviour. In any event, manufacturers should start adapting their production processes and their labelling and packaging to ensure compliance with the new requirements.