A practical 2025 decision guide for Indonesian exporters on when you can legally skip nutrition panels on fresh vegetables in the EU, US, and UK. Clear yes/no rules, examples, and a 7-step checklist from the Indonesia‑Vegetables team.
Hook
Last year we cut relabeling costs by $10,247 in one quarter for a customer simply by applying the right exemptions. Same cucumbers. Same carrots. Different packs and claims. The difference was knowing exactly when a nutrition panel is legally required versus when you can skip it. If you export Indonesian vegetables to the EU, US, or UK in 2025, this is the playbook we actually use.
The 3 pillars of smart label decisions
- Know your product state. Whole and raw, peeled or cut, mixed, or frozen. That alone predicts 80% of outcomes.
- Know the market rule-set. The US treats fresh-cut differently from the EU/UK. Claims flip exemptions off in all three.
- Keep proof. A short evidence file avoids delays with customs and retailers and lets you scale packaging confidently.
Week 1–2: Market research and validation (your yes/no map)
Start with the questions we ask on every new SKU.
Do fresh whole vegetables require a Nutrition Facts label in the United States?
Generally no. Whole, unpeeled vegetables in their raw state are “raw agricultural commodities” (RACs) and are exempt from mandatory Nutrition Facts under 21 CFR 101.9(j)(10). A bag of whole Carrots or Japanese Cucumber (Kyuri) heading to US retail usually doesn’t need a Nutrition Facts panel. Retailers may display voluntary posters for raw produce, but it’s not required on pack.
Is the EU nutrition declaration mandatory for unprocessed single‑ingredient vegetables?
No. The EU’s Regulation (EU) 1169/2011 exempts unprocessed products that are a single ingredient or a single category of ingredients. Fresh vegetables fall under this. The exemption survives basic physical prep like washing, trimming, peeling or cutting. So a pack of peeled beets or cut romaine still qualifies as “unprocessed” in EU terms and can omit the nutrition declaration if it’s just the vegetable.
In the UK, can I sell bagged whole cucumbers without nutrition information on the pack?
Yes. The UK retained the EU FIC rules post‑Brexit. In Great Britain, unprocessed single‑ingredient vegetables are exempt from nutrition info on pack. Northern Ireland follows EU FIC as well, so same outcome.
Practical takeaway for Week 1–2: Map each SKU by state and market. Write a one‑line conclusion per SKU. Example: “US, bagged whole cucumbers, no claims. RAC exemption applies. No Nutrition Facts.”
Week 3–6: MVP creation and testing (pack copy and edge cases)
Now pressure test the tricky scenarios.
Does peeling or cutting vegetables change the nutrition labelling requirement in the US versus the EU/UK?
- US. Yes, it can. Once you peel or cut, you’re usually no longer a RAC. Fresh‑cut carrots, peeled baby carrots, shredded cabbage, or chopped romaine typically need a Nutrition Facts panel unless another exemption applies (for example, a qualifying small business exemption). That’s why so many US bagged salads carry panels even when there’s no dressing.
- EU/UK. No, not by itself. Peeling, cutting, trimming or washing doesn’t remove the exemption for unprocessed single‑ingredient products. Nutrition info stays optional unless you add ingredients or make a claim.
Real example from our line. Whole Baby Romaine (Baby Romaine Lettuce) in a simple bag. EU/UK: can omit nutrition declaration. US: whole heads usually exempt. But if we offer a pre‑cut hearts pack for US retail, we plan a Nutrition Facts panel.
If I add a vitamin or fiber claim on fresh vegetables, do I need a nutrition panel?
Yes in all three markets. A nutrition or health claim immediately triggers full nutrition labeling.
- EU/UK. A claim like “source of vitamin A” or “high in fiber” activates Article 30(3) of FIC. You must provide the full nutrition declaration and meet the claim’s conditions. Same under the GB version.
- US. Nutrient content claims under 21 CFR 101.13 require Nutrition Facts and strict criteria. “Low sodium,” “good source of potassium,” etc. If you make a claim on bagged whole onions, plan the panel.
Pro tip. Avoid casual claims on packs where you want to keep the exemption. We’ve seen teams accidentally trigger labeling by adding “rich in antioxidants” to beautiful red lettuce. Save it for marketing materials off pack.
Are outer shipping cartons for fresh vegetables required to show nutrition information?
No, if they’re not intended for retail sale. Master cartons for wholesale distribution don’t require nutrition information in the EU, UK, or US. Focus on the consumer pack.
Are mixed vegetable packs without dressing exempt?
- EU/UK. Grey area. The exemption covers “single ingredient or single category of ingredients.” Some authorities accept a “single category” interpretation for mixed vegetables. Others expect a nutrition declaration when multiple different vegetables are combined. Retailers also have their own house views. Our rule of thumb. If it’s a simple mix of raw vegetables only, many EU/UK buyers accept omission. But align early with the retailer’s technical team and cite Annex V of FIC. When in doubt, include the panel.
- US. A mixed fresh‑cut pack is not a RAC. Plan a Nutrition Facts panel.
Reality check. Frozen or IQF products are processed by definition. Our Frozen Mixed Vegetables and Premium Frozen Sweet Corn always carry nutrition panels in all three markets.
Week 7–12: Scale and optimize (lock the system)
Here’s the simple framework we install with partners so teams stop reinventing the wheel.
The 2025 checklist to decide if fresh vegetables need nutrition labeling
- Market. EU, UK, or US?
- State. Whole raw. Peeled or cut. Mixed. Frozen. Any added ingredients?
- Claims. Any nutrition or health claims on pack? If yes, panel is mandatory in all markets.
- US only. If peeled/cut or mixed, it’s likely not a RAC. Plan the panel unless you qualify for the small business exemption in 21 CFR 101.9(j)(18).
- EU/UK only. If unprocessed and single ingredient/category, exemption applies even if peeled/cut. If multi‑veg, align with buyer’s interpretation or include panel to be safe.
- Pack size and add‑ons. Tiny packs with largest surface <25 cm² can use abbreviated rules in EU/UK, but that rarely applies to produce bags.
- Documentation. Save a one‑page rationale and citations.
Once validated, templatize. We keep three master artworks per market: exempt‑pack template, claim‑pack template, and frozen/processed template. That alone has cut our relabeling by 30–40% across seasons.
The 5 biggest mistakes we keep seeing (and how to avoid them)
- Using US RAC logic in the EU/UK. Teams add Nutrition Facts to peeled carrots in the EU out of habit. You can legally skip it if it’s just carrots and no claims. Save the ink.
- Making claims without the back‑of‑pack ready. A tiny “high vitamin A” bubble on Loloroso (Red Lettuce) turns an exempt pack into a non‑exempt one.
- Assuming mixed raw veg is always exempt in the EU/UK. Many buyers accept it. Some don’t. Align early or include the panel.
- Forgetting that frozen = processed. Every frozen line, from Premium Frozen Okra to Frozen Paprika (Bell Peppers) - Red, Yellow, Green & Mixed, needs a panel.
- No evidence file. Customs or retail QA asks “why no panel?” and the team scrambles. Keep a single PDF per SKU with your reasoning.
Quick answers to the most asked questions
- Do fresh whole vegetables require a Nutrition Facts label in the United States? Usually no. RAC exemption applies to whole, unpeeled produce with no claims.
- Is the EU nutrition declaration mandatory for unprocessed single‑ingredient vegetables? No. Exempt under FIC Annex V.
- In the UK, can I sell bagged whole cucumbers without nutrition information? Yes. Same exemption as EU.
- Does peeling or cutting change the requirement in the US versus EU/UK? US. Often yes, panel required. EU/UK. No, still exempt if single ingredient and unprocessed by FIC definitions.
- If I add a vitamin or fiber claim, do I need a panel? Yes, in all three markets.
- Do outer shipping cartons need nutrition info? No, not for non‑retail outer packs.
- What evidence should I keep to justify skipping the label? See below.
What evidence to keep on file (the “customs‑ready” packet)
We keep this to one page per SKU and it’s saved us days during audits.
- Product description and state. Whole raw, peeled, cut, mixed, or frozen.
- Artwork snippet. Front and back showing no nutrition or health claims if you’re using the exemption.
- Legal basis. One‑line citation. Examples: EU/UK. FIC 1169/2011 Annex V, point 1. US. 21 CFR 101.9(j)(10) for RACs, 21 CFR 101.13 for claims.
- Decision summary. “Exempt in EU/UK. Non‑exempt in US due to fresh‑cut. Panel included for US.”
- Spec sheet and CoA. Confirms single ingredient and no added components.
Need a second set of eyes on a tricky SKU mix or a retailer technical query? Send us the pack mockup and target markets and we’ll sanity‑check the exemption path. If it helps to move fast, you can Contact us on whatsapp.
Resources and next steps
- Build your SKU map for the next season. Start with your fresh export lines like Tomatoes, Onion, and Japanese Cucumber (Kyuri). Flag any that will be peeled, cut, or mixed for US orders.
- Separate your frozen portfolio. All frozen products, including Premium Frozen Edamame and Premium Frozen Potatoes, will need nutrition panels everywhere.
- 2025 outlook. As of late 2024, no confirmed EU, UK, or US changes remove the exemptions covered here. Retailers continue tightening technical checks, so your evidence file matters more than ever.
If you’re planning a multi‑market program and want a fast cross‑check by our regulatory and packaging team, share your draft artworks and we’ll flag where you can legally simplify. Or just browse our current range to see how we apply this in practice: View our products.
We’ve learned this the hard way, season after season. Use the exemptions when they’re available, avoid the claims that flip them off, and keep a short paper trail. That’s how we keep compliance tight and packaging efficient across the EU, US, and UK in 2025.