The 12 Most Common Food Label Mistakes in South Africa (and How to Fix Them)

By Mthokozisi Nkosi, Food Safety & Regulatory Consultant, ASC Food Safety

Walk down any supermarket aisle in South Africa and you will find labels that would not survive a proper regulatory review. Some mistakes are cosmetic; others expose the brand to product recalls, Port Health detentions, retailer delistings, or complaints escalated through the National Consumer Commission. And in the worst cases, such as an undeclared allergen, the consequence is a genuine risk to a consumer’s life.

Our consultants review hundreds of labels a year for food businesses of every size, from start-ups to JSE-listed manufacturers. The same food label mistakes appear again and again. Here are the twelve we see most often under R146 of 2010, the current Regulations Relating to the Labelling and Advertising of Foodstuffs, and how to fix each one before it costs you.

1. Missing or incomplete allergen declarations

The most dangerous mistake on the list. R146 requires declaration of the common allergens: egg, cow’s milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts, and gluten-containing cereals (wheat, rye, barley, oats, spelt and kamut), including when they arrive hidden inside compound ingredients like seasoning blends, sauces or bakery premixes. We regularly find labels that declare “milk” but miss the whey powder in the flavouring, or declare “wheat” but not the barley-derived ingredient two lines down.

The fix: Build an allergen map from your full ingredient specifications (every raw material, every supplier declaration) and reconcile it against the label before every artwork change. Undeclared allergens are the leading cause of food recalls worldwide; this is the one item on this list you audit twice.

2. Illegal health claims

“Boosts immunity.” “Supports heart health.” “Helps fight colds.” Claims that a food treats, prevents or cures a disease or medical condition are prohibited on South African food labels, and claims in this territory can also push a product toward SAHPRA’s jurisdiction as a health product, an entirely different regulatory world.

The fix: Audit every claim on pack, on the website and on social media against R146’s rules. If a claim implies a therapeutic effect, remove it. If a nutrition claim is permitted, make sure the product actually qualifies and that you hold the substantiation. (We cover claims in depth in our companion post on health and nutrition claims.)

3. Wrong date marking format

R146 prescribes how date marking must appear. The wording and the format matter, not just the presence of a date. We see American-style month-first dates, ambiguous numeric strings, and invented phrases that don’t match the prescribed terminology.

The fix: Use the prescribed wording and an unambiguous format consistently across your range, and make sure the date is where the label says it is (“see base of can” must be true). Standardise this in your artwork template so no designer can improvise.

4. Missing country of origin

Country of origin is mandatory, and it trips up two groups: importers who leave only the origin-market text, and local manufacturers using imported ingredients who are unsure what to declare. Vague phrasing that obscures origin is a compliance risk and, increasingly, a consumer-trust issue.

The fix: Declare origin clearly and accurately using compliant wording. If your sourcing changes seasonally, build a controlled process for updating the declaration rather than printing the most convenient version.

5. Net quantity errors

Net contents fall under the Legal Metrology Act, administered by the NRCS, separate legislation with its own rules on units, placement and minimum print height relative to pack size. Common failures: imperial-only units on imports, print too small for the pack face, quantity tucked where it isn’t permitted, or drained weight missing where required.

The fix: Declare in metric units at the prescribed size and position. Check the print-height requirement against your actual pack dimensions every time the pack size changes. A compliant declaration on the 400g pack may be non-compliant on the 1kg.

6. Unapproved “sugar-free” and “low fat” claims

Nutrient content claims like “sugar-free”, “low fat”, “high in fibre” or “reduced sodium” are only permitted when the product meets the defined criteria, and the burden of proof sits with you. Marketing teams love these claims; laboratories decide whether you may use them.

The fix: Test before you claim. Obtain laboratory analysis from an accredited lab confirming the product meets the threshold for the specific claim, keep the certificate on file, and re-verify after any reformulation. If the numbers don’t support the claim, change the claim, not the interpretation.

7. Missing manufacturer or importer details

Every label must carry the name and physical address of the manufacturer, packer, importer or seller. We still see labels with only a brand name and a website, or imported products carrying only the overseas factory’s address with no South African party identified.

The fix: Include a full physical street address of the responsible party in South Africa. For imports, the local importer or distributor must be identifiable on the label. A web address or P.O. Box alone does not do the job.

8. Font size and legibility failures

Compliance isn’t only about what the label says. It’s about whether a consumer can actually read it. Minimum letter heights, adequate contrast and legible print apply to mandatory information. Metallic ink on foil, 4-point ingredient lists, and text curved around a bottle shoulder are recurring offenders.

The fix: Give your designers the legibility requirements as a design constraint up front, and proof mandatory text at actual print size, not zoomed in on screen. If you can’t read the allergen statement at arm’s length under shop lighting, neither can the inspector or the consumer.

9. GMO declaration gaps

South Africa requires labelling related to genetically modified content in defined circumstances, relevant for the many products containing maize and soy derivatives, two of the most commonly modified crops. Many manufacturers simply haven’t assessed whether their ingredients trigger a declaration.

The fix: Obtain GM status declarations from your ingredient suppliers, assess your obligations against the applicable thresholds, and declare where required. Keep the supplier declarations on file as your evidence trail.

10. Translated import labels that were never localised

A special category of mistake: the imported product whose label was translated into English but never adapted to South African law. Translation preserves the original market’s allergen conventions, date formats, units and claims, which means it preserves the original market’s non-compliance with R146. Port Health detains these consignments routinely.

The fix: Localise, don’t translate. Every imported label needs a line-by-line review against R146, Legal Metrology and any category-specific standards, with a compliant over-label or reprint before the product reaches the market. Our team does this daily for international brands entering South Africa: see our Labelling & Regulatory Advisory service.

11. Misuse of “natural” and “pure”

Words like “natural”, “pure”, “fresh” and “traditional” are regulated descriptors, not free marketing vocabulary. A “pure” product with added ingredients, or a “natural” product built on processed and synthesised components, is misleading labelling, and misleading labelling is enforceable.

The fix: Before using any evocative descriptor, check it against the rules and against your actual formulation. If the product doesn’t strictly qualify, find honest language that sells. There is always compliant copy that works.

12. No batch identification

Batch or lot identification is mandatory, and it is also the backbone of your recall system. Without it, a single consumer complaint can force you to withdraw everything on the market instead of one production run. We see small producers omit it entirely, and larger ones print codes that their own traceability records can’t decode.

The fix: Print a durable, legible batch code on every unit and ensure it links cleanly to your production and traceability records. Test it: pick a unit off the shelf and see how fast your team can trace it back to raw materials. That speed is what a recall will demand.

Fix them now, before the rules get stricter

One more reason to act: draft R3337, published for comment in late 2023, is expected to replace R146. While it is still a draft and not yet in force, it signals the direction of travel: mandatory front-of-pack warning labels for products high in sugar, sodium or saturated fat, restrictions on marketing to children, and stricter allergen and claims rules. Labels that scrape past R146 today will not survive the transition. Cleaning up your compliance now, while artwork cycles are calm, is far cheaper than doing it under a deadline.

If you want your team to catch these mistakes themselves, our accredited training platform offers self-paced labelling courses, including Essentials of Food Labelling Claims for Food Manufacturing. Browse them at ascfoodsafetytraining.com.

Frequently asked questions

What law governs food labels in South Africa?

R146 of 2010, the Regulations Relating to the Labelling and Advertising of Foodstuffs, made under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972. Net quantity marking is governed separately under the Legal Metrology Act, and agricultural products carry additional requirements under the Agricultural Product Standards Act.

What is the most serious food label mistake?

An undeclared allergen. It creates a direct health risk for allergic consumers and is the most common trigger for product recalls. Allergen declarations should be verified against full ingredient specifications, including compound ingredients, at every artwork revision.

Can I write “sugar-free” or “low fat” on my product?

Only if the product meets the defined criteria for that specific claim, verified by laboratory analysis. Using a nutrient content claim without substantiation is non-compliant and can be challenged by regulators, retailers and competitors.

Do imported products need new labels for South Africa?

Almost always. An overseas label, even one translated into English, must be localised to R146: South African allergen declarations, prescribed date marking, metric net quantity, local importer details and compliant claims. A compliant over-label is often the practical solution.

Is R3337 already law?

No. R3337 is a draft, published for comment in late 2023, and is expected to replace R146 once finalised. R146 remains the law today, but manufacturers should factor the draft’s proposals, such as front-of-pack warning labels, into long-term packaging plans.

By Mthokozisi Nkosi, Food Safety & Regulatory Consultant, ASC Food Safety. Our labelling team reviews artwork for leading pharmaceutical and FMCG brands nationwide from Gqeberha, Johannesburg, Cape Town and Durban.