To write a lawful ingredient list on a South African food label, put everything under the heading “Ingredients” in descending order of mass as present in the end product, break every compound ingredient open in brackets, declare added water and additives the way R146 prescribes, flag each common allergen, and give a percentage for any ingredient your pack emphasises. Regulations 16 to 29 of R146 set the rules, with the additive and allergen rules in regulations 36 to 45.

If you sign off labels for a living, the Advanced Food and Beverage Labelling course (about 16 hours online, R2,950) works through ingredient lists, nutrition tables, claims and category rules on real South African labels. If you would rather we checked yours, our food labelling and regulatory advisory team returns a line by line report against R146.

What does R146 say about the ingredient list?

Regulation 9(d) of the Regulations relating to the Labelling and Advertising of Foodstuffs, R146 of 2010 requires the label of a prepacked foodstuff to carry the list of ingredients required by regulations 16 to 29, where applicable. Regulation 8(d) adds a presentation rule that is often missed: the list of ingredients and any proportions must be in a letter type of uniform size, colour, font and prominence throughout, although the first letter may be a capital.

So the hero ingredient may not be bold, coloured or bigger inside the list. Emphasis belongs on the front of pack, where it brings in the percentage rules below.

Two exemptions apply. Packs with a total exterior area of 2,000 mm² or less need only the name, the manufacturer’s address, a date, common allergens and any irradiation statement (regulation 31). Bulk food sold other than by retail, with trade documents carrying all the label particulars, needs no ingredient list on the pack (regulation 30(2)).

In what order must ingredients be listed?

Regulation 17 requires the ingredients of a blended, compounded or mixed foodstuff, including additives, to be listed in descending order of mass as present in the end product. Work from the batch recipe, then think about what the process removes. Water lost in baking, drying or toasting can move an ingredient down the list.

R146 allows four departures from strict order:

• Seasonal ingredients (regulation 16). Where the climate or season makes a fixed recipe impossible, ingredients other than the main ingredient that might be present may be listed one after the other, not necessarily in order, preceded by “and/or”.
• Mixed fruit, nuts or vegetables (regulation 20). Where none predominates significantly by mass, they may be listed in any order with the words “in variable proportions”.
• Herbs and spices not exceeding 2% by mass, singly or together, may go in any order at the end of the list (regulation 21).
• Vitamins and minerals may also go at the end in any order (regulation 21). For an added mineral, regulation 52(6) requires the compound it comes from to be named in the list.

When must you declare added water?

Regulation 18 says added water must be declared in its proper place in the list, subject to regulation 28. Regulation 28 sets out the exceptions: water used only to wet a dry additive or ingredient, and water that is part of a brine or syrup declared as “brine” or “syrup”, where the added water does not exceed 5% of the finished product. Raw processed meats are excluded from this exception (regulation 28(c)).

Read the conditions together and be conservative: water that is a real part of a sauce, soup or injected meat goes in the list in its order.

How do you list a compound ingredient?

A compound ingredient is any ingredient made of two or more ingredients, such as chocolate chips, mayonnaise, a spice blend or a stock powder. Regulation 27 requires its ingoing ingredients, additives and components to be listed in brackets, in descending order, straight after its name. Milk solids are named in the regulation as a compound ingredient.

So “chocolate chips” on its own is wrong. “Chocolate chips (sugar, cocoa mass, cocoa butter, emulsifier, flavouring)” follows the rule, with milk or soya flagged if the supplier’s specification shows them. Your raw material specifications are the source for every bracket, so ask suppliers for a full breakdown, including carriers and processing aids, and keep it on file. Regulation 5 requires the manufacturer, importer or seller to keep all information behind the label on record, and not producing it within two working days of an inspector’s request is an offence. Review the specification and re-approve the label whenever a supplier, a recipe or a process changes, and keep the signed artwork approval with the specification it was checked against.

Additives carried into your product through an ingredient need not be declared if they do not perform the same technological function in the final food (regulation 41). Preservatives, antioxidants and tartrazine are the exceptions: they must always be declared.

How should ingredients and additives be named?

Use the name the ingredient would carry if it were sold on its own (regulation 22). Cultures are named by purpose, such as “yoghurt culture” or “cheese culture”. A reconstituted concentrate is shown as, for example, “reconstituted orange juice concentrate” (regulation 19). Fats and oils are declared by class, “vegetable”, “animal”, “fish” or “marine”, followed in brackets by each type and, for vegetable oils, the part of the plant, with “hydrogenated” where it applies (regulation 29).

For additives, regulation 36 says all of them must appear, and most may use a category name from Annexure 1, such as “raising agents”, “emulsifier” or “thickener”. The exceptions catch people out:

• Flavourings are declared as “flavouring” only, never “natural”, “artificial” or “nature identical” (regulation 23).
• Preservatives are shown as “preservative” followed by the common chemical name, for example “preservative (potassium sorbate)” (regulation 38). Sulphur dioxide below 10 mg/kg in the food as packed or ready to eat need not be declared, unless it reaches the food from the packaging or the skin of whole, unpeeled fresh fruit or vegetables was treated with it. Then it must be declared at any level (regulation 38(2), as amended by R45 of 2012). Nitrites and nitrates in shelf stable cured meats are declared as “curing agent” instead, followed by their names in brackets.
• Antioxidants are declared by common chemical name or abbreviation (regulation 39).
• Tartrazine must appear by that name (regulation 37), and MSG as “monosodium glutamate” or “MSG” followed by “flavour enhancer” (regulation 40).
• An additive or carrier derived from, or contaminated with, a common allergen names the allergen in brackets after it, for example “emulsifier (soya)” (regulation 42).

Getting these exceptions right on every label is a skill. The Advanced Food and Beverage Labelling course (about 16 hours online, R2,950) drills additive, allergen and QUID declarations on real South African labels. If you need one label checked now, send us the label and specifications for a review in five to seven business days, or 48 hours on the express service.

When do you need a percentage, or QUID?

Regulation 26(1) requires a quantitative ingredient declaration whenever the label places special emphasis on one or more valuable or characterising ingredients, or the description has the same effect. A product called “Honey and macadamia crunch”, a picture of strawberries or the words “made with real butter” all trigger it. Declare the ingoing percentage at the time of manufacture, in brackets, in one of three places: close to the words or pictures that emphasise it, directly after the product name, or after the ingredient in the list.

Raw processed meat products have their own rule in regulation 26(2): the meat and water content as percentages on the main panel, in bold capital letters at least 3 mm high. It applies notwithstanding the Agricultural Products Standards Act.

How must allergens appear in the ingredient list?

R146 defines the common allergens as egg, cow’s milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts and the significant cereals (wheat, rye, barley, oats and their crossbred hybrids such as triticale). Regulation 43 requires each one in the product or its packaging to be shown in brackets after the ingredient if it is not obvious from the name, or in a “Contains:” statement close to the list, or both. For cereals, the species is named in the ingredient with “(gluten)” in brackets, as in “wheat flour (gluten)”.

Goat’s milk is labelled the same way as a common allergen (regulation 44(2)). Precautionary “may contain” statements are a separate decision under regulation 45, backed by a documented risk assessment. Our guides to allergen risk assessment and cross contact and the Codex rules on precautionary allergen labelling cover that step.

A worked South African example: honey and macadamia crunch

Which mistakes do inspectors and retailers find most?

• Compound ingredients with no brackets, or brackets copied from an old supplier specification.
• “Natural flavouring” or “nature identical flavouring” in the list.
• A preservative declared only by E number, or only by category name.
• Emphasised ingredients with no percentage, or a percentage worked out on the cooked weight instead of the ingoing weight.
• “Flour” with no cereal species and no “(gluten)”.
• Added water left out of a sauce or marinated product.

Our list of the 12 most common food label mistakes in South Africa covers the rest of the pack, and importers should read our guide to importing food into South Africa.

Does draft R3337 change the ingredient list rules?

Not yet. The draft labelling regulations, R3337, were published for comment on 21 April 2023 and, as at 29 October 2026, have not been finalised. R146 is the regulation in force, and labels must comply with it today. Plan artwork changes so that a final R3337 can be absorbed in one reprint, but do not label to the draft. Our guide to the draft R3337 labelling regulations tracks what may change.

Questions we are often asked

Do ingredients go in order of the recipe or the finished product?

Regulation 17 says descending order of mass as present in the end product. Start from the recipe, then check whether moisture loss in cooking, baking or drying moves any ingredient below the next one.

Is a percentage needed if the ingredient is only in the picture?

Yes. Regulation 26 applies where the labelling places special emphasis on an ingredient, and a picture can do that as clearly as words.

Do carry over additives have to be declared?

Only if they perform the same technological function in the final food. Preservatives, antioxidants and tartrazine carried over from an ingredient must always be declared (regulation 41).