A QUID declaration is the percentage of a named or pictured ingredient shown on a finished food. For freeze-dried fruit, Annex VIII of Regulation (EU) No 1169/2011 lets you count the weight recorded before dehydration. That route opens only when the process reconstitutes the fruit during manufacture.

Key takeaways

  • Point 4(c) of Annex VIII lets a dehydrated ingredient count at its weight before drying, when the factory reconstitutes it.
  • The choice of calculation basis moves the on-pack figure by a factor of roughly seven to ten for freeze-dried fruit.
  • Your supplier specification has to carry the input ratio and the residual moisture, because the auditor will ask for the mass balance.
  • A fruit picture on the pack triggers the same duty as a fruit word in the product name.
  • Codex uses ingoing weight at the time of manufacture, so third-country labels may need a second calculation.

When a QUID declaration becomes mandatory on your pack

Article 22 of Regulation (EU) No 1169/2011 sets three triggers. One is an ingredient named in the food. Another is an ingredient emphasised on the label in words, pictures or graphics. A third covers any ingredient essential to characterise the food.

So a QUID declaration follows from your artwork as well as your recipe. A pear photograph on a cereal box counts. Design decisions therefore create labelling duties, and the design team rarely knows that. Put the artwork brief in the same folder as the recipe, because both feed the same number.

The regulation entered into application on 13 December 2014. The European Commission confirms the nutrition duty runs from 13 December 2016. Trade bodies keep pushing the picture rule further. Freshfel asked for a legal floor of 50 g of fruit per 100 g of finished product whenever fruit images appear. Its survey of 188 European products found 7 % with no fruit at all. Another 34 % held only 1 % to 10 % fruit.

The two calculation bases open to you

Point 3 of Annex VIII gives the general rule. You express the percentage of the ingredient at the time of its use. Point 4 then lists derogations. Two of them matter for dried fruit.

The Commission adopted a notice on this subject on 20 November 2017. It appears as 52017XC1121(01) in the Commission guidance list. The notice quotes each derogation and works through examples.

SituationBasis for the percentage
General rule, point 3Weight at the time of use
Moisture lost after treatment, point 4(a)Weight of the ingredient related to the finished product
Dehydrated ingredient reconstituted in the factory, point 4(c)Weight recorded before concentration or dehydration
Dehydrated food reconstituted by the consumer, point 4(d)Proportion by weight in the reconstituted product

Round the declared figure to a precision your records support. A second decimal implies a measurement accuracy that a mass balance rarely delivers. State the rounding convention once, in the labelling procedure, so every product in the range follows it.

Pick one basis and record why you picked it. Auditors accept either route when the file shows the reasoning. Keep that note with the launch pack, because staff change and the logic walks out of the door with them.

Point 4(c) and the pre-drying weight of freeze-dried fruit

The Commission Notice on QUID quotes point 4(c) directly. The quantity of ingredients used in concentrated or dehydrated form and reconstituted during manufacture may be indicated on the basis of their proportion by weight as recorded before their concentration or dehydration.

Two conditions sit inside that sentence, and both must hold. First, the material must arrive in dehydrated form, which freeze-dried fruit clearly does. Second, the factory must reconstitute it during manufacture.

That second condition decides most cases. Freeze-dried pear stirred into a yoghurt base takes up water, so it reconstitutes. The same pear scattered over a chocolate bar stays dry. Point 4(c) then closes and you fall back to point 3. Read how freeze drying removes water from fruit before you decide which case you are in.

Borderline products need a decision on paper. A cereal topping that meets milk in the bowl still leaves the factory dry, so the factory never reconstitutes it. Treat that as point 3 until you can show otherwise.

A worked example for a pear and peach cereal

Assume the drying record shows 8 kg of fresh pear charged for every 1 kg of freeze-dried pear. Your recipe adds 3 kg of freeze-dried pear to 97 kg of other ingredients.

Under point 3, the figure reads 3 %. Under point 4(c), the pre-drying weight becomes 24 kg. The denominator has to move as well, because fresh fruit replaces dried fruit in the recipe total. The total climbs to 121 kg, so the declaration reads 19.8 %.

One recipe, two lawful numbers, and a gap wide enough to change how the product sells. Do not invent anything in that file, though. The 8:1 ratio has to come from a real mass balance for a real batch, and ratios shift with variety and season.

Compare that with the cooked examples in the notice. A butter cookie carries 50 g of butter in 200 g of ingredients. Baking yields 170 g of product, so the label shows butter at 29.4 %. The Irish Food Safety Authority works a chilli con carne the same way. Take 300 g of beef in 1,100 g of ingredients, then 1,000 g after cooking. The figure lands at 30 %.

Spec wording that supports a QUID declaration

Your specification carries the burden of proof. Ask the supplier for four numbers, and put each one on the document. An email thread will not survive an audit., Kilograms of fresh fruit charged per kilogram of dried output, with the batch it came from., Residual moisture of the dried lot, as a percentage with its method., The variety and the harvest year, because input ratios move between seasons., Water activity, since it governs the storage claim you make later.

State the intended use as well. Write that the process reconstitutes the fruit, when it truly does. An auditor who reads that line will look for the water addition step in the process flow. The two documents therefore have to agree.

SALESWAVE confirms the input ratio and the residual moisture for a specific batch, once we agree the documentation scope at specification stage. Our freeze-dried pear datasheet lists the parameters buyers usually request.

Point 4(a) when the mix loses moisture in the oven

Baked products raise a second question. The Commission Notice sets out point 4(a) for foods that lost moisture following heat treatment. You relate the ingredient weight to the finished product.

Sometimes the arithmetic passes 100 %. The notice handles that with a salami. Take 120 g of pork in 130 g of ingredients, giving 100 g of product. The label then states that 120 g of pork meat has been used for the production of 100 g of salami. Use the same sentence pattern for a fruit filling that bakes down hard.

Batch variation deserves a tolerance policy as well. Input ratios move with variety, harvest year and slice thickness. Set the declared figure from a spread of batches, using more than one record, then review it each year. Keep the review date on the specification, so the next technologist knows when the number last moved.

Do not stack the two derogations. Counting fresh weight under point 4(c) and then relating it to a reduced finished weight inflates the number twice. Choose the derogation that matches the physical process, then hold it across the range. Products in the breakfast cereals and granola category often need both approaches across a portfolio. Write the decision rule into your labelling procedure so that each new recipe inherits it.

Where the QUID declaration and the ingredient list must agree

The percentage sits next to the name of the food or beside the ingredient in the list. Whichever position you pick, the ingredient list has to name the same material. A list that says freeze-dried pear while the figure rests on fresh weight needs a bracketed note explaining the basis.

Order matters too. Declare fresh weight for QUID, rank the list by dried weight, and a reader sees a large percentage against a low list position. Trading standards officers open exactly that gap first. Consumers notice as well. A survey of more than 800 people reported by New Food Magazine found 52 % would not buy again after a mislabelled product.

Run the check at artwork proof stage. Read the front of pack, the list and the QUID figure together, in that order, and ask whether they tell one story. Most errors surface in ninety seconds when you read them side by side.

Codex, Great Britain and the export label

Outside the EU the basis shifts. Codex CXS 1-1985 asks for the ingoing percentage of the ingredient at the time of manufacture where the label emphasises it. Codex also states that a reference in the name of a food to a particular ingredient shall not of itself constitute the placing of special emphasis. That wording is narrower than Article 22, so an EU calculation does not transfer automatically.

Great Britain is moving on its own track. Trade coverage notes that UK rules are diverging from EU legislation. The same coverage records that allergen errors drove 23 % of recorded recalls in the first half of 2024. Defra also archived its guidance on terms such as fresh, pure and natural in late 2024. That note grew out of a 2008 consultation with over 1,200 stakeholders.

Distributors in the Gulf and in Ukraine ask for the same evidence in a different order, so send the mass balance with the first sample, ahead of the tender. A QUID declaration prepared late tends to delay a listing by a full season.

Build one calculation file per market, then. Keep the mass balance, the chosen derogation and the artwork brief together. Those three documents answer every question an auditor asks about the number on the front of the pack.

Frequently asked questions

Does a picture of fruit trigger a QUID declaration?

Yes. Article 22 of Regulation (EU) No 1169/2011 covers an ingredient emphasised in words, pictures or graphics. A raspberry photo on a granola pack therefore carries the same duty as the word raspberry in the product name.

Can I count freeze-dried pear at its fresh weight?

Only when the process reconstitutes the pear during manufacture. Point 4(c) of Annex VIII permits the weight recorded before dehydration in that case, and the Commission Notice on QUID quotes the wording.

What happens when the total of all declared ingredients passes 100 percent?

Then you drop the percentage form. The Commission Notice shows a salami example declared as 120 g of pork meat used for the production of 100 g of salami.

Which document proves the input ratio to an auditor?

A mass balance record from the drying batch, referenced in the raw material specification. Ask for the kilograms of fresh fruit charged per kilogram of dried output. Ask for the residual moisture of the finished lot as well.

Do the same rules apply outside the EU?

No. Codex CXS 1-1985 asks for the ingoing percentage at the time of manufacture. Great Britain has also begun to diverge from EU labelling guidance, so export artwork needs a separate check.

Scroll to Top