Pictorial Representation guidance

This resource provides food businesses with advice on what to consider when declaring a pictorial representation of a food ingredient on the label of a pre-packed product.

The guidance addresses the different components of a product that can deliver flavour, be it flavourings or ingredients, and how, being used in combination or individually, companies can substantiate the use of a pictorial of a certain food ingredient. Three comprehensive worked examples of how the principles apply to different foodstuffs are also included in the guidance.

Report contents:


For the purposes of this guidance document:

Depiction = pictorial representation.

Ingredient = any substance or product and any constituent of a compound ingredient, used in the manufacture or preparation of a food and still present in the finished product even if in an altered form. For the purpose of this guidance flavourings, food additives and enzymes are not considered ingredients.

Flavourings = products which are not intended to be consumed as such, which are added to food in order to impart or modify odour and/or taste. The categories of flavourings are set out in section 3. This does not preclude the use of the term flavourings in the ingredients list to cover all categories of flavourings.

Wholly or mainly can be interpreted in different ways but as a guide at least 51% weight/weight of the flavouring components of the flavouring should come from the depicted source. When determining the % from the named food (FTNF) only the flavouring components are considered not the carrier or additives used to formulate the flavouring.


The Department for Environment, Food and Rural Affairs commends the Food and Drink Federation and its supporting partner the UK Flavour Association for their work to provide industry guidance about pictorial representations on food labels. It is important that the approach is consistent to maintain current industry practices where these are in accordance with the law. This approach enables consumers to be fully informed and to prevent them being misled about the composition of the food they buy.
Sarah Church, Director, Food and Farming Department for Environment, Food and Rural Affairs.

Next page: Background

Last reviewed: 19 Apr 2018