The revised Breakfast Directive[1] overhauls the composition, manufacturing, traceability and labelling rules for four categories:
- Honey
- Fruit juices
- Fruit jams including jellies, marmalades and sweetened chestnut purée, and
- Dehydrated milk
The legislation echoes the EU’s key objectives under the Green Deal and its Farm to Fork Strategy, introducing strict transparency and health-focused formulation rules to protect consumers and combat food fraud. Utilising tightened criteria for fruit content, sugar addition and geographic food origins, the Directive applies to all relevant products sold on the EU market.
The Revised Breakfast Directive was transposed into Irish law in December 2025 via S.I. 591, S.I. No. 620, S.I. No. 621, and S.I. No. 622[2].
Key updates introduced by the new directive
- Mandatory country-of-origin labelling for honey: Honey blends that contain honey from multiple countries, whether from EU or non‑EU sources, must list each country of origin on the label in descending order of their share in the blend by weight. A 5% tolerance is permitted for each individual share, based on the operator’s traceability records. To allow some flexibility, producers may list only the four largest contributing countries, provided that together they account for more than 50% of the total blend. For single‑portion packs of 30 g or less, the full country names may be replaced with the two‑letter ISO country codes.
- Increased fruit requirements for jams: To support the fruit market and promote jams and jellies with higher fruit content and reduced free sugars, the minimum fruit quantities in Annex I to Directive 2001/113/EC are increased. Standard jams shall contain not less than 450 g of fruit per kilogram of finished product as a general rule. This was previously 350 g. In addition, extra jam shall contain not less than 500 g of fruit per kilogram as a general rule.
- New category of “sugar‑reduced” fruit juices: A new product category, “sugar‑reduced fruit juice”, is established for fruit juices that remain 100% fruit‑derived but have undergone an authorised technological process to achieve at least a 30% reduction in naturally occurring sugars. These products must:
- Retain the essential characteristics of fruit juice, no added water, sugars or sweeteners, and
- Comply with the applicable compositional, naming and labelling rules under S.I. No. 621[3].
- Streamlined milk definitions for dehydrated and evaporated milk: To align milk product terminology with international standards, the definitions for dehydrated milk, evaporated milk and related preserved milk products will be updated. These revised definitions will be incorporated into national food legislation. They will apply to the placing on the market, presentation and labelling of these products, ensuring consistent terminology and clearer compliance requirements for operators.
- Deadline: These revised compositional requirements shall apply to all products placed on the market after the 14 June 2026 deadline.
- Grace period: Under transitional measures, food brands may continue to place and sell existing stocks of honey, fruit juices, jams, jellies, marmalades, chestnut purée, and preserved milk on the market after 14 June 2026 until exhausted. This is provided they are labelled or placed on the market before that date, in accordance with the underlying Directives amended by the Revised Breakfast Directive.
Improving transparency and compliance
To date, labelling for products like blended honey relied on broad, vague phrases such as "blend of EU and non-EU honeys," which made tracing authentic supply chains difficult. Implementing the revised Breakfast Directive is expected to significantly improve raw material traceability and empower consumers to make well-informed dietary choices.
The initiative will also work in tandem with the EU's broader customs and enforcement strategies to intercept adulterated components before they reach supermarket shelves, particularly non-compliant sugar syrup additions in honey imports.
Comment
As the Revised Breakfast Directive was transposed into Irish law, the amended standards are formally deemed "food legislation" under the scope of the Food Safety Authority of Ireland (FSAI) Act 1998. Therefore, enforcement bodies now have clear statutory power to police composition and labelling criteria.
Food brands must:
- Treat the 14 June 2026 deadline as a strict regulatory threshold rather than a soft guideline. Local enforcement bodies will have full authority to monitor compliance and issue market withdrawals for non-conforming goods, and
- Ensure all relevant products produced or labelled after this date strictly adhere to the updated standards.
For further information and tailored expert guidance on updating your product formulations, labelling compliance, or supply chain auditing ahead of the June deadline, please reach out to a member of our Food, Agribusiness & Beverage team.
The content of this article is provided for information purposes only and does not constitute legal or other advice.
[2] European Union (Marketing of Fruit Juices and Certain Similar Products) (Amendment) Regulations 2025
[3] European Union (Marketing of Fruit Juices and Certain Similar Products) (Amendment) Regulations 2025