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Labeling: how to indicate “sugar syrups”

26 May 2026
Stefano Senatore, Avvocato ed Esperto di Legislazione degli Alimenti

Regulation (EU) 1169/2011 allows compound ingredients to be listed in the ingredients list by opening the parentheses and listing them; similarly, it sometimes allows ingredients to be grouped together and specified in parentheses. Is it possible to do the same with sugar syrups? For example, if we had a recipe consisting of FRUIT 59%, GLUCOSE-FRUCTOSE SYRUP 25%, PECTIN 10%, GLUCOSE SYRUP 5%, COLOURING 1%, would it be possible to declare the ingredients on the label as follows: FRUIT, GLUCOSE-FRUCTOSE SYRUP, PECTIN, COLOURING? Although the ingredients “glucose-fructose syrup” and “glucose syrup” are two distinct ingredients when mixed, is it possible to group them together given their similar nature? Would it be correct to refer to them as glucose and fructose syrup, given that the two distinct ingredients contain glucose and fructose in one and glucose in the other? In the case illustrated, they would be listed in descending order by weight, as glucose would be present in greater quantities than fructose.

First, it is worth remembering that, for the purposes of providing food information to consumers, Article 18, paragraph 2 of Regulation (EU) 1169/2011 requires that the ingredients of a food be designated “by their specific name, in accordance with the rules laid down in Article 17 and Annex VI.”

Consequently, pursuant to the aforementioned Article 17, paragraph 1, the names listed in the list of ingredients must correspond to their legal name, where applicable, or to their usual name, or, in extreme cases, to a descriptive name.

That said, with regard to the glucose syrups at issue, the EU legislator has defined specific legal names through Directive 2001/111/EC – part of the so-called “Breakfast Package” – implemented in Italy by Legislative Decree 51/2004.

According to Annex I, point 7 of the national legislation, in particular, the term “glucose syrup” identifies “a purified and concentrated aqueous solution of food saccharides, obtained from starch and/or inulin, and which meets the following characteristics:

a) Dry matter not less than 70% by weight

b) Dextrose equivalent not less than 20% by weight of the dry matter, expressed as D-glucose

c) Sulfated ash not more than 1% by weight of the dry matter.”

However, according to Article 2, paragraph 2, letter g) of the same legislative decree, if the glucose syrup contains fructose in a quantity greater than 5% of the dry matter, the term “glucose-fructose syrup” or “fructose-glucose syrup” must be used, depending on the predominant sugar.

From the relevant legislation, it can therefore be deduced that “glucose syrup,” “glucose-fructose syrup,” and “fructose-glucose syrup” are essentially the same products, both in terms of production process and composition, differing only in terms of the percentage of fructose present.

Therefore, in the author’s opinion, where a food recipe calls for the use of glucose syrup and glucose-fructose syrup, mixed together before being added to the preparation, it would be reasonable to allow the two sugars to be identified in the list of ingredients under the single name “glucose-fructose syrup.” Such a name, in fact, would be consistent with the provisions of Legislative Decree 51/2004 – as previously mentioned – and would not, in principle, be misleading to consumers.

It should be clarified, however, that the aforementioned interpretation – though well-reasoned and justifiable – is not explicitly supported by the regulatory framework to date. Consequently, as a precaution, to prevent any potential disputes, it is still advisable to identify the two ingredients separately on the label, with the respective names of “glucose syrup” and “glucose-fructose syrup”.