Ask who signed off the label on your biggest selling product and you will usually get a name. Ask what that person checked and you will usually get a pause. In most plants the honest answer is that they read the artwork for spelling, saw that the logo was the right green, and signed.
In short
- A food label sign off checklist is run by a named, technically competent person, in writing, with the evidence filed.
- The checklist follows the R146 of 2010 mandatory particulars, plus net quantity under the Legal Metrology Act 9 of 2014, the nutrition table and every claim.
- Check the label against the current recipe, supplier specifications and allergen matrix, never against the previous label.
- Letter size and legibility are checked on the printer’s proof at final size.
- Sign off is not the end. Recipe, supplier, process, pack size and regulation changes must each trigger a review.
A signature without a checklist is decoration. The list below is one a technologist can run on Monday. It follows the way the Advanced Food and Beverage Labelling Course from ASC Food Safety Training breaks a label down: particulars, then numbers, then claims, then the controls that keep it right. The course costs R2 950. One label run with a missed allergen can cost a recall.
Who should sign off a food label in a South African food business?
A food label should be signed off by a named person with the technical knowledge to check it against the law and the authority to stop a print run. In practice that is a technologist, QA manager or regulatory specialist, working to a written procedure.
Marketing owns the look and the designer owns the file. Neither owns compliance. Inspectors, the retailer and the National Consumer Commission under the Consumer Protection Act 68 of 2008 will come to the responsible party on the pack, and “the agency did it” is not a defence.
Good practice is two signatures: one technical, one commercial.
What should be on a food label sign off checklist?
A food label sign off checklist for South Africa covers everything R146 makes mandatory, the net quantity rules under legal metrology, the nutrition information table, every claim with its evidence, and the controls around the artwork file itself. Each of the fourteen items needs a source document to check against and a record that the check was done.
| What to check | Check it against |
|---|---|
| 1. Name and description | |
| True description of the food, not misleading, meets any compositional standard for the category | Product specification, category regulations |
| 2. Ingredient list | |
| Descending order of mass, compound ingredients broken down, additives named correctly, percentage shown for emphasised ingredients | Current recipe and supplier specifications |
| 3. Allergens | |
| Every common allergen declared as R146 requires, including those hidden in compound ingredients and processing aids. Precautionary statements backed by a risk assessment | Allergen matrix, supplier declarations |
| 4. Net quantity | |
| Correct metric unit, position and numeral size for the pack size | Legal Metrology Act requirements, fill data |
| 5. Date marking | |
| Permitted wording, clear format, a printable position on the pack | Shelf life study, coder capability |
| 6. Storage and use instructions | |
| Storage before and after opening, validated cooking instructions | Shelf life and cooking validation records |
| 7. Responsible party | |
| Name and address of the manufacturer, packer, importer or seller, as the regulation requires | Company registration details |
| 8. Country of origin | |
| Wording that matches the facts. R146 ties specific phrases to where the food was grown, processed or packed | Sourcing records |
| 9. Batch identification | |
| A code that links the pack to production records | Traceability procedure |
| 10. Letter size and legibility | |
| Minimum letter heights under the regulation, contrast, language, nothing mandatory hidden in a seal or fold | Printer’s proof at final size, with a ruler |
| 11. Nutrition table | |
| Prescribed format and units, per 100 g or 100 ml and per serving, energy arithmetic, rounding | Calculation file, laboratory reports |
| 12. Claims | |
| Each claim permitted, qualifying criteria met, no prohibited wording, pictures and brand names included | Claim substantiation file |
| 13. Imported product stickers | |
| Sticker carries the missing South African particulars and hides nothing mandatory | Original label translation, importer details |
| 14. Version control | |
| Artwork version number, approved text document, old versions withdrawn at the printer | Artwork register |
Where a number matters, such as a letter height or a numeral size for net quantity, check the current regulation text.
A checklist tells you what to check. It does not tell you what right looks like for item 3 or item 12. Most of that table is taught in ASC’s R146 food labelling course for the people who sign off labels. Module 1 alone covers the mandatory particulars in technical detail, the anatomy of a compliant label and a worked pasta sauce example.
Start the Advanced Food and Beverage Labelling Course, R2 950
What does a workable label sign off workflow look like?
A workable label sign off workflow has five steps in a fixed order: freeze the specification, approve the text before any design work, check the artwork against that text, sign with a name, date and version number, then verify the first print run on the line. Steps two and five are the ones most often skipped.
1
Freeze the inputs. Current recipe, supplier specifications, allergen matrix, shelf life, fill weight. If any of these is still moving, stop.
2
Approve the text. Write the label copy in a plain document and run the checklist on it before a designer touches it.
3
Check the artwork. Compare the proof with the approved text word for word, at final print size, including letter heights.
4
Sign and file. Name, date, version number, completed checklist and evidence in one place.
5
Verify the first run. Check printed packs on the line: right version, legible date code, the old stock quarantined.
Which checklist items fail most often?
The label checklist items that fail most often are allergens, ingredient order, net quantity presentation, letter size and unsupported claims. They fail for the same reason: the label was checked against the previous label and not against the current recipe and specifications.
A copied error passes every proofread because it looks familiar.
Allergens are the dangerous one. A supplier swaps a carrier in a spice blend, the specification arrives by email, and nobody connects it to the artwork. Letter size fails quietly: the text was legal on the 500 g pack, and then someone shrank the same artwork onto the 125 g tub. Claims fail when marketing adds a word that R146 restricts or prohibits, such as “wholesome” or “nutritious”, late in the process. There is more in common food label mistakes in South Africa.
Nutrition table failures are mostly arithmetic and yield. See how to calculate a nutrition information table. If the panel declares vitamins, the value has to hold to the end of shelf life, which is the subject of vitamin overage and label claims.
How should you handle imported products and stickers?
An imported product sold in South Africa must meet South African labelling law, whatever was legal where it was made. The importer becomes the local responsible party. A sticker may supply the missing particulars, provided it is durable and legible and does not cover mandatory information that is already on the pack.
Run the whole checklist on the foreign label first. Expect gaps in allergen presentation, the nutrition table format and units, the language, claims that are permitted abroad and not here, and the local name and address. Then check where the sticker will physically sit on the pack. A sticker that covers the date code causes more trouble than it solves.
What should trigger a label review after sign off?
A label review should be triggered by any change to the recipe, an ingredient supplier or specification, the process, the pack size or format, the shelf life, a claim, the company address, or the regulations. Add a scheduled review, at least yearly, to catch what change control missed. A label is only correct for the product and the law on the day it was signed.
Build the triggers into change control so a purchasing decision cannot bypass the label. What a recipe change should trigger sets out the mechanics. On the regulatory side, draft replacement labelling regulations (R3337) were published for comment in April 2023 and had not been finalised at the time of writing. Treat R146 as the regulation in force unless you have checked otherwise.
What does the Advanced Food and Beverage Labelling Course cover, and what does it cost?
The Advanced Food and Beverage Labelling Course is an advanced online food labelling course from ASC Food Safety Training. It costs R2 950 and is self paced. The checklist above maps to module 1 (mandatory particulars, legal metrology, letter sizes under regulation 8, imported products), module 2 (nutrition), module 4 (claims and substantiation), module 5 (ingredients, allergens and additives) and module 7 (risk, enforcement, recalls and the practical workshop).
| Course | Advanced Food and Beverage Labelling Course |
|---|---|
| Provider | ASC Food Safety Training |
| What you take back to work | The anatomy of a compliant label, a regulation by regulation map of R146, a pre sign off checklist for panel errors and a practical workshop |
| Level | Advanced. Third step in the ASC labelling ladder |
| Time | Seven modules, worked through at your own speed |
| Price | R2 950, paid once. Card or EFT through PayFast |
| Format | Online, self paced, lifetime access |
| Assessment | A knowledge test for each module and a course assessment |
| Certificate | Certificate of completion |
| Who it is for | The people who check and sign off labels |
Enrol in the Advanced Food and Beverage Labelling Course, R2 950
Questions people ask before they enrol
How much does the Advanced Food and Beverage Labelling Course cost, and how long does it take?
R2 950, paid once by card or EFT through PayFast. That covers seven online modules, a knowledge test for each module, a course assessment, lifetime access to the material and a certificate of completion. There is no fixed timetable: the course is self paced, so you work through it around production.
Is this the right level for me, or should I start lower?
It is the third step in the ASC labelling ladder, after Essentials of Food Labelling Claims (R1 250) and Labelling Claims and Regulatory Framework (R1 750). If you already sign off labels against R146, start here. If the mandatory particulars are new to you, start with Essentials.
Does the course suit my sector?
The core modules deal with prepacked food and beverage labels in general. Module 5 covers ingredients, allergens, additives, sugar, sweeteners and caffeine, and module 6 covers category specific requirements, alcohol and the boundary between food and medicine. Importers are covered in module 1.
How is the course assessed, and do I get a certificate?
Each of the seven modules has a knowledge test and there is a course assessment at the end. You receive a certificate of completion. Module 7 includes a practical workshop.
Can I enrol from outside South Africa?
Yes. Prices are in rand, the course page shows an indicative equivalent in US dollars, euros and pounds, and payment settles in rand. The course is built on South African law, which is what you need if you export to or import into South Africa.
Print the table, run it on one live label this week, and count the items you could not evidence. That count is your training need, and your name is on the signature. A reprint, a sticker run, an allergen recall: price any one and put it next to R2 950. Enrol in the Advanced Food and Beverage Labelling Course (R2 950) before the next artwork lands on your desk. The food labelling training hub shows the two courses that come before it.
This article is training material, not legal advice. Check the current regulation text where a number matters. The course is an independent training product and is not approved or endorsed by any government department or regulator.