Maker-Side Label Check for a Private-Label Food, Sri Lanka 2026
By the Silk Foods Ceylon Editorial Team
A blank white proof sheet beside three plain unlabelled glass jars of dark glossy sauce, a stainless kitchen scale and a closed clipboard on a neutral worktop.
Buyer’s snapshot
- A label is a set of figures, and every figure should trace to a record the maker already holds: the formulation sheet, supplier specifications, a laboratory report and the fill record.
- Five checks cover the ground before print: the ingredient list, the allergen set, the nutrition panel, the colour code values and the net contents.
- Cooking removes water, so a figure worked on ingoing weight can sit in a different colour band from the same figure on the finished food. In the worked example below, a 20 per cent cook-down moves salt from amber to red.
- The regulations do not require a plain label to be sent for approval before printing, so this review is the only gate the label passes through.
- Silk Foods Ceylon (SFC) runs the reconciliation inside R&D, which takes 3 to 4 weeks at most from signed brief to approved formulation, so it is finished before artwork is committed.
Sri Lanka’s labelling rules changed on 1 July 2026, and brand owners mostly ask about the front of the pack: which words, which languages, which logo. The maker’s question is whether every figure on the proof can be shown to come from something on file.
Two earlier SFC notes cover the rules themselves, the 2026 labelling regulations and the sugar, salt and fat colour code. This note sets out the review a maker runs on a proof before print, with a worked example of where a label figure and a plant record drift apart.
Why the maker’s check is the only check
The Food (Labelling and Advertising) Regulations 2026 (Gazette Extraordinary No. 2494/47) came into operation on 1 July 2026. Regulation 3 frames the duty as a prohibition: food may not be sold, imported, distributed or advertised unless labelled as required. Nothing in the text read for this note sends a plain label to a regulator for approval first. Prior written approval from the Chief Food Authority attaches to particular claims, which a descriptive pack avoids.
That puts the whole burden on the label’s author. An error is found on enforcement, after printing and filling, the most expensive point to find it. A short written reconciliation before print moves the finding to the cheapest point.
What does the reconciliation compare?
Each label element has a source record. The review confirms the two agree and that someone with authority has signed.
| Label element | Source record the maker holds | Signs it off | What forces a re-check |
|---|---|---|---|
| Ingredient list | Formulation sheet with ingoing weights; supplier specifications | R&D lead | Any change to a recipe line, a supplier or a grade |
| Allergen set | Supplier specifications, line-by-line review, cleaning and changeover records | Quality lead | A new supplier, a new carrier or flavouring, a shared line |
| Nutrition panel | Laboratory report on representative finished product; serving-size decision | Quality lead with R&D | Any formulation change, cook-down change or new serving size |
| Colour code values | The same laboratory report, per 100 g of the finished food | Quality lead | Any change to the report above |
| Net contents | Fill specification and fill-weight records | Production lead | A new jar, pouch or fill weight |
The right-hand column is the point. A label is stale the moment one of those triggers fires, and the person who owns the artwork rarely knows a supplier has changed.
Check one: the ingredient list against the formulation sheet
Regulation 5(2)(a)(i) requires a complete list of ingredients by common name, in descending order of ingoing weight (m/m) at the time of manufacture, with each permitted additive given by common name and INS number. Two phrases in that sentence decide the work. Ingoing means what went into the vessel, not what is in the jar. At the time of manufacture means the recipe as run on the day.
The regulations define an ingredient as any substance, including a food additive, used in the manufacture or preparation of a food. On that wording, water added in the recipe belongs in the list at its ingoing weight, which often places it first.
Three further provisions turn up here. A characterising ingredient named in the product name or emphasised in words or pictures needs its percentage of ingoing ingredients (regulation 9(2)). Added flavour enhancers need a separate statement of names and INS numbers at 1.5 mm or larger (regulation 10(4)). An animal-origin ingredient in a plant-based food must be declared in bold at that size, with dairy and a few others excepted (regulation 10(5)).
Check two: the allergen set against supplier specifications
The word allergen does not appear in the 2026 regulations. What the text does is name seven groups that may never be dropped from the ingredient list, including as processing aids that remain in the food: cereals containing gluten (wheat, spelt, rye, barley, oats and their hybrids), crustacea, eggs, fish, peanuts and soybeans, milk including lactose, and tree nuts, each with their products.
For the maker the work is a line-by-line pass through the specification of every incoming material, including the ones nobody thinks about: a seasoning with a wheat-based carrier, a flavouring in a milk-derived base, a processing aid used on the line. The recipe sheet lists the headline ingredient, not what sits inside it, so the supplier specification is the document that answers the question.
The text read for this note does not prescribe a “may contain” format. Whether to print a cross-contact statement is a decision for maker and brand owner together, resting on cleaning and changeover records. Recording the decision and its evidence is the check.
Check three: the nutrition panel against the laboratory report
Schedule II sets what a panel declares: energy, protein, total sugars, available carbohydrate, dietary fibre, total fat, saturated fat, trans fat and sodium, plus any nutrient named in a claim. Section 5.2 says the values used must be weighted average values derived from analysis of products representative of the one being labelled. A figure copied from a similar recipe does not meet that test.
Three details deserve a look. Energy uses the schedule’s conversion factors: 4 kcal per gram of carbohydrate or protein, 9 kcal per gram of fat, 3 kcal per gram of organic acid. Protein is total Kjeldahl nitrogen times 6.25 unless the method for that food gives another factor. And values appear per 100 g or 100 ml and per serving, with servings per pack stated, so the serving size must be decided and matched to the fill weight before typesetting.
Whether a panel is needed at all depends on the product and the date. It is mandatory now for claim-bearing foods and foods for infants, pregnant mothers and special dietary use, and for most other packaged food from late June 2027, with exemptions that include spices, salt, sugar, tea, packs of 100 square centimetres printable area or less, and cottage industry production. Populate the panel now rather than reprint later.
Check four: the colour code values against the same report
The colour code regulations of 2019 set red, amber and green bands for total sugar, total salt and total fat per 100 g of a solid or semi-solid food, and the logo carries the numeric value. That value must come from the same laboratory report as the nutrition panel, and the two have to agree.
Two traps sit here. The panel declares sodium, while the colour code is framed in salt as sodium chloride, so someone has to convert and the report should state the factor used. And the value is per 100 g of the finished food, which is where cooking changes the answer.
A worked example: how a cook-down moves a band
The batch below is an illustrative sweet and sour fruit chutney. The ingoing weights are invented, and the sugar from the dates and tamarind is an assumption; a real file uses the laboratory report.
| Ingredient | Ingoing weight (kg) |
|---|---|
| Water | 38.0 |
| Sugar | 24.0 |
| Dates | 15.0 |
| Tamarind pulp | 12.0 |
| Vinegar | 5.0 |
| Onion | 3.0 |
| Salt | 1.1 |
| Vegetable oil | 1.0 |
| Chilli | 0.9 |
| Total ingoing | 100.0 |
The ingredient list follows the table top to bottom, descending ingoing weight. The batch cooks down to 80 kg of finished food, so 20 kg of water has evaporated.
Salt is 1.1 kg in 100 kg of ingoing material, which reads as 1.1 g per 100 g and an amber value, since amber for salt runs from 0.25 g to 1.25 g. On the finished food it is 1.1 kg in 80 kg, which is 1.375 g per 100 g, and that is red. The water left and the salt stayed.
Sugar is 24 kg added, plus an assumed 9 kg from the dates and 3.6 kg from the tamarind pulp: 36.6 kg in 80 kg, about 45.8 g per 100 g, well above the 22 g red threshold. Oil at 1.0 kg in 80 kg is 1.25 g per 100 g, inside the green fat band (below 3 g).
At a 15 g serving the same product delivers about 6.9 g of sugar and 0.21 g of salt. Those are the panel’s per-serving figures. The logo uses the per 100 g figures, so the one jar carries a red sugar logo, a red salt logo and a green fat logo.
The lesson is that the cook-down yield is itself a record. If the yield on the line drifts from 80 per cent to 76, the salt value moves with it. A figure close to a band boundary deserves a margin, and a conversation with the laboratory about declared tolerance.
Check five: net contents against the fill record
Regulation 5(1)(c) requires net contents in SI units, with the net drained weight where the food is packed in a liquid medium. The fill specification, the fill-weight records and the printed figure must be the same number. This is also the check that catches a late fill-weight change, because net contents, panel area, type size and the per-serving column all move together when a 250 g jar becomes 300 g.
Putting the five checks into a signed sheet
The reconciliation works best as a single page that travels with the proof: one line per label element, giving the figure on the proof, the record it came from, that record’s version, who confirmed it and the date. A second block lists the triggers from the table above. A change after sign-off reopens the line it touches and every line that depends on it.
A buyer or auditor will ask for this page, and it sits beside the quality records a food maker keeps before launch and the documentation pack for a private-label SKU. The shelf-life file is the record behind the date, the artwork and print lead-time gate covers sequencing around print, and a clean-label reformulation reopens the whole sheet.
Frequently asked questions
Does a Sri Lankan food label need approval before printing?
No. The Food (Labelling and Advertising) Regulations 2026 contain no general pre-approval step for a plain label; compliance is the manufacturer’s obligation and is tested on enforcement. Prior written approval from the Chief Food Authority applies only to particular claims, such as health claims under regulation 13(6)(a) (Government of Sri Lanka, 2026).
In what order must ingredients be listed on a Sri Lankan food label?
Regulation 5(2)(a)(i) requires descending order of ingoing weight (m/m) at the time of manufacture, with permitted additives named and given their INS numbers. Ingoing weight is what went into the vessel, so a cooked product is ordered on the recipe sheet, not on the finished weight (Government of Sri Lanka, 2026).
Why can a colour code band change after cooking?
The colour code is read per 100 g of the finished food. Cooking removes water and leaves salt and sugar behind, so the same ingredients are more concentrated. In the worked example, 1.1 kg of salt reads as 1.1 g per 100 g ingoing, amber, but 1.375 g per 100 g on 80 kg finished, red.
Does Silk Foods Ceylon check labels for a private-label run?
Yes. Label reconciliation is part of the work between a tested recipe and a retail-ready SKU at the Matale facility, alongside Sri Lanka Food Act labelling support. A locked recipe typically goes from purchase order to dispatch in 2 to 3 weeks, and R&D takes 3 to 4 weeks at most (SFC, 2026).
How Silk Foods Ceylon can help
For founders and brand owners launching a first commercial run, Silk Foods Ceylon (SFC) operates a cellular-manufacturing facility in Matale that handles the steps between a tested recipe and a retail-ready SKU, including the label reconciliation described above. Small runs are welcome, quote on request. Lead times typically run 2 to 3 weeks once a recipe is locked. Where R&D is needed first, it takes 3 to 4 weeks maximum from signed brief to approved formulation. The Matale facility is BRCGS- and FSSC 22000 V6-audited, with SLSI submission support and Sri Lanka Food Act labelling support built into a standard engagement.
To brief a project, email brands@esilkroute.com.lk or call +94 77 157 7294.
Sources
- Government of Sri Lanka, Food (Labelling and Advertising) Regulations 2026, Gazette Extraordinary No. 2494/47 of 26 June 2026, read in full for this note: regulations 3, 5, 9, 10 and 13 and Schedule II (sections 3 to 6). eohfs.health.gov.lk (retrieved 10 November 2026).
- Government of Sri Lanka, Food (Colour Coding for Sugar, Salt and Fat) Regulations 2019, Gazette Extraordinary No. 2119/3 of 17 April 2019, on the Schedule I bands per 100 g; the file is a scanned image, so the bands are as transcribed in SFC’s 20 September 2026 reading. eohfs.health.gov.lk (retrieved 10 November 2026).
- Ministry of Health, Directorate of Environmental Health, Occupational Health and Food Safety, Current Regulations register under the Food Act No. 26 of 1980. eohfs.health.gov.lk (retrieved 10 November 2026).
- Silk Foods Ceylon (2026), internal capability data for the Matale facility: sample dispatch in 1 to 2 weeks on an existing recipe, R&D of 3 to 4 weeks at most from signed brief to approved formulation, and 2 to 3 weeks from purchase order to dispatch on a locked recipe.
Written by the Silk Foods Ceylon Team. Silk Foods Ceylon (Pvt) Ltd. is a BRCGS- and FSSC 22000 V6-audited contract manufacturer in Matale, Sri Lanka, offering contract manufacturing, private labelling, co-packing, and in-house R&D for local Sri Lankan brand owners, FMCG companies, hotel and restaurant groups, and distributors. To brief a project: brands@esilkroute.com.lk or +94 77 157 7294.
