NOM-051 and the labelling deadline European food brands keep missing

NOM-051-SCFI/SSA1-2010 is the Mexican standard governing the labelling of prepackaged food and non-alcoholic drink. Its 2020 modification introduced the black octagonal warning seals that now dominate the front of Mexican packaging, plus rules on the use of characters and cartoons on products carrying them.

It applies to imported products on exactly the same terms as domestic ones. There is no equivalence route, and an EU-compliant label carrying a Nutri-Score or a European nutrition declaration does not satisfy it.

What the standard actually requires

Products exceeding thresholds for energy, added sugars, saturated fat, trans fat or sodium must carry the corresponding octagonal seal on the front of the package, sized and placed as the standard specifies. Products carrying seals face restrictions on the use of characters, celebrities, animations and interactive elements that appeal to children. There are also precautionary legends for sweeteners and caffeine.

Three practical points for a European exporter.

The seals are calculated against a Mexican profile. A product that carries no warning in the EU can carry two or three seals in Mexico, because the thresholds and the reference basis are different. Run your own nutritional data against the Mexican criteria before you cost a print run.

Spanish is mandatory and the required information has to be present at the point of import, not added later at retail.

Relabelling in Mexico is permitted but is an operation. It happens in bonded warehouses or authorised facilities under customs supervision, it has a per unit cost, and it introduces a step between the port and the shelf. For a first shipment it can be the pragmatic answer. As a permanent model it is a tax on every case you sell, and the correct answer is a Mexican artwork variant.

The phases, and the part that moved

The 2020 modification set out compliance in phases, with progressively stricter criteria. An agreement published in the Diario Oficial de la Federacion on 31 July 2025 extended the period of the second phase and updated the start of the third.

We want to be straight about the sourcing here. The instrument and its date are confirmed. The specific end and start dates of 31 December 2027 and 1 January 2028 come to us through secondary reporting of that agreement rather than from the agreement's own text, which we have not been able to open. Treat them as the working dates and confirm them against the Diario Oficial before you commit a print run or a launch date to them.

Who actually stops your product

Two agencies, with different reach, and knowing which one you are dealing with changes what you do about it.

COFEPRIS, the health regulator, sits on the sanitary side. It has a role at import for products in its scope and enforces the health-related aspects of labelling.

PROFECO, the consumer protection agency, enforces at the point of sale. It conducts retail inspections and can order product immobilised on the shelf.

The practical consequence is that clearing customs is not the end of the exposure. A shipment can enter and then be immobilised in store months later, at which point the cost falls on your distributor, and then on your relationship with them. Since your distributor is usually also your importer of record and often your certificate holder, as we set out in why a European company cannot be its own importer in Mexico, a labelling failure lands on the party you most need to keep on side.

What to do before your first order

1. Run your nutritional panel against the Mexican thresholds and find out how many seals you carry. This is a desk exercise and it takes an afternoon.
2. If you carry seals, check whether your existing artwork uses characters or claims that then become prohibited. Several European confectionery and cereal brands have had to redesign rather than relabel.
3. Decide artwork variant versus relabelling, with the per unit relabelling cost in front of you rather than as an assumption.
4. Confirm the current phase dates against the Diario Oficial, not against a summary.

For where these products then have to be sold, see getting listed in Mexican retail.

Common questions

Does NOM-051 apply to imported food?

Yes, on the same terms as domestic product. There is no equivalence route for EU labelling, and the required information must be present when the goods are imported rather than added afterwards at retail.

Can I relabel imported products in Mexico instead of changing my artwork?

Yes. Relabelling under customs supervision is permitted and is commonly used for first shipments and small volumes. It carries a per unit cost and adds a step between port and shelf, so as a permanent model it is usually more expensive than a Mexican artwork variant.

What are the black octagons on Mexican food packaging?

Front of pack warning seals required by NOM-051 where a product exceeds Mexican thresholds for energy, added sugars, saturated fat, trans fat or sodium. Products carrying them also face restrictions on child-directed marketing elements on the pack.

Who enforces food labelling in Mexico, COFEPRIS or PROFECO?

Both, in different places. COFEPRIS covers the sanitary and health-related side including at import. PROFECO enforces at the point of sale and can immobilise product on the shelf, which means clearing customs does not end the exposure.