As of 1 August 2025, the newly adopted Regulation on Additional Requirements for the Placement on the Market of Products Containing Palm Oil, Palm Fat, or Other Vegetable Oils and Fats (the “Regulation”) will come into effect in Serbia, marking a significant development in the regulatory framework at the intersection of food law and consumer protection.
The Regulation introduces a series of obligations aimed at enhancing transparency in the presentation and advertising of certain food products. Its primary aim is to prevent consumer deception, specifically in differentiating between dairy-based items and those made with vegetable substitutes, like palm oil and palm fat.
The original version of the Regulation, adopted earlier this year, raised concern within the food retail sector due to its broad and somewhat vague wording. By referring to products containing palm oil and other vegetable oils, the Regulation was initially interpreted as potentially applying to a much wider range of products than intended. However, the amended text, published in July, brought (some) welcome clarity. The scope now targets a clearly defined group of products — namely dairy products, filled bakery goods containing dairy components, and pizzas with dairy ingredients — which also contain palm oil, palm fat, or other specified vegetable oils and fats. This is further detailed in an annexe listing the exact product categories, including inter alia fermented dairy products, butter and sour cream, as well as filled pastries such as burek and strudel.
Under the Regulation, food business operators — including importers, wholesalers, retailers, entities engaged in distance selling and vending machine sales, and food service providers such as bakeries, restaurants, school canteens, hospitals, etc. — are responsible for compliance. They must ensure that affected products are clearly marked with a standardised warning label and are physically separated from traditional dairy or dairy-containing products in retail displays. The prescribed label consists of a yellow triangle with a red exclamation mark, accompanied by the statement “Not 100% dairy product – contains palm oil or other vegetable oils” – which may still be confusing in certain cases, e.g. when it stands next to a pizza or burek.
Additionally, operators must provide accessible consumer information through various media such as packaging, menus, digital channels, and verbal communication where applicable. Compliance also requires adherence to specified temperature conditions for chilled products.
Furthermore, the Regulation draws a clear distinction between products that contain dairy components — for which the above-described obligations regarding labelling, physical separation, and consumer information apply — and those that do not. For non-dairy products, it is strictly prohibited to use dairy-related terms or imagery in any form of labelling, advertising, or marketing. This includes references such as “cheese,” “plant-based cheese,” “cheese-style,” “a la,” or similar expressions, as well as visual depictions of dairy products — especially where such presentation may mislead consumers into believing the product contains milk or milk-derived ingredients.
While the new rules will apply as of 1 August, a transitional period has been foreseen, allowing relevant products labelled under the previous regime to remain in circulation until their expiry date, but no later than 31 December 2025, provided they are clearly separated from products that could be mistaken for traditional dairy-based items. With the effective date approaching, food business operators may wish to revisit their internal practices and assess the adjustments needed to ensure compliance.
As this regulatory landscape evolves, we remain committed to keeping you informed of key developments and practical guidance.
The information in this document does not constitute legal advice on any particular matter and is provided for general informational purposes only.
