The annex to Regulation (EC) 1924/2006 is the benchmark of which you're probably thinking:
SOURCE OF FIBRE
A claim that a food is a source of fibre, and any claim likely to have the same meaning for the consumer, may only be made where the product contains at least 3g of fibre per 100g or at least 1.5g of fibre per 100kcal.
If the exact wording they are using on FoP is "source of fibre" then this is the one the recipe would need to meet, but if the wording is different then you may also need to be aware of the additional "high fibre" claim option and check that either the product complies, or that the wording doesn't inadvertently imply this one over the lesser "source of fibre" version above.
A claim that a food is high in fibre, and any claim likely to have the same meaning for the consumer, may only be made where the product contains at least 6g of fibre per 100g or at least 3g of fibre per 100kcal.
There are three entries for Flapjack in the current McCance & Widdowson's dataset, available for free here: https://www.gov.uk/g...d-dataset-cofid
Nonetheless as there is a specific nutritional claim involved I certainly wouldn't be comfortable with relying solely on reference data based on flapjacks of unknown composition, so IMO yes this really should be analytically confirmed for your customer's particular formulation.
Pictorial representation can be a minefield!
I've attached a guide from the FDF that is potentially useful, but this was developed in association with the UK Flavour Association and therefore does lean very heavily towards interpretation in cases of flavourings rather than ingredients.
Nonetheless the same principle as per Article 7(1)(d) of Regulations (EU) 1169/2011 applies:
Food information shall not be misleading, particularly... by suggesting, by means of the appearance, the description or pictorial representations, the presence of a particular food or an ingredient, while in reality a component naturally present or an ingredient normally used in that food has been substituted with a different component or a different ingredient.
Is there actually fruit in the product and does the product also taste of the pictured fruit(s), and/or reasonably characterise the nature of the product?
If the answer is yes then you're probably fine to use the pictures.
Nonetheless if unsure then ask your local TSO - they'll review labels for a tiny fee (compared to the normal research associations) so you have a bit more certainty if needed.
I'd also recommend having a wonder through the relevant aisles of your local supermarkets - see what the big retailers / large brands are doing with these types of product, as they've usually got a significant amount of regulatory/legal resource behind them
As a tangential consideration - Are the pictured ingredient QUID'ed in the ingredient dec? They should be if there is a picture of them on the label, in accordance with Article 22(1)( c) of 1169/2011.