Allergen Labelling Guide
Food allergies affect around 2 million Britons, making proper allergen labelling essential for consumer safety. This comprehensive allergen labelling guide explains the regulations on how food manufacturers must declare allergenic ingredients by law. Understanding these requirements is crucial for food businesses and consumers alike. For a broader overview, see our complete food labelling requirements guide.
The foundation of allergen labelling in Europe is Regulation (EU) No 1169/2011, also known as the Food Information to Consumers (FIC) regulation. Implemented in December 2014, this legislation modernised how allergen information is presented to consumers. The European Food Information Council (EUFIC) provides guidance on these regulations, which aim to protect allergic individuals and ensure transparent food labelling across all EU member states.
Introduction to the Allergen Labelling Guide
The Legal Framework: EU Regulation 1169/2011
This allergen labelling guide is based on the principle that consumers have the right to clear, accurate information about what they’re eating. The regulation applies to all prepacked foods, non-prepacked foods, and meals served in restaurants, cafés, and catering establishments.
The 14 Mandatory Allergens
According to EUFIC guidelines and Annex II of the FIC regulation, fourteen specific substances must be declared on food labels when present as ingredients. This allergen labelling guide lists all fourteen:
- Cereals containing gluten including wheat (such as spelt and Khorasan wheat), rye, barley, oats, and their hybridized strains
- Crustaceans such as prawns, crabs, lobster, and crayfish
- Eggs and all egg products
- Fish and fish-derived products
- Peanuts and peanut-derived products
- Soybeans and soy products
- Milk including lactose and all dairy products
- Nuts specifically ‘tree nuts’: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, and Macadamia (Queensland) nuts
- Celery and celeriac
- Mustard including mustard seeds and products
- Sesame seeds and sesame-derived products
- Sulphur dioxide and sulphites at concentrations above 10mg/kg or 10mg/litre
- Lupin and lupin-based products
- Molluscs such as mussels, oysters, squid, and snails
These allergens were selected based on scientific evidence from the European Food Safety Authority (EFSA), that identified them as the most common and serious causes of food hypersensitivity across Europe.
Highlighting Requirements in the Ingredients List
One of the most important aspects of this allergen labelling guide concerns how allergens must be presented. The FIC regulation mandates that allergenic ingredients must be emphasized within the ingredients list to make them easily identifiable. Food manufacturers have flexibility in choosing their emphasis method, but it must clearly distinguish the allergen from other ingredients.
Acceptable highlighting methods include:
- Bold typeface (the most commonly preferred method)
- Different font style (such as italics)
- Contrasting background colour
- Underlining
- CAPITAL LETTERS
- A combination of these methods
The key requirement is that the allergen must stand out visually from the rest of the ingredients list. For example, an ingredient list might read: “Wheat flour, sugar, eggs, vegetable oil, milk powder, salt.” The words “wheat”, “eggs” and “milk” are emphasized to alert allergic consumers.
When an ingredient name doesn’t obviously indicate the presence of an allergen, the allergen must be referenced in parentheses. For instance: “tahini (sesame)”, “whey powder (milk)”, or “couscous (wheat)”. It is also pertinent to explain the specific allergen such as wheat (gluten), oats (gluten), spelt (gluten)
The Ban on Separate Allergen Lists
A critical rule covered in this allergen labelling guide is that separate allergen declaration boxes are not permitted under EU regulation. Prior to December 2014, many manufacturers used “Contains” statements or separate allergy advice boxes listing allergens outside the ingredients list. This practice is now prohibited.
The reasoning behind this restriction is consumer safety. Research revealed that consumers relying on separate allergen boxes often overlooked allergen information in the ingredients list. Additionally, separate statements sometimes contained inconsistent information compared to the actual ingredients list, creating dangerous confusion.
However, manufacturers may include signposting statements such as “For allergens, see ingredients in bold” to help consumers locate the highlighted information within the ingredients list. These advisory statements direct attention to the proper location but do not repeat the allergen information separately.
This harmonized approach ensures consistency across all EU food products, reducing confusion and improving safety for allergic consumers who must check every label carefully.
Cross-Contamination and Precautionary Allergen Labelling
While mandatory allergen declarations cover intentionally added ingredients, this allergen labelling guide must also address unintentional allergen presence. Cross-contamination can occur when allergens from one product transfer to another during production, even when not intentionally added.
Currently, precautionary allergen labelling (PAL) statements are voluntary and not harmonized across the EU. Common phrases include:
- “May contain [allergen]”
- “Made in a facility that also processes [allergen]”
- “Made on equipment that also processes [allergen]”
- “Not suitable for customers with [allergen] allergy”
These statements help manufacturers communicate cross-contamination risks. However, because they’re voluntary and lack standardized wording, their use varies significantly between manufacturers. Some apply them broadly as a precaution, while others use them only after rigorous risk assessment.
Food safety advocates and patient organizations continue pushing for mandatory, standardized precautionary labelling backed by scientific risk assessments. The goal is to provide clearer, more consistent information about trace allergen risks.
Special Considerations and Exemptions
This allergen labelling guide should note that certain processed derivatives of allergenic foods may be exempt from labelling requirements. The EFSA evaluates these exemptions based on scientific evidence that processing has removed allergenic proteins to trace levels unlikely to cause reactions.
Examples of exempted products include:
- Fully refined soybean oil
- Cereals used for making distillates in alcoholic beverages
- Certain wheat-based glucose syrups
- Specific tocopherols derived from soybeans
These exemptions are regularly reviewed as scientific understanding evolves.
Additionally, for sulphur dioxide and sulphites, labelling is only mandatory when concentrations exceed 10mg/kg or 10mg/litre in the ready-to-consume product. This applies even to alcoholic beverages, which are not exempt.
Non-Prepacked Food and Restaurant Requirements
This allergen labelling guide extends to non-prepacked foods, including restaurant meals, bakery items sold loose, and delicatessen products. Food service establishments must provide allergen information, though they have more flexibility in presentation methods.
Acceptable methods include:
- Written menus with allergen information
- Chalkboards or display signs
- Information booklets or sheets
- Verbal communication by trained staff
If allergen information is provided verbally, establishments must display clear signage indicating that customers should ask staff for details. This ensures allergic consumers know information is available.
Positive ID Labelling Solutions for Food Businesses and Sandwich Labelling
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All food labelling guides are provided in good faith for information purposes only and do not constitute legal advice. For specific compliance questions about specific labelling laws, contact a specialist or contact your local Trading Standards authority. Read our Regulatory Information Disclaimer