Allergens on the label: which 14, and how they have to appear
Every ingredients list on a prepacked food has to show the allergens it contains. The rule is not a general one: it states which allergens, where they go, and how they have to stand out visually. Below we explain what the text says.
The legal basis
The rule is Regulation (EU) No 1169/2011 on the provision of food information to consumers, applicable since December 2014. It is a regulation and not a directive: it applies directly and in identical wording in every member state, with no national transposition.
The fourteen in Annex II
- cereals containing gluten (wheat, rye, barley, oats, spelt, kamut) and products thereof
- crustaceans and products thereof
- eggs and products thereof
- fish and products thereof
- peanuts and products thereof
- soybeans and products thereof
- milk and products thereof, including lactose
- nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamias) and products thereof
- celery and products thereof
- mustard and products thereof
- sesame seeds and products thereof
- sulphur dioxide and sulphites at concentrations above 10 mg/kg
- lupin and products thereof
- molluscs and products thereof
How they have to appear
Article 21 states that the allergen is declared inside the list of ingredients and that its name is emphasised through a typeset that clearly distinguishes it from the rest of the list, for example by means of the font, the style or the background colour.
Commission Notice 2017/C 428/01 sets out the accepted forms concretely: bold text, underlining, capital letters or a different background colour, as long as the contrast is visible.
The emphasis applies to every occurrence of the allergen in the list, not only the first one.
A separate box does not replace the emphasis
The emphasis is required inside the ingredients list. A separate box stating contains… next to the list does not on its own satisfy the obligation.
Only one quantitative threshold
For thirteen of the fourteen there is no threshold: where the allergen is used as an ingredient it is declared, even in traces. The single exception is sulphur dioxide and sulphites, declared where they exceed 10 mg/kg expressed as SO₂.
May contain is not regulated
EU law contains no provisions on the unintentional presence of an allergen. A may contain traces statement is given voluntarily by the business. Its presence therefore follows no standardised criterion, and its absence is not a declaration of absence.
Also without packaging
Since 2014 the obligation also covers non-prepacked food, which includes restaurants and canteens. The same requirements apply to distance selling, such as online orders.
In Germany
The German LMIDV (Lebensmittelinformations-Durchführungsverordnung) supplements the regulation with national implementing detail. For non-prepacked food it permits oral information, under two conditions that have to be met at the same time: a clearly visible notice on the premises stating that the information is available on request, and complete written documentation accessible to staff at all times.
In other member states, France among them, written declaration is required without exception. The basis is common; the way the information is provided is not.
Why it matters in a recall
A large share of food recalls concerns an undeclared allergen. In those cases the notice states which allergen was not declared and which lots are affected.
If you have a label in front of you and cannot place the entries: VeraRead reads the label and names its fields, based on the official rules, in plain language.