EU Food Allergen Labelling Requirements for Manufacturers

Allergen labelling in the EU sits within the general food information rules for consumers, which set out what information must appear on food labels and how. Within that framework, a specific list of substances is identified as allergens that must always be declared when present.

Because the EU rules apply across member states, the core requirements are the same everywhere in the EU. National rules can still add details, especially for food that isn't sold prepacked, so check the countries you sell into.

The EU list covers 14 groups of allergens:

1. Cereals containing gluten (such as wheat, rye, barley and oats) and products made from them

2. Crustaceans

3. Eggs

4. Fish

5. Peanuts

6. Soybeans

7. Milk, including lactose

8. Tree nuts (such as almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia nuts)

9. Celery

10. Mustard

11. Sesame seeds

12. Sulphur dioxide and sulphites, above a set concentration

13. Lupin

14. Molluscs

Two details matter in practice. First, the list covers products derived from these substances, not only the raw ingredient. Second, a small number of specific derived ingredients are exempt from declaration under defined conditions. Check the current legal text for the exemptions before relying on them, and don't assume an exemption applies without confirming it covers your exact ingredient and processing.

Declaring an allergen isn't only about including it. The way it appears matters.

Emphasis in the ingredient list. For prepacked food with an ingredient list, each allergen must be emphasised so it stands out from the rest of the list, for example through bold type, italics, capitals, underlining or a contrasting background. Whichever method you choose, apply it consistently.

No ingredient list. Where a product has no ingredient list, the allergen must be shown with the word "contains" followed by the name of the allergen.

Naming the allergen clearly. The declaration should make clear which allergen is involved. For compound ingredients, the allergens within them still need to be shown.

Legibility. Mandatory information, including allergens, must be easy to see and read, and there are minimum text size requirements, with smaller allowances for very small packs. Check the current requirements when designing packaging.

Language. Information must be provided in a language easily understood by consumers in the country of sale, so multi-market packs need to consider each market's language requirements.

This is the area that causes the most confusion. In the EU, precautionary allergen labelling, the "may contain" or "traces of" type of statement, isn't governed by a harmonised EU rule setting when it must be used or what thresholds apply. Such statements are voluntary, and the general rule that food information must not be misleading still applies.

In practice, that means:

• Base any precautionary statement on a documented assessment of real cross-contact risk, not as an automatic disclaimer.

• Avoid using it as a substitute for good allergen control. The statement shouldn't be used to cover avoidable contamination.

• Keep the wording consistent, because overuse makes the statements meaningless for consumers with allergies.

• Check national guidance and customer requirements, which can be stricter than the law.

1. Control ingredient information. Keep up-to-date specifications for every ingredient, including compound ingredients, additives, flavourings and processing aids. Allergens often arrive hidden inside these.

2. Map allergens to every recipe. For each product, record which of the 14 allergens it contains, including through derivatives, and keep that map current.

3. Assess cross-contact risk. Review shared lines, equipment, handling and storage, and document the findings. This assessment drives any precautionary statement and your cleaning and scheduling controls.

4. Standardise label wording and formatting. Use consistent templates for ingredient lists, emphasis and "contains" statements, so every label follows the same approach.

5. Review every label before print. Have a named person check the final artwork against the recipe map and the market's requirements. Many allergen errors come from artwork that wasn't updated after a recipe change.

6. Control change. Make any change to an ingredient, supplier or recipe trigger an allergen review before it goes ahead.

7. Check each market's language and format needs. Don't assume a label that works in one EU country works unchanged in another.

8. Keep records. Hold the recipe map, supplier information, assessments and label approvals together so you can show them if asked.

You can adapt the structure in ourproduct safety compliance checklist article to create an allergen-specific version.

Missing hidden allergens. Allergens in compound ingredients or processing aids are easy to overlook.

Forgetting to update artwork after recipe changes. This is a leading cause of errors.

Inconsistent emphasis. Using different methods within one list, or emphasising only some allergens.

Using "may contain" as a cover-all. It isn't a substitute for control, and it can mislead.

Assuming exemptions apply. Confirm them against the legal text for your exact ingredient.

Ignoring non-prepacked and online channels. Requirements apply there too.

Making unsupported free-from claims. Claims need controls that make them true.

Start by building a reliable recipe-to-allergen map and a label review step. Those two controls prevent most errors. Training your whole team on the basics means fewer mistakes slip through.

Build your labelling foundation withIntroduction to Food Labelling Compliance, Part 1, the first course in our two-part labelling series.