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How EU allergen labelling actually works

Every packaged food sold in the EU has to tell you about fourteen substances. What the law demands, and what it deliberately leaves out, are both worth knowing before you rely on a label.

This is reference information, not a diagnosis and not a treatment plan. A pollen calendar cannot tell you what you are allergic to, and no page can clear a food as safe for you — only the label on the packet in your hand and the clinician who knows your history can do that. Anything beyond mild, short-lived symptoms in the mouth or nose — swelling that affects breathing or swallowing, hives away from the mouth, wheeze, vomiting or faintness — is an emergency question, not a reading question.

The rule in one sentence

Regulation (EU) No 1169/2011 on the provision of food information to consumers — usually called the FIC Regulation — requires any of the fourteen substances in its Annex II to be declared whenever it is used as an ingredient or a processing aid and is still present in the finished food, even in an altered form.

The list is closed. It has fourteen entries and only fourteen, and a food that upsets you but is not on it carries no special labelling duty. That is a legal boundary, not a medical one.

Emphasis, not a separate box

The Regulation does not require an "allergens" panel. It requires the allergen to be emphasised inside the ingredient list, distinguished from the rest by typeset — bold, capitals, italics, underlining or a contrasting colour. So the place to look is the ingredient list itself, where the word will be picked out.

A separate "contains" statement is common, but it is a manufacturer's addition. Where a food has no ingredient list at all, the allergen still has to be stated using the word "contains".

The exemptions

Some highly processed derivatives are named in Annex II as exempt because the protein has effectively been removed. Wheat-based glucose syrups and maltodextrins are exempt, as are glucose syrups based on barley, and cereals used to make distilled alcohol. Fully refined soybean oil and fat are exempt, along with soy-derived tocopherols, phytosterols and plant stanol esters. Fish gelatine used as a vitamin carrier or as a fining agent in beer and wine is exempt. Whey used for distilled alcohol and lactitol are exempt, and so are nuts used for distilled alcohol.

One entry has a threshold rather than an exemption: sulphur dioxide and sulphites are declarable only above 10 mg/kg or 10 mg/litre expressed as total SO2 in the product as consumed.

"May contain" is not a legal grade

Precautionary allergen labelling — "may contain traces of", "made in a factory that also handles" — is voluntary in EU law. It is not standardised, there is no threshold behind it, and its absence does not mean cross-contact is impossible. Two products with identical real risk can carry different wording, or none.

This is the single biggest gap between what people assume a label means and what it means. Clinical advice on how strictly to treat precautionary wording is individual, and it is a conversation with the allergist rather than a rule that can be printed.

Restaurants, bakeries and market stalls

Food sold without packaging is covered by Article 44 of the same Regulation: the allergen information must be provided, but each member state decides how — written on a menu, on a board, or given verbally by trained staff on request. Estonia, Finland, Latvia, Lithuania, Sweden, Norway and Denmark have each set their own national arrangements within that frame.

The practical consequence is that the answer in a restaurant is a person, not a document. Ask about the specific dish, ask whether the sauce or the stock contains it, and ask before ordering rather than after.

Where the law stops

The Regulation governs information. It says nothing about how a kitchen is organised, it sets no cleaning standard for a shared fryer, and it does not require a manufacturer to test for cross-contact. A correct label on a food that has been in contact with an allergen is still a correct label.

It also has nothing to say about severity. The fourteen entries are there because they are common causes of allergy and intolerance in Europe, not because a reaction to them is more dangerous than a reaction to something else.

The fourteen entries in order

Sources: Regulation (EU) No 1169/2011, Annex II · Commission Implementing Regulation (EU) No 828/2014 (gluten claims) · WHO/IUIS Allergen Nomenclature · season windows from the national aerobiology monitoring programmes of Estonia, Finland, Sweden, Denmark and Norway · cross-reaction patterns paraphrased from the allergy literature and EAACI material · checked 2026-09-06

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