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Sulphur dioxide and sulphites

Sulphur dioxide and sulphites is entry 12 of the fourteen substances Annex II of Regulation (EU) No 1169/2011 makes declarable. Intolerance, not usually IgE allergy — bronchoconstriction in some people with asthma is the main concern. Where it hides, which exemptions apply, and what it cross-reacts with.

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.

What the law says

Annex II, entry 12: “Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre, expressed as total SO2, in the product as sold ready for consumption or as reconstituted”

That wording carries the whole obligation. The substance must be declared whenever it is used in the making of a food and is still present in the finished product, even in an altered form, and it must be picked out inside the ingredient list by typeset — bold, capitals, italics, underlining or a contrasting colour. There is no legal requirement for a separate allergen box, so the ingredient list is where to look.

Source: Regulation (EU) No 1169/2011, Annex II and Article 21 · checked 2026-09-06

What the reaction actually is

This is the one entry on the list that is not a food but a group of preservatives, used to stop browning and microbial spoilage. It is also the one with a threshold: it is declarable only above 10 mg/kg or 10 mg/litre expressed as total sulphur dioxide, measured in the product as it is actually consumed. Below that it can be present without appearing on the label.

Who gets it, and does it last

Most reactions are not classic IgE allergy. The best-documented problem is bronchoconstriction in a subgroup of people with asthma, sometimes within minutes of a drink or a portion of dried fruit. Other reported symptoms are flushing, headache, abdominal discomfort and rhinitis.

Where it hides

• Wine, cider and beer
• Dried apricots, raisins and other dried fruit
• Pickled vegetables and vinegar preserves
• Processed and pre-cut potato products
• Some sausages and burgers where permitted
• Fruit juices and concentrates
• Bottled lemon and lime juice

Dried fruit, pickled vegetables and processed potato are staples of the winter table across this region, and sulphites are widely used in all three. Sulphites in wine get the attention, but for someone with asthma the dried-fruit and pickle route is the one that is easy to miss.

Cross-reactions

Sulphites are a chemical group, not a biological family, so there is no cross-reactivity in the allergy sense. What matters is the total intake across everything eaten and drunk at a sitting, which is why a glass of wine with a dried-fruit dessert is a more informative test than either alone.

The labelling detail

The threshold makes this entry unusual: a low-sulphite product is legally silent about them. E-numbers E220 to E228 are the sulphiting agents, and seeing any of them in an ingredient list is the practical marker even where the wording "sulphur dioxide" does not appear.

Exemptions: none. Entry 12 has no carve-outs at all, so there is no processed fraction of it that escapes the label.

Precautionary wording — “may contain”, “made in a factory that also handles” — is a separate matter: it is voluntary, unstandardised and carries no threshold. How strictly to treat it is a clinical decision, not a reading of the label. The labelling explainer sets out the whole frame, including what happens in restaurants and bakeries where there is no pack at all.

What gets misread

Sulphites are routinely blamed for red-wine headaches. White wine generally carries more sulphite than red, which makes that explanation difficult, and the evidence points elsewhere. Sulphite sensitivity is a real and specific phenomenon, mainly respiratory, and mainly in people who already have asthma.

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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