Allergens on food labels: the 14 mandatory allergens and how to emphasise them
The 14 allergens to declare under Regulation (EU) 1169/2011, how to emphasise them in the list of ingredients and when to use "Contains" and "May contain".
Allergens are the most sensitive information on a food label: a mistake can make an allergic person ill, and it is among the irregularities most often found in inspections. The rules are in Article 21 and Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers.
The 14 mandatory allergens
Annex II lists the substances causing allergies or intolerances that must always be declared, together with the products made from them:
- cereals containing gluten: wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains;
- crustaceans;
- eggs;
- fish;
- peanuts;
- soybeans;
- milk, including lactose;
- nuts: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts;
- celery;
- mustard;
- sesame seeds;
- sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of total SO₂;
- lupin;
- molluscs.
For some derived products Annex II lists express exclusions (for example certain wheat-based glucose syrups): if you use one of these ingredients, check the text of the annex.
How to emphasise them in the list of ingredients
The allergen is shown in the list of ingredients, with a typeset that clearly distinguishes it from the rest: a different font, style (for example bold or capitals) or background colour (Article 21(1)).
The emphasis goes on the name of the allergen, wherever it appears:
Ingredients: type 00 wheat flour, extra virgin olive oil (9.5%), water, brewer's yeast, salt, rosemary (1.4%).
If the same allergen comes from several ingredients, it must be emphasised in each of them. When a compound ingredient, such as a chocolate or a filling, contains allergens, the emphasis also applies inside its list in brackets.
When to use "Contains"
If the food has no list of ingredients, allergens are shown with the word "Contains" followed by the name of the substance (Article 21(1)(b)). This is not needed when the name of the food clearly refers to the allergen.
Even when there is a list of ingredients, many producers add a "Contains" line summarising the allergens: it is extra information, useful to the consumer, but it does not replace the emphasis in the list.
"May contain traces of"
The statement for accidental contamination, such as "May contain traces of nuts", is voluntary information. It must meet the requirements of Article 36: it must not mislead, must not be ambiguous or confusing and must be based, where appropriate, on the relevant scientific data. In practice:
- use it after assessing the risk of contamination in the plant or from suppliers, not out of general caution;
- keep it separate from the list of ingredients;
- do not name an allergen that is already an ingredient of the product.
The most common mistakes
- Emphasising the whole ingredient instead of the allergen: in "wheat flour" the allergen is wheat.
- Forgetting allergens inside compound ingredients or intermediate products.
- Using "May contain" instead of declaring an allergen that is in the recipe.
- Not updating the label when a supplier changes, and with it the specification of an ingredient.
How Etichettalo handles them
In Etichettalo allergens are set once on the ingredient: the platform also recognises them from the name, carries them into the products and intermediate products that use it and emphasises them in the list of ingredients in the style you choose. The "Contains" line and the traces are generated from the same data, so they never conflict with the recipe. The manual explains how to set them up; for a complete label start from how to make a food label.