Basics · Allergens
The 14 allergens that must be declared (Annex II)
Annex II of the EU Food Information Regulation (Regulation (EU) No 1169/2011) lists 14 substances and products causing allergies or intolerances. They have to be declared across the EU — on packaged food just as much as over the counter. Here is the complete list, with examples and the labelling rules.
Where do the 14 allergens come from?
The obligation follows from Article 9(1)(c): any substance or product listed in Annex II “causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form”, has to be indicated. Annex II names exactly these 14 groups.
The 14 allergens
| No. | Allergen | Includes |
|---|---|---|
| 1 | Cereals containing gluten | wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains |
| 2 | Crustaceans | prawns, crabs, lobster |
| 3 | Eggs | and products thereof |
| 4 | Fish | and products thereof |
| 5 | Peanuts | and products thereof |
| 6 | Soybeans | and products thereof |
| 7 | Milk | including lactose |
| 8 | Nuts | almonds, hazelnuts, walnuts, cashews, pecan, Brazil, pistachio, macadamia or Queensland nuts |
| 9 | Celery | and products thereof |
| 10 | Mustard | and products thereof |
| 11 | Sesame seeds | and products thereof |
| 12 | Sulphur dioxide & sulphites | at more than 10 mg/kg or 10 mg/litre as total SO₂ |
| 13 | Lupin | and products thereof |
| 14 | Molluscs | mussels, snails, squid |
Two points where mistakes happen most often: oats are expressly one of the cereals containing gluten (no. 1) and therefore one of the 14. And sulphur dioxide and sulphites (no. 12) only have to be declared above a concentration of more than 10 mg/kg or 10 mg/litre — which matters for dried fruit, wine and some convenience foods.
More on individual allergens: most of the 14 now have an article of their own — just click the highlighted allergen name in the table above. The awkward cases are the ones worth reading: cereals containing gluten and the gluten-free thresholds, nuts (and why the peanut is not one), milk (lactose-free is not milk-free) and sulphites with their concentration threshold.
Check it yourself: paste an ingredient list into the free allergen checker and see straight away which of the 14 allergens are in it — in the browser, no sign-up.
Allergens have to be emphasised
Under Article 21(1)(b) it is not enough to mention the allergen somewhere. The name “shall be emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour”. In practice that is usually bold type:
Wheat flour, water, butter, eggs, sugar, hazelnuts, salt, yeast.
What gets emphasised is the name as listed in Annex II — so “wheat”, not the whole phrase “wheat flour”. The Commission Notice 2017/C 428/01 says so directly: “When the name of an ingredient consists of several separate words …, it is sufficient to only emphasise the word that corresponds to the substance/product listed in Annex II” — and where the allergen sits inside a single word, “it is sufficient to emphasise the part of the name of the ingredient” that corresponds to it.
Butter is the interesting case, because the word does not contain “milk” at all. Article 21(1)(a) requires the indication to carry “a clear reference to the name of the substance or product as listed in Annex II”, and the same Notice treats names such as “cheese” and “cream” as ones “which clearly refer” to milk. Reading those two together — and this step is our interpretation, not something the wording settles in so many words — the whole word “butter” is what gets emphasised, and an added “(milk)” is unnecessary. A bracket in a list of ingredients normally opens the sub-list of a compound ingredient (“cheese (milk, salt, rennet)”), so adding one here can actually mislead.
The other way round, something has to be added when the Annex II name does not appear in the ingredient name at all. The Notice is explicit: “Where ‘spelt’, ‘khorasan’ or ‘durum’ is used, a clear reference to the specific type of the cereal, i.e. ‘wheat’ is required” — so “wheat (durum)” or “durum wheat”.
Where there is no list of ingredients at all, Article 21(1) second subparagraph puts the word “contains” in its place, followed by the Annex II name.
Allergens in food sold loose — counter, café, restaurant
Food that is not prepacked, at a service counter or in a restaurant, has to carry allergen information too. Article 44(1)(a) makes those particulars mandatory, and Article 44(2) leaves it to each Member State to decide “the means through which the particulars … are to be made available”.
In Germany that national measure is § 4 LMIDV. The information may be given in writing or electronically (a sign, a card, a notice) or orally (§ 4(4) LMIDV), provided written documentation exists and is accessible on request and a clearly visible notice points to it. Other Member States have their own measures under Article 44(2), so check the rules of the country you sell in. Details for Germany in allergen labelling in restaurants.
This article is general information and does not replace legal advice. What counts is the wording of the regulation as it applies at the time (Annex II of Regulation (EU) No 1169/2011). The English text of the Regulation is quoted from the consolidated version of 1 January 2018 on EUR-Lex.