Which allergens have to be declared?

Annex II of Regulation (EU) No 1169/2011 names 14: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites (above 10 mg/kg or 10 mg/litre), lupin and molluscs. They have to be declared regardless of quantity — with the exception of sulphites, which carry a threshold.

How do allergens have to be labelled on packaged food?

On prepacked food the allergen has to appear in the list of ingredients and be emphasised there through a typeset that clearly distinguishes it from the rest — typically bold type (Article 21). Where there is no list of ingredients, the word "contains" followed by the allergen is required instead.

How does allergen labelling work for food sold loose?

For food sold loose — a restaurant, a bakery, a counter, a market, a canteen — the 14 allergens have to be communicated. Article 44(1)(a) makes it mandatory; in Germany § 4 LMIDV allows it in writing or electronically (a menu, a notice, a folder) or orally, provided written or electronic documentation is easily accessible on request and a written notice points to that possibility.

Basics · Allergens

Allergen labelling — the duty and the 14 allergens

Q: Does "may contain traces" have to be stated?

No. "May contain traces of ..." is voluntary and refers to possible unintended entry through cross-contact. It does not replace the mandatory declaration of the allergenic ingredients actually used. The duty also covers flavourings, additives and processing aids made from an allergen.

2 July 2026 · about 8 min read

Allergen labelling is mandatory — for prepacked food just as much as in a restaurant, at a counter or in a canteen. Anyone supplying food has to inform about 14 allergens. This overview shows which they are, how they have to be declared on packaged and on loose food — and what to watch for with flavourings, additives and traces statements.

What allergen labelling is for

For people with a food allergy or intolerance, even the smallest amounts can be dangerous. The FIC Regulation (Regulation (EU) No 1169/2011) therefore requires, across the EU, that certain allergenic substances are always identifiable — whether the food sits on a shelf or goes fresh over the counter. Which substances those are is settled exhaustively by Annex II: the 14 allergens.

The 14 allergens

Annex II lists these 14 substances and groups. They have to be declared regardless of quantity — the only exception being sulphites, which carry a threshold:

No.	Allergen
1	Cereals containing gluten (wheat, rye, barley, oats …)
2	Crustaceans
3	Eggs
4	Fish
5	Peanuts
6	Soybeans
7	Milk (including lactose)
8	Nuts (almond, hazelnut, walnut, cashew …)
9	Celery
10	Mustard
11	Sesame seeds
12	Sulphur dioxide and sulphites (above 10 mg/kg or 10 mg/litre)
13	Lupin
14	Molluscs

Every single allergen, with examples, hidden occurrences and the duty to emphasise it, is covered in the 14 allergens. You can check an ingredient list against all 14 in seconds with our free allergen checker.

Prepacked food: emphasis in the list of ingredients

On prepacked food every allergen present has to appear in the list of ingredients and be emphasised there, so it clearly stands out from the rest. Article 21(1)(b) allows this “for example by means of the font, style or background colour” — in practice usually bold type, though capitals, italics or a coloured background are equally acceptable.

Wheat flour, water, sugar, hazelnuts, butter, egg.

What is emphasised is the name as listed in Annex II — “wheat”, not the whole phrase “wheat flour”. With “butter” the whole word is emphasised, because the Annex II entry is “Milk and products thereof” and the word does not itself contain “milk”. Where a product exceptionally has no list of ingredients, Article 21(1) requires the word “contains” followed by the Annex II name instead.

Loose food and food service

Allergen information is required without any packaging too — in a restaurant, a bakery, at a meat or cheese counter, at a market and in mass catering. Article 44(1)(a) makes it mandatory; Article 44(2) leaves the means to the Member States. In Germany that is § 4 LMIDV, under which the information may be given:

in writing or electronically — on a menu or price list, a notice, an allergen folder, or a digital terminal; or
orally by trained staff — but then written or electronic documentation has to be easily accessible on request, and a written notice has to point to that possibility.

What that looks like in practice is in restaurants and bakeries. How to put the allergens on a menu (letter code plus example) and how to build the whole menu have articles of their own.

Flavourings, additives and processing aids too

A point that is often missed: the duty applies equally where an allergen is not an obvious ingredient but sits processed in the product — in flavourings, additives or processing aids made from one of the 14 (lecithin from soya, whey protein from milk). Those have to be emphasised in the list of ingredients as well.

Sulphites: the allergen with a threshold

Sulphur dioxide and sulphites are the special case: they only have to be declared at concentrations of more than 10 mg/kg or 10 mg/litre as total SO₂. They sit above all in wine, dried fruit and many convenience foods. Why, and where they turn up, is in sulphites and sulphur dioxide.

“May contain traces”: voluntary, and no substitute

The statement “may contain traces of …” is voluntary. It refers to possible unintended entry through cross-contact in production — not to ingredients used deliberately. Crucially, it does not replace the mandatory declaration of the allergens actually used. Anyone using it also has to make sure it is not misleading: Article 36 subjects voluntary food information to the same fairness requirements.

Allergen labelling in practice

In practice the biggest source of error is not the theory but overlooking an allergen in a nested recipe — mustard in a bought-in sauce, celery in a spice blend. So it pays to derive the allergens automatically from the ingredients rather than maintaining them by hand. That is what Foodlex does.

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 and Articles 21, 36 and 44 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.