Guide · Allergens

Eggs — allergen no. 3 under the FIC Regulation

2 July 2026 · about 5 min read

Egg is in far more products than scrambled egg — as a binder, an emulsifier, even as a preservative (lysozyme) in cheese and wine. And unlike soya or sulphites it has no exceptions. Here is where egg turns up and how to label it.

What is the eggs allergen?

Annex II of the FIC Regulation (Regulation (EU) No 1169/2011) lists as number 3: “Eggs and products thereof”. No exceptions are attached. What is meant is the hen’s egg with all its parts — egg white (with the main allergens ovalbumin, ovomucoid and lysozyme) and egg yolk. Every egg product has to be declared.

The tricky case: lysozyme (E1105) in cheese and wine

Lysozyme is an enzyme obtained from egg white and used as a preservative (E1105) — for instance to stop unwanted secondary fermentation in some hard cheeses, or to stabilise wine. Because it comes from egg, it counts as the egg allergen and has to be declared — usually as “lysozyme (from egg)” or “egg albumin”. A cheese or a wine “with egg” surprises many people — but this is exactly that case.

Where eggs hides

• Obvious — scrambled egg, omelette, poached or boiled egg, egg pasta.
• As a binder or emulsifier — mayonnaise, aioli, hollandaise and béarnaise, custards, fillings.
• Bakery & sweets — cakes, meringue, egg liqueur, many doughs; as an egg wash on pastries.
• Savoury dishes — coatings (breaded escalope), meatballs, dumplings, quiche, some pasta sauces.
• Ice cream — especially the creamy kind made on an egg-yolk base.

How to label eggs correctly

In the list of ingredients on prepacked food, the ingredient has to be named (“egg”, “egg protein”, “lysozyme (from egg)”) and the Annex II name has to be emphasised. Article 21(1)(b) puts it like this: 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 almost always bold type.

This also covers the cases that are not obvious — lysozyme in cheese, egg in a coating. For food sold without prepackaging, Article 44(1)(a) makes the allergen particulars mandatory, while 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; see allergen labelling in restaurants and how to write a menu.

Frequently asked questions

Which products contain egg?

Obviously scrambled egg, omelette and egg pasta — but also hidden as a binder or emulsifier in mayonnaise, sauces (hollandaise, béarnaise, aioli), bakery products, coatings, meringue, custards, ice cream and glazes. Also as lysozyme (E1105) from egg white in some cheeses and wines.

Is lysozyme an egg allergen?

Yes, where it is obtained from egg white (E1105). Lysozyme is used as a preservative and has to be declared as the egg allergen — usually as "lysozyme (from egg)" or "egg albumin".

Are there exceptions for egg, as there are for soya or sulphites?

No. Unlike soybeans (fully refined oil is excepted) or sulphur dioxide and sulphites (a concentration threshold), Annex II no. 3 attaches no exception to eggs — every egg product has to be declared.

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 no. 3 of Regulation (EU) No 1169/2011). The English text of the Regulation is quoted from the consolidated version of 1 April 2025 on EUR-Lex (CELEX 02011R1169-20250401).