Guide · Allergens
Fish — allergen no. 4 under the FIC Regulation
Fish as an allergen is obvious in a fillet or in sushi. It gets tricky with the hidden sources: Worcestershire sauce contains anchovies, so does Caesar dressing. At the same time fish comes with a couple of exceptions. Here is where fish turns up, when it does not have to be declared, and why fish, crustaceans and molluscs are three different allergens.
What is the fish allergen?
Annex II of the FIC Regulation (Regulation (EU) No 1169/2011) lists as number 4: “Fish and products thereof”. All species of fish are covered. The species itself does not have to be named for allergen purposes — “fish” is enough, naming the particular kind is voluntary.
Three separate seafood allergens
An important distinction: fish is not the same as crustaceans or molluscs. Annex II lists three separate seafood allergens:
| No. | Allergen | Examples |
|---|---|---|
| 2 | Crustaceans | Prawns, crabs, lobster, spiny lobster |
| 4 | Fish | Salmon, tuna, cod, anchovies … |
| 14 | Molluscs | Mussels, oysters, squid, snails |
Where fish hides
- Obvious — fish fillet, sushi, smoked fish, tinned tuna, fish fingers, caviar and roe.
- Worcestershire sauce — classically contains anchovies. It turns up in dressings, marinades and cocktails.
- Caesar dressing — usually contains anchovies.
- Fish sauce (nam pla) — the base of many Asian dishes, curry pastes and dips.
- Other — surimi, fish stock and soup, tapenade, some pizza toppings (anchovies), deli salads.
Diagram: Foodlex. Regulation (EU) No 1169/2011, Annex II. Examples from practice.
The exceptions: fish gelatine and isinglass
Annex II no. 4 attaches two express exceptions, for highly processed products:
| Excepted | Wording in Annex II |
|---|---|
| Fish gelatine | “used as carrier for vitamin or carotenoid preparations” |
| Fish gelatine or isinglass | “used as fining agent in beer and wine” |
In practice: a beer or a wine fined with isinglass does not have to be labelled as fish. Where fish gelatine is used as an ordinary ingredient, however — in desserts or gummy sweets, say — the exception does not apply and it has to be declared.
How to label fish correctly
In the list of ingredients on prepacked food, the ingredient has to be named (“fish”, “anchovies”, “fish sauce”) 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.
With compound ingredients such as Worcestershire sauce it is worth reading the supplier specification closely. 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
Does Worcestershire sauce contain fish?
Classic Worcestershire sauce contains anchovies and therefore fish — a frequently overlooked case. Caesar dressing, fish sauce (nam pla) and some soups also bring fish in as a hidden ingredient.
Does beer or wine fined with isinglass have to be labelled as fish?
No. Fish gelatine or isinglass used as a fining agent in beer and wine is expressly excepted in Annex II no. 4 — as is fish gelatine used as a carrier for vitamin or carotenoid preparations.
Is fish the same allergen as crustaceans or mussels?
No. Annex II lists three separate seafood allergens: fish (no. 4), crustaceans (no. 2, e.g. prawns) and molluscs (no. 14, e.g. mussels and squid). Each has to be declared separately.
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. 4 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).