Guide · Allergens
Lupin — allergen no. 13 under the FIC Regulation
Hardly anyone thinks of lupin as an allergen — yet lupin flour goes into more and more bakery, gluten-free and vegan products. As one of the 14 allergens (number 13) it must be declared, and because it is related to the peanut it matters especially to people with allergies.
What is the lupin allergen?
Annex II of the FIC Regulation (Regulation (EU) No 1169/2011) lists as number 13: “Lupin and products thereof”. No exceptions are attached. The lupin is a legume; it is processed above all into lupin flour, lupin concentrate and lupin protein.
Cross-reactivity with peanut
Because lupin and the peanut are botanically both legumes, a cross-reaction can occur: people with a peanut allergy sometimes react to lupin as well. That makes clean labelling particularly important — precisely because lupin turns up where it is not expected.
Where lupin hides
- Bakery — lupin flour as a whitening agent or egg replacer in bread, rolls and pastries.
- Gluten-free products — as a protein or flour component.
- Vegan alternatives — lupin-based meat and milk substitutes, spreads.
- Other — lupin coffee, protein bars, some pasta.
How to label lupin correctly
In the list of ingredients on prepacked food, the ingredient has to be named (“lupin”, “lupin flour”, “lupin protein”) 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.
Lupin flour in bakery products is the case that gets missed most often. 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.
This article is general information and does not replace legal or medical advice. What counts is the wording of the regulation as it applies at the time (Annex II no. 13 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.