Which animals count as molluscs?

Molluscs include mussels, oysters, scallops, clams and snails (such as vineyard snails), as well as cephalopods such as squid, calamari, cuttlefish and octopus.

Is there an allergen in oyster sauce?

Yes. Oyster sauce contains oysters and therefore the mollusc allergen — a case that is frequently overlooked in Asian cooking. It has to be declared accordingly.

Are molluscs the same allergen as fish or crustaceans?

No. Annex II lists three separate seafood allergens: molluscs (no. 14), fish (no. 4) and crustaceans (no. 2, e.g. prawns). Each has to be declared separately.

Guide · Allergens

Molluscs — allergen no. 14 under the FIC Regulation

2 July 2026 · about 5 min read

Mussels, oysters, squid, even snails — molluscs are the last of the 14 allergens (number 14) and awkwardly hidden: the oyster sauce of Asian cooking almost always contains it. And like fish and crustaceans it is an allergen in its own right — not part of a catch-all called “seafood”.

What is the molluscs allergen?

Annex II of the FIC Regulation (Regulation (EU) No 1169/2011) lists as number 14: “Molluscs and products thereof”. No exceptions are attached. Cephalopods (squid, calamari, cuttlefish, octopus) and snails are covered as well.

Three separate seafood allergens

No.	Allergen	Examples
2	Crustaceans	Prawns, shrimp, crabs, lobster, crayfish
4	Fish	Salmon, tuna, anchovies …
14	Molluscs	Mussels, oysters, squid, snails

Where molluscs hides

Obvious — mussels, oysters, scallops, clams, calamari and squid, octopus, vineyard snails.
Oyster sauce — the base of many Asian dishes, marinades and wok sauces.
Ready meals — paella, seafood mixes, fish soups and stews, antipasti salads.
Deli — filled pasta, Mediterranean starters, some stocks.

How to label molluscs correctly

In the list of ingredients on prepacked food, the ingredient has to be named (“mussels”, “squid”, “oyster 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.

Oyster sauce is the case that gets overlooked 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 advice. What counts is the wording of the regulation as it applies at the time (Annex II no. 14 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.