No. Sesame is a seed, not a tree nut. Annex II treats it as an allergen of its own (no. 11), separate from nuts (no. 8).

Where is sesame often hidden?

On burger buns and rolls, in tahini and hummus, in sesame oil (Asian cooking), halva, gomasio, falafel, muesli and bars, and in some bakery products and coatings.

Are there any exceptions for sesame?

No. Sesame seeds (Annex II no. 11 of Regulation (EU) No 1169/2011) and all products thereof — sesame oil included — must be declared, without exception.

Guide · Allergens

Sesame — allergen no. 11 under the FIC Regulation

2 July 2026 · about 5 min read

Everyone sees the sesame seeds on a burger bun — nobody sees the sesame in the oil, the coating or the hummus. Sesame is one of the 14 allergens (number 11) and is becoming more important, not less. Here is where it turns up and how to label it.

What is the sesame allergen?

Annex II of the FIC Regulation (Regulation (EU) No 1169/2011) lists as number 11: “Sesame seeds and products thereof” — with no exceptions. Sesame is a seed, not a nut, and an allergen in its own right. Sesame oil, sesame flour and sesame paste are covered as well.

Where sesame hides

Bakery — burger buns and rolls, crackers, grissini, some breads.
Pastes & dips — tahini, hummus, baba ghanoush.
Oil & Asian cooking — sesame oil, wok dishes, dressings, marinades.
Sweets & snacks — halva, sesame bars, muesli, gomasio, falafel.

How to label sesame correctly

In the list of ingredients on prepacked food, the ingredient has to be named (“sesame seeds”, “sesame oil”, “sesame paste”) 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.

Watch for sesame oil in sauces and dressings — that is where the allergen is 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 advice. What counts is the wording of the regulation as it applies at the time (Annex II no. 11 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.