Food Information Regulations GB: A Brief Look at Allergen Labelling Requirements

Food Information Regulations UK attempt to give a level playing field to manufacturers and retailers, while informing consumers of the characteristics of the product that might inform their purchasing decision.  

A very important part of Food Information Regulations is Allergen Labelling; correctly displaying allergens is integral to the safety of consumers. There are currently 14 major allergens in the UK, and when present as an ingredient, derivative or trace content, they must be stated clearly on a food label. (Although on menus they can be provided in a variety of ways, including orally). 

The 14 allergens in the UK and EU currently include: 

• Celery 

• Cereals containing gluten 

• Crustaceans 

• Eggs 

• Fish 

• Lupin 

• Milk 

• Molluscs 

• Mustard 

• Nuts 

• Peanuts 

• Sesame seeds 

• Soya 

• Sulphur dioxide  

This is not an exhaustive list of allergens; there are other foodstuffs that may cause a reaction. However, in the EU, current food law only requires these 14 allergens to be emphasised as they are considered the most problematic for consumers within the EU member states. The UK adopted these allergen laws after transition and, at least for the meantime, they remain aligned with the EU.    

Requirements for Allergen Labelling UK

1. Allergens must be emphasised in your ingredients list by using bold type, capital letters, contrasting colours or underlined text. This must be clear enough for the consumer to read. 

2. Precautionary allergen labelling (PAL) is used to advise of any potential cross contamination along the supply chain (from farm to fork) based on risk analysis. A legal obligation exists for food business operators to ensure that the food which is offered for sale to consumers is safe. PAL is therefore relevant to ensure that safe food is offered to consumers and achieve the high level of consumer protection required by the Regulation.

3. Be prepared for changes in allergen declaration for food prepacked for direct sale – which now take on a similar approach to prepacked products.

4.  Be familiar with the definitions of prepacked and prepacked for direct sale. 

5. Be aware of using new ingredients or adopting recipes to e.g., ‘plant based’ thereby unwittingly introducing allergens.

Challenges of Allergen Labelling Requirements  

While Allergen requirements are seemingly simple to apply, in reality, the uniqueness of a product and the journey it’s ingredients go on can make it more difficult. Incorrect labelling or poor traceability leading to missed disclosure of allergens is still a major cause of recall, enforcement action and cost to business – not to mention consumer safety. According to the Food Standards Agency, there were 8 product recalls across the UK in June 2021 alone related to incorrect allergen labelling and an even higher number of 15 in May 2021.  

Cross-contamination is a major challenge with it comes to allergen labelling, as well as the control of allergens along the supply chain and the provision of allergen information to consumers for different kinds of foodstuffs – such as prepacked or prepacked for direct sale (a challenge which the recent ‘Natasha’s Law’ aims to mitigate). Allergen labelling requirements are at the end of much broader food safety framework that starts at the beginning of the supply chain. Businesses have the challenge of building and adhering to strict sourcing and manufacturing procedures, including testing, cleaning and technology, to support allergen management and ultimately ensure what results on the end label is correct.

Allergen legislation is just a single piece of the puzzle that makes up food information regulations. There is lots to consider when creating food packaging; if you are unsure of your compliance needs, our experts are here to offer advice and guidance.