Allergen labelling in online stores: the 14 allergens under EU law
Allergens are the particular where mistakes matter most. The EU Food Information Regulation lists 14 substances that must always be declared and sets out how to emphasise them in the list of ingredients. Online, this applies before purchase.
Last updated: · ZutatenKlar by SyncVentura
At a glance
- The 14 substances in Annex II must be declared if they are present in the finished product, even in an altered form (Article 9(1)(c) FIC).
- In the list of ingredients, they must be emphasised, for example by font, style or background colour (Article 21(1)).
- Without a list of ingredients, the word “contains” precedes the name from Annex II.
- “May contain traces” is voluntary information and must not be misleading, ambiguous or confusing (Article 36(2)).
The 14 allergens in Annex II
Annex II FIC lists the substances or products causing allergies or intolerances, each including products thereof:
| Allergen | Exceptions (selection) |
|---|---|
| 1. Cereals containing gluten: wheat (such as spelt and khorasan wheat), rye, barley, oats | wheat- and barley-based glucose syrups, wheat-based maltodextrins |
| 2. Crustaceans | – |
| 3. Eggs | – |
| 4. Fish | fish gelatine used as a carrier or as a fining agent in beer and wine |
| 5. Peanuts | – |
| 6. Soybeans | fully refined soybean oil and fat |
| 7. Milk (including lactose) | lactitol |
| 8. Nuts: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts | nuts used for making alcoholic distillates |
| 9. Celery | – |
| 10. Mustard | behenic acid (at least 85% purity) used to make the emulsifiers E 470a, E 471 and E 477 |
| 11. Sesame seeds | – |
| 12. Sulphur dioxide and sulphites | only at concentrations of more than 10 mg/kg or 10 mg/litre |
| 13. Lupin | – |
| 14. Molluscs | – |
Coconut and nutmeg are not nuts within the meaning of Annex II; peanuts have their own entry.
Emphasis in the list of ingredients
Under Article 21(1) FIC, allergens
- are indicated in the list of ingredients “with a clear reference to the name of the substance or product as listed in Annex II” (point (a)), and
- are “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” (point (b)).
| List of ingredients | Why |
|---|---|
| Ingredients: wheat flour, sugar, butter, hazelnuts (8%) | Allergens in bold, name recognisable |
| Ingredients: … whey powder (milk) … | “Whey” alone does not state the name from Annex II |
| Ingredients: … soy lecithin, soy protein … | If several ingredients come from one allergen, each one is labelled |
The indication is not required where the name of the food clearly refers to the allergen (Article 21(1), fourth subparagraph).
Without a list of ingredients: “contains”
Some foods need no list of ingredients – for example under Article 19 or beverages above 1.2% vol (Article 16(4)). Allergens must still be declared: “In the absence of a list of ingredients, the indication … shall comprise the word ‘contains’ followed by the name of the substance or product as listed in Annex II” (Article 21(1), second subparagraph).
The name follows Annex II, for example “Contains: milk”.
“May contain traces”
Statements on the possible and unintentional presence of allergens – such as “may contain traces of peanuts” – are not required by the FIC. They are voluntary information and must then meet Article 36(2): not misleading, not ambiguous or confusing and, where appropriate, based on relevant scientific data. Article 36(3)(a) provides for implementing acts on this.
If a precautionary statement is on the packaging, it belongs on the product page too – customers with allergies look for exactly that.
Allergens in online stores
Allergens are among the mandatory particulars that must be available before the purchase is concluded in distance selling (Article 14(1)(a)). This also applies to non-prepacked food: there, allergens are mandatory even where other particulars are not (Article 44(1)(a) in conjunction with Article 14(2)).
Which other particulars must appear before purchase is covered in the guide mandatory food information in online stores.
Emphasising allergens in Shopify
In the product description, you can set allergens in bold by hand. With many products, a fixed routine helps:
- Copy the list of ingredients from the packaging
Word for word, with percentages.
- Emphasise every allergen
Also where it is part of an ingredient name, such as “wheat flour” or “skimmed milk powder” – but not in “coconut milk” or “buckwheat”.
- Add the precautionary statement
If it is on the packaging, word for word.
- Follow up recipe changes
Check new stock against the product page before selling it.
Sources
This guide gives a general overview as of the date shown and is not legal advice. The wording of the regulations is authoritative; individual cases may require advice from a lawyer or the competent authority.