Allergen Labeling Checklist: Stay Compliant

Why Allergen Errors Cost More Than You Think

Allergen labelling mistakes aren't just a regulatory problem — they're a safety issue. An undeclared allergen can put a consumer's life at risk. It can also cost your business everything: a product recall, legal liability, and a brand association with harm that's almost impossible to recover from.

The good news: allergen compliance is straightforward once you know what to check. This checklist walks through every step, from formulation to final print.

The 14 Allergens You Must Declare

EU Regulation 1169/2011 requires declaration and emphasis for these 14 allergen groups whenever they're present as ingredients or processing aids:

• 🌾 Cereals containing gluten — wheat, rye, barley, oats, spelt, kamut, and their hybrids
• 🦐 Crustaceans — prawns, lobster, crab, crayfish
• 🥚 Eggs — and products thereof
• 🐟 Fish — and products thereof
• 🥜 Peanuts — and products thereof
• 🫘 Soybeans — and products thereof
• 🥛 Milk — including lactose, and dairy products
• 🌰 Nuts — almonds, hazelnuts, walnuts, cashews, pecans, Brazils, pistachios, macadamias
• 🥗 Celery — and products thereof
• 🌭 Mustard — and products thereof
• 🌿 Sesame seeds — and products thereof
• 🍷 Sulphur dioxide and sulphites — at concentrations above 10mg/kg or 10mg/litre
• 🌸 Lupin — flour and products thereof
• 🐚 Molluscs — mussels, oysters, squid, snails

Pre-Formulation Checklist

Before you finalise your recipe:

• ☐ Have you obtained full ingredient specifications from your suppliers, including allergen declarations?
• ☐ Have you identified every allergen present — including those in compound ingredients (e.g. a sauce containing fish)?
• ☐ Do any of your ingredients contain allergens as processing aids (e.g. wheat starch used as a carrier for a flavouring)?
• ☐ Have you considered cross-contamination risk at your production facility?
• ☐ Have you documented your allergen assessment in writing?

Ingredient List Checklist

When building your ingredient list:

• ☐ Are ingredients listed in descending order by weight at time of manufacture?
• ☐ Is every allergen emphasised — bold, italic, underlined, or different colour — so it stands out from the rest of the text?
• ☐ Are compound ingredients (e.g. "chocolate (cocoa mass, sugar, milk solids)") listed with their own sub-ingredients, with allergens highlighted within?
• ☐ Are allergen-containing additives and processing aids included?
• ☐ Is the emphasis consistent across all allergens on the label (don't bold some and italicise others without clear reason)?

Use NutriLabel's allergen-aware label generator to automatically flag and emphasise allergens in your ingredient list as you build it.

Advisory "May Contain" Statements

Advisory statements like "May contain traces of nuts" are voluntary and must not replace mandatory declarations. Rules for using them correctly:

• ☐ Only use advisory statements where there is a real, assessed risk of cross-contamination — not as a blanket disclaimer.
• ☐ Conduct and document a formal cross-contamination risk assessment.
• ☐ Do not use advisory statements for allergens that are deliberately added ingredients — those must be in the ingredient list.
• ☐ Phrase advisory statements precisely: "May contain wheat" rather than vague terms like "made in a facility with allergens."
• ☐ Ensure advisory statements are consistent with your HACCP documentation.

Label Layout and Legibility Checklist

• ☐ Is the allergen emphasis visually obvious? Print a test copy and check at arm's length.
• ☐ Is the minimum x-height for allergen text at least 1.2mm (0.9mm for very small packs)?
• ☐ Does the emphasis remain visible on coloured or patterned backgrounds?
• ☐ Is the ingredient list and allergen information on the same panel, or at least clearly sign-posted?

Post-Production Verification

Before product goes to shelf:

• ☐ Has someone other than the label designer reviewed the final print for allergen accuracy?
• ☐ Does the printed label match the approved proof?
• ☐ Have you filed the signed-off label against your product specification for traceability?
• ☐ If your recipe changes (even slightly), has the label been re-reviewed for allergen impact?

Catering and Loose Foods

If you sell loose or unpackaged food (e.g. at a market, in a restaurant, or as a caterer), EU rules still require you to provide allergen information — verbally, on a menu, or via a written notice. The same 14 allergens apply. You do not need a full nutrition declaration for loose food, but allergen information is non-negotiable.

Build Your Compliant Label Now

Running through this checklist manually every time is time-consuming. NutriLabel's label generator integrates allergen management into the label-building process — automatically highlighting allergens, flagging cross-contamination risks, and generating compliant ingredient lists.

Stop guessing, start complying. Create your first allergen-compliant label free at NutriLabel.io →