EU Allergen Labeling: The Complete Guide (14 Allergens)

EU Allergen Labeling: The Complete Guide

Undeclared allergens are the number-one cause of food recalls in the European Union. In the Netherlands, NVWA regularly issues public warnings for food products with missing or incorrect allergen information.

This guide covers every EU allergen requirement — the 14 mandatory allergens, how to declare them, and what the most common mistakes look like.

The 14 EU Mandatory Allergens

EU Regulation 1169/2011 Annex II lists the following 14 substances and products causing allergies or intolerances that must always be declared on food labels:

#	Allergen	Common Sources
1	Cereals containing gluten	Wheat, rye, barley, oats, spelt, kamut
2	Crustaceans	Shrimp, crab, lobster, crayfish
3	Eggs	Egg, egg white, egg yolk, egg powder, mayonnaise
4	Fish	Any fish species, fish sauce, fish paste, Worcester sauce
5	Peanuts	Peanut butter, peanut oil, groundnuts
6	Soybeans	Soy sauce, tofu, tempeh, edamame, miso
7	Milk	Milk, butter, cream, cheese, yogurt, casein, whey, lactose
8	Tree nuts	Almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia
9	Celery	Celery sticks, celery seeds, celeriac, many stock cubes and soups
10	Mustard	Mustard seeds, mustard powder, mustard leaves
11	Sesame	Sesame seeds, tahini, sesame oil, hummus
12	Sulphur dioxide & sulphites	Wine, dried fruits, vinegar, many preservatives (if >10mg/kg or >10mg/litre)
13	Lupin	Lupin flour (popular in gluten-free baking), lupin seeds
14	Molluscs	Squid, octopus, cuttlefish, clams, oysters, scallops

The 5 Allergens US Businesses Miss

If you're expanding into the EU market from the US — or if you use US FDA compliance templates — your allergen list is missing 5 items. The EU requires 14 allergens vs. the FDA's 9. The 5 extra:

• Celery — Extremely common in European soups, stocks, and sauces
• Mustard — Common in condiments, dressings, many Dutch products
• Sesame — Tahini, hummus, sesame buns
• Lupin — Increasingly used in gluten-free and high-protein products
• Molluscs — Calamari, oyster sauce, scallops

How to Declare Allergens: The Exact Rules

Rule 1: In the ingredient list — not just a "Contains" box

Some businesses put a "Contains: gluten, milk, eggs" statement at the bottom of their label. This is NOT sufficient on its own. The allergens must also be differentiated within the ingredient list itself.

Rule 2: Visual differentiation — must stand out from surrounding text

Allergens must be highlighted using bold, italic, uppercase, different font, or different color. The key: they must visually stand out from non-allergen ingredients.

Compliant example: Ingredients: water, WHEAT flour, vegetable oil, MILK powder, SESAME seeds, salt, MUSTARD extract

"May Contain" Statements

"May contain traces of [allergen]" statements are voluntary — not required by EU law. However, they're strongly recommended when you process multiple products on shared equipment or there is a realistic risk of cross-contamination.

Important: "May contain" cannot replace proper allergen declaration. If an allergen is intentionally in your recipe, it must be in the ingredient list with visual differentiation.

Hidden Allergens in Common Catering Ingredients

Many food businesses are meticulous about the allergens they consciously add, but miss the ones hidden in compound ingredients:

• Stock cubes → often contain celery, mustard
• Soy sauce → contains wheat (gluten)
• Worcester sauce → often contains fish (anchovies)
• Seasoning mixes → may contain mustard, celery
• Chocolate chips → usually contain milk, may contain tree nuts
• Pesto → often contains tree nuts and/or milk

How NutriLabel.io Handles Allergen Detection

NutriLabel.io automatically detects all 14 EU allergens from your ingredient list and generates a label with allergens highlighted in bold in the ingredient list, plus an allergen summary box. No missed allergens — the system checks all ingredients against all 14 allergen categories.

Free for 10 labels/month. Start at nutrilabel.io/generate.