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List of allergens that must be declared

By Yumiq

List of allergens that must be declared

Which allergens must appear on the packaging, how to identify them in the ingredient list, and what does the phrase 'may contain traces' mean.

The 14 allergens that must be declared

In the European Union, the list of substances that must be indicated is set out in Annex II of Regulation EU No 1169/2011, known as the INCO Regulation. It includes 14 families, along with their derivatives:

  • the cereals containing gluten: wheat, rye, barley, oats and their hybridised strains. Exceptions: certain glucose and dextrose syrups based on wheat, maltodextrins based on wheat, glucose syrups based on barley, and cereals used for alcoholic distillates;
  • the crustaceans;
  • the eggs;
  • the fish. Exceptions: fish gelatine used as a carrier for vitamin or carotenoid preparations, and fish gelatine or isinglass used as a clarifying agent in beer and wine;
  • the peanuts;
  • the soybeans. Exceptions: fully refined soybean oil and fat, certain natural tocopherols, phytosterols and phytosterol esters derived from soybean vegetable oils, and phytostanol esters based on sterols from soybeans;
  • the milk, including lactose. Exceptions: whey used for alcoholic distillates, and lactitol;
  • the nuts: almonds, hazelnuts, walnuts, cashew nuts, pecan nuts, Brazil nuts, pistachios and macadamia nuts. Exception: nuts used for alcoholic distillates;
  • the celery;
  • the mustard;
  • the sesame seeds;
  • the sulphur dioxide and sulphites, at concentrations above 10 mg/kg or 10 mg/litre expressed as total SO2;
  • the lupin;
  • the molluscs.

The regulation specifies that the derivatives mentioned are only concerned if their processing is not likely to increase the level of allergenicity assessed for the starting product. The above exceptions are specific cases: a product containing, for example, fully refined soybean oil does not have to indicate soy for this reason.

Two useful points to read. First, the list is the same for all food products sold in the Union, which makes it possible to find it regardless of the country of purchase, even if the words used on the packaging are those of the product's language. Secondly, the threshold of 10 mg/kg or 10 mg/litre for sulphites means that below this level, their presence does not have to be indicated as an allergen, even if they may be listed among the additives.

How to identify them in the list of ingredients

For a pre-packaged product, Article 21 of the Regulation requires that each allergen be listed in the list of ingredients, under the name provided in Annex II, and be highlighted in relation to the rest of the list: by the font, style or background colour. In practice, you will see it in bold, in capital letters, underlined or highlighted, depending on the brand.

  • If several ingredients or technological aids come from the same allergen, the label must make this clear.
  • If there is no list of ingredients, the allergen is indicated by the words 'contains', followed by its name.
  • The indication is not required when the trade name already clearly indicates the allergen, as in the case of 'cheese' or 'rye bread'.

Allergens must therefore be read in the list of ingredients itself. For the rest of the label, see our guide to reading a label properly.

Non-prepackaged products: catering, bakery

The obligation does not stop at packaged products. The European regulation provides that for non-prepackaged foodstuffs (bulk, bakery, restaurant), information on allergens remains compulsory, while Member States decide on the form in which it is provided.

In France, Decree No. 2015-447 of 17 April 2015, applicable since 1 July 2015, sets this framework. The information must be provided in writing, in a legible and visible manner, for example on a menu, a board, a notebook or a screen. The arrangements vary according to the establishment. According to the sante.fr fact sheet relayed by the DGCCRF, a display is not compulsory when a system allows an allergic person to indicate that they refuse an allergen. This information must correspond to the recipe, not to accidental contamination.

Caterers and craftsmen must also, according to the DGCCRF, distinguish between allergens present in recipes and those resulting from cross-contamination. Its investigations have revealed frequent confusion between the two among some professionals. For you, the consequence is simple: do not hesitate to ask the establishment questions, and specify that you are looking for information on both the recipe and the risks of contact.

Allergy or intolerance: two different things

A food allergy is an abnormal reaction of the immune system after ingestion of a food, with symptoms that generally appear rapidly. An intoleranceThis does not go through this immune mechanism, according to ANSES. Two examples:

  • thelactose intolerance comes from a lack of lactase, the enzyme that digests lactose, the sugar in milk. It causes digestive discomfort, whereas a milk protein allergy is an immune reaction to these proteins. Lactose alone does not trigger an allergy;
  • the coeliac disease is a chronic autoimmune disease that requires total exclusion of gluten. ANSES does not classify it as an allergy. For an overview of gluten, see Is gluten really bad?.

The INCO Regulation groups substances that cause allergies or intolerances into a single list, hence the presence of gluten and lactose. This guide does not replace the advice of a doctor, who is the only one who can make a diagnosis.

'May contain traces of': a voluntary precaution

Allergens added intentionally to the recipe are listed in the ingredients list. The statement 'may contain traces of' or 'may contain' refers to something else: a possible accidental presence, for example on a shared production line. According to sante.fr, manufacturers must assess the risks of contamination and seek to reduce them, and this statement is only a last resort when the risk cannot be controlled.

This statement is at the manufacturer's discretion and its wording is not harmonised. Its absence does not guarantee, in itself, the total absence of traces: sante.fr recalls that the accidental presence of major allergens is not impossible.

If in doubt

  • read the ingredient list of each product, every time you buy it: a recipe may change;
  • contact the manufacturer, whose contact details are on the packaging, for a specific question;
  • in restaurants or bakeries, ask for written information about allergens;
  • to find out what you need to avoid and how to react, consult your doctor or an allergist;
  • for regulatory questions, sante.fr refers you to the DDPP or DDCSPP in your department.

On Yumiq, you can find the list of ingredients for a product on its product page, which should be compared with the packaging in hand.

Sources

Frequently asked questions

What are the 14 allergens that must be declared in Europe?
Cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites (above 10 mg/kg or 10 mg/litre), lupin and molluscs. The list is set out in Annex II of Regulation INCO No 1169/2011.
How are allergens indicated on packaging?
They appear in the ingredient list, highlighted by the font, style or background colour (bold, capital letters, highlighting). If there is no ingredient list, the term 'contains' is used to indicate them. This is not required when the product name already clearly identifies the allergen.
Are allergens also declared in restaurants or bakeries?
Yes. This information is mandatory for non-prepacked products. In France, Decree No 2015-447 requires that it be provided in writing, in a legible and visible manner. The methods vary depending on the establishment: menu, board, notebook or screen.
Is an allergy the same thing as an intolerance?
No. An allergy is a reaction of the immune system. Intolerance, such as lactose intolerance, does not involve this mechanism, according to ANSES, and coeliac disease is a distinct autoimmune disease. Only a doctor can make a diagnosis.