Food labelling requirement

As of 13 December 2014, a new EU directive regulates, among other things, the labelling of the 14 most common triggers of allergies or intolerances (EU Regulation No. 1169/2011).

If these substances or products made thereof are used in a product, they must be clearly labelled in the list of ingredients.

1) Cereals containing gluten, namely wheat (such as spelt and khorasan wheat), rye, barley, oats, or hybrid strains thereof.
2) Crustaceans
3) Eggs
4) Fish
5) Peanuts
6) Soybeans
7) Milk (including lactose)
8) Nuts, namely almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia, or Queensland nuts.
9) Celery
10) Mustard
11) Sesame
12) Sulphur dioxide and sulphites of more than 10 mg/kg or 10 mg/l
13) Lupin
14) Molluscs

This labelling requirement applies not only to packaged goods with a printed list of ingredients, but also to unpackaged goods, such as those available in bakeries, butcher shops, restaurants, or canteens. The information on the allergens contained may be provided in writing, electronically or orally. However, in the case of oral information, written documentation must also be available and easily accessible.

Allergen labelling on packaged goods must be clearly distinguishable from the other ingredients in the list of ingredients, such as by bold type or a coloured word mark.

Thus, there is a clear labelling obligation for the substances mentioned, as defined by the EU, as soon as they are actually used as an ingredient in a product, regardless of the quantity used. However, it gets complicated for consumers when a product bears the notice “May contain traces of …”. This trace labelling is not legally regulated and it remains unclear, for one thing, whether traces of the allergen mentioned are contained at all and, for another, exactly what quantity constitutes a “trace” amount.

A Ga2len position paper was recently published on this topic, proposing a workable threshold of 0.5 mg of protein per 100 grams of processed food for voluntary trace labelling in processed foods. More than 200 studies were analysed for this purpose and it was found that a contamination of less than 0.5 mg protein in 100 grams of processed food does not pose a risk to the majority of allergy sufferers if a usual serving size is consumed. This tangible threshold value would provide clear guidance for allergy sufferers when making product choices. Nevertheless, the need for further research in the area of threshold values is pointed out. Here you can find the LINK to the article.

Further information on the topic of food labelling and the underlying criteria can be found here.

Find out more about the ECARF Seal for allergy-friendly products, buildings, and services. Products from all areas of life are tested: better for allergy sufferers, better for the environment, healthier for everyone.



1) EU Regulation No. 1169/2011
2) Zuberbier T, et al. Proposal of 0.5 mg of protein/100 g of processed food as threshold for voluntary declaration of food allergen traces in processed food-A first step in an initiative to better inform patients and avoid fatal allergic reactions: A GA²LEN position paper. Allergy. 2022 Jun;77(6):1736-1750.