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UK’s 14 allergens: pack, PPDS and loose food rules

Reference table of the 14 allergens requiring declaration in UK food law, and the differing information rules for prepacked, PPDS and loose food.

Claims9 min read
The short answer

A front-of-pack nutrition claim is a regulated phrase, not a general impression. No added sugar, reduced sugar, light, source of fibre and high in protein each have to meet a stated legal condition before they may appear, and several require accompanying wording on the pack. Read the exact claim words first, then check the nutrition declaration, the comparison food where the claim is comparative, and any qualifying statement beside it.

UK food law identifies 14 allergens that must be declared when used as ingredients or processing aids and still present in the finished food. Prepacked and PPDS foods require an ingredients list with allergens emphasised. Loose food must make allergen information available before purchase, including at a counter.

The rule in one reading order

For food sold in Great Britain, start by identifying how it is offered for sale. The format of sale determines how allergen information must reach the customer. The relevant list is the 14 allergens in Annex II of retained food information law. They are not a list of foods to avoid generally. They are ingredients or substances for which specific declaration duties apply when they are used and remain present in the food.

For ordinary prepacked food, read the ingredients list first. Every Annex II allergen used in the recipe, including one contained within a compound ingredient, must be identified and visually emphasised in that list. For food prepacked for direct sale, often shortened to PPDS, the package or a label attached to it must carry the name of the food and a full ingredients list with allergens emphasised. This is the requirement commonly called Natasha's Law.

For loose food, such as food served from a counter, food ordered in a café, or unpackaged bakery items, an ingredients label is not automatically required. The business must nevertheless provide allergen information before the customer buys. It may provide that information in writing, or orally where clear signposting tells customers how to obtain it. The information needs to be specific to the food being sold, rather than a general statement that allergens may be present.

Sale formatCore allergen dutyWhere a reader should look
Prepacked foodIngredients list, with each listed allergen emphasisedOn the pack
PPDS foodName of food and full ingredients list, with allergens emphasisedOn the package or attached label
Loose or non-prepacked foodAllergen information available before purchaseAt the counter, menu, notice or from staff as signposted

This reference concerns mandatory allergen declaration, not nutritional advice, diagnosis or the medical management of an allergy.

The fourteen allergens and names that may appear

The table uses the statutory categories and gives familiar ingredient names that may help a reader recognise them in an ingredients list. It is not exhaustive. A food can contain an Annex II allergen through a less familiar ingredient, a flavouring, a processing aid, or a compound ingredient. In a complete ingredients list, the allergen itself must still be made clear.

Allergen categoryCommon ingredient names a reader may encounterWhat the category covers
Cereals containing glutenWheat, rye, barley, oats, spelt, khorasan wheatThe named cereal must be identified
CrustaceansCrab, lobster, prawn, shrimp, crayfishCrustacean ingredients
EggsEgg, albumen, egg white, egg yolkEgg and egg-derived ingredients
FishFish, anchovy, salmon, tuna, codFish ingredients
PeanutsPeanut, groundnutPeanut ingredients
SoyaSoya, soy, tofu, edamameSoya bean ingredients
MilkMilk, butter, cream, cheese, whey, yoghurtMilk ingredients, including lactose where relevant
NutsAlmond, hazelnut, walnut, cashew, pecan, Brazil nut, pistachio, macadamiaThe specified tree nuts in the legal category
CeleryCelery, celeriacCelery and celery-derived ingredients
MustardMustard, mustard seed, mustard powderMustard ingredients
SesameSesame, tahiniSesame seed ingredients
Sulphur dioxide and sulphitesSulphites, sulphur dioxideAt concentrations above the legal threshold
LupinLupin, lupin flour, lupin seedLupin ingredients
MolluscsMussel, oyster, squid, clam, scallopMollusc ingredients

The nuts category is limited to the named tree nuts. Coconut and pine nuts are not among those specified nuts, although a business may voluntarily identify other ingredients for other reasons. That voluntary information does not replace the statutory allergen declaration.

What “emphasised” means in an ingredients list

On prepacked and PPDS food, allergen information belongs within the ingredients list. The allergen must be emphasised through a typeset that clearly distinguishes it from the rest of the list. Bold type is common, but it is not the only method. A contrasting font, style or background colour can meet the purpose if the distinction is clear and legible.

The duty concerns the allergen actually used in the food. A straightforward example is an ingredient list reading: “flour (wheat), water, yeast, salt”. A compound ingredient must also disclose an allergen it contains. For example, where an ingredient is mayonnaise, the full declaration may make clear that it contains egg. The point is not merely to highlight the word “mayonnaise”, because that word alone does not identify the regulated allergen clearly enough.

Where a product has no ingredients list, the allergen must instead be indicated with the word “contains” followed by the allergen name. This situation is limited in practice, because many packaged foods require an ingredients list. A separate allergen box can be useful additional information, but it does not normally cure an ingredients list that fails to identify and emphasise the allergens within it.

“May contain” wording is different. It is precautionary allergen labelling, used to communicate a possible unintended presence from cross-contact. It is not the declaration of an ingredient, and it is not one of the prescribed ways to replace ingredient information. The publication’s existing guides to ingredients-list order and allergen information on packaging provide the wider pack-reading context.

Prepacked food: the full ingredients-list duty

Prepacked food is food put into packaging before it is offered for sale, where the packaging encloses it so that the contents cannot be altered without opening or changing the packaging. A sealed packet placed on a shop shelf is the familiar example. The customer should be able to inspect the required information before choosing to buy.

The food business operator responsible for the information must provide an ingredients list unless a specific legal exemption applies. Where an Annex II allergen or a product derived from it is used as an ingredient or processing aid and remains present in the finished food, it must be clearly referred to in the ingredients list and emphasised. This applies even if the allergen is present through an ingredient that has its own list of components.

Reading order matters. First find the ingredients heading. Then scan the list for emphasis, but do not stop there. Check parenthetical ingredient details, because a highlighted allergen can appear within them. If the product has a separate voluntary allergen panel, compare it with, rather than substitute it for, the ingredients list. The legally significant information is the ingredient declaration and its emphasis.

A reader should also distinguish a recipe allergen from a cross-contact warning. “Contains milk” or highlighted milk in an ingredient list identifies milk as part of the food. “May contain milk” communicates a different risk statement. Neither phrase establishes whether a food is suitable for a particular individual. A person managing an allergy should obtain advice appropriate to their circumstances.

PPDS food and Natasha’s Law

PPDS means prepacked for direct sale. It describes food packed on the same premises from which it is sold, before it is selected by the customer, and sold from those premises or from a mobile or temporary premises operated by the same business. The category commonly includes food made and packed for display in a shop or service outlet, ready for a customer to pick up.

Since the PPDS changes known as Natasha’s Law took effect in England, Wales and Northern Ireland, PPDS food must carry the name of the food and a full ingredients list with allergens emphasised. Scotland has corresponding PPDS requirements. The practical consequence is that a PPDS seller cannot rely only on a general notice directing customers to ask staff for allergen information.

The requirement is about the package or a label attached to it. A customer must be able to identify the food and inspect the full list of ingredients before purchase. The highlighting rule is the same basic rule used for prepacked food: Annex II allergens must stand out from the other ingredients by typeface, style or background colour.

The category depends on the facts of packing and sale, not on whether a product looks like a supermarket item. Food packed at one site and then supplied to a separate outlet may fall under the ordinary prepacked rules instead. Food prepared only after the customer orders it may be loose food rather than PPDS. When the sales arrangement is unclear, the relevant local authority food safety team can assess the operation.

Loose food: information before the customer buys

Loose or non-prepacked food includes food sold without packaging, food packed at a customer’s request, and food served in catering settings. The legal outcome is not that allergen information disappears. It must be available to the customer before the purchase is completed.

A business can provide the information in writing, for example on a menu, ticket, counter card or separate allergen record. It may also give information orally, provided there is clear signposting that customers can ask a member of staff and the information is available when requested. Food Standards Agency guidance explains that businesses using oral communication should support it with accurate written information so staff can provide a reliable answer.

A vague disclaimer is not a substitute for food-specific information. A notice saying that a kitchen handles all allergens does not tell a customer whether a particular soup contains celery, whether a cake contains egg, or whether a sauce contains mustard. If an item’s ingredients change, the information available to staff and customers needs to change with it.

At a staffed counter, the useful question is direct: “Which of the 14 allergens are ingredients in this item?” For an unpackaged item sold from a display, ask before paying and before relying on a previous answer. Recipes, suppliers and preparation methods can change. A customer who cannot obtain a clear answer should not treat an assumption as allergen information.

Limits, exceptions and enforcement

This reference covers the United Kingdom’s core allergen-information framework, but it is not a complete guide to every food-labelling requirement. It does not explain ingredient order, quantitative ingredient declarations, date marking, nutrition claims, organic status, country of origin, or the separate rules for medicines and cosmetics. It also does not decide whether a particular food is safe for an individual with an allergy, coeliac disease or another condition.

Some technical exceptions apply within Annex II. For example, sulphur dioxide and sulphites are subject to a concentration threshold expressed as sulphur dioxide. Certain highly processed derivatives of listed allergens are excluded where the law identifies them as not likely to cause adverse reactions. Those exceptions are narrow technical provisions. A reader should not infer an exception simply because an ingredient sounds refined or because an allergen is present in a small amount.

Local authorities enforce food information rules for most food businesses. In Great Britain, Food Standards Agency guidance supports the application of the rules, while local authority officers investigate food safety and labelling matters in their areas. Enforcement can involve requests for information, corrective action and, where appropriate, formal action under food law.

For a shopper, retain the pack or take a clear record of the product name, batch or date code, retailer and the wording seen. For loose food, note the item, outlet, date and the information given. This does not replace urgent medical help where a person is unwell after eating food.

Questions readers ask

What are the 14 allergens that must be declared in UK food law?

They are cereals containing gluten, crustaceans, eggs, fish, peanuts, soya, milk, nuts, celery, mustard, sesame, sulphur dioxide and sulphites, lupin, and molluscs. The duty applies when one is used as an ingredient or processing aid and remains present in the finished food, subject to specified technical exceptions.

Do allergens have to be in bold on food packaging?

Bold is a common way to make allergens stand out, but it is not the only permitted approach. On an ingredients list, the allergen must be emphasised using a clearly distinct typeface, font style or background colour. The result must make the allergen readily distinguishable from the other ingredients.

Does Natasha’s Law apply to all food sold in a café?

No. It applies to food prepacked for direct sale, meaning food packed before the customer selects it and sold from the same business premises or its relevant mobile or temporary operation. Food made to order or served loose remains subject to the loose-food duty to provide allergen information before purchase.

Can a counter staff member give allergen information verbally?

Yes, allergen information for loose food may be provided orally if clear signposting tells customers how to obtain it. The answer must be available before purchase and be specific to the item. Food Standards Agency guidance supports keeping written information available to underpin staff answers.

Is “may contain” the same as declaring an allergen ingredient?

No. “May contain” is precautionary allergen labelling about possible unintended cross-contact. It does not state that the allergen is an ingredient, and it cannot replace the requirement to identify and emphasise allergens that are actually used in an ingredients list.

Do all tree nuts fall under the legal nuts allergen category?

The statutory nuts category names almond, hazelnut, walnut, cashew, pecan, Brazil nut, pistachio and macadamia or Queensland nut. A label may identify other ingredients voluntarily, but that does not alter the defined list. The ingredient list remains the starting point for identifying what is in the food.

Sources

Links to regulators, legislation and official guidance. They are cited because they are public and verifiable, not as an endorsement of this article. Where any subject reaches diet or health, the NHS and a registered dietitian are the right sources rather than this publication.

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