UK EU allergen regulations have changed substantially since Brexit. These changes have created challenges that caused UK food and agricultural exports to slump by 22% since 2018, a drop of almost £4bn in real terms. Food manufacturers exporting to the EU must now manage dual compliance frameworks and balance Regulation (EU) No 1169/2011, which has required labelling of 14 specific allergens since December 2014, with evolving UK-specific requirements. Mandatory allergen labels now apply in all formats. Businesses must understand food allergen legislation in both jurisdictions to avoid fines and maintain market access.
UK vs EU allergen regulations: current landscape post-Brexit
Retained EU law and UK-specific requirements
The European Union (Withdrawal) Act 2018 set up the constitutional framework for retaining EU legislation in UK law following Brexit. This created a snapshot of EU law as it applied on 31 December 2020 [1]. Retained EU law covered thousands of legislative instruments across food safety, labelling and compositional standards. The Food Standards Agency managed to keep its top priority of making sure UK food remains safe and gets labelled with accuracy [2].
The 2023 Retained EU Law (Revocation and Reform) Act changed this framework on 1 January 2024. It renamed retained EU law as ‘assimilated law’ and removed special EU law features such as the principle of supremacy [1]. Food business operators working with UK food allergen regulations now operate under this assimilated legal framework. The UK government can amend it without Brussels.
The UK introduced Natasha’s Law in October 2021. It requires prepacked for direct sale (PPDS) foods to display full ingredient lists with emphasised allergens [3]. DEFRA regulates this legislation, which applies to foods prepared and packaged on-site for sale. This closed a gap where businesses previously provided allergen information only upon request. Failure to comply attracts substantial financial penalties and potential criminal prosecution [3].
Food Information Regulations (FIR) vs EU FIC Regulation 1169/2011
The Food Information Regulations 2014 serve as the UK’s primary allergen labelling framework. They were put in place before Brexit to transpose EU requirements into domestic law [4]. These regulations apply across England, Wales and Scotland. Local authorities handle enforcement. The FIR underwent amendment on 1 October 2021 to incorporate PPDS labelling requirements. This brought allergen information provision in line with prepacked food standards and reduced consumer confusion [4].
Regulation (EU) No 1169/2011 on the provision of Food Information to Consumers (FIC) remains the governing legislation in the EU. Article 9(1)(c) mandates declaration of any of the 14 major allergens listed in Annexe II when present as ingredients or processing aids in the finished product [4]. The FIC requires that mandatory allergen information appears in a conspicuous place and remains easily visible and clearly legible in accordance with Articles 12 and 13 [4].
Northern Ireland presents a distinct regulatory position. Products sold there must follow EU labelling rules and display an EU or NI address. This reflects the Windsor Framework arrangements [5]. Businesses exporting from Great Britain to the EU must ensure compliance with the full EU FIC framework, not just the UK’s assimilated version.
Key areas of continued alignment
Both jurisdictions recognise the same 14 substances listed in Annexe II of the FIC as mandatory allergens that require declaration [4]. These include cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites above 10mg per kg or litre, lupin and molluscs [6]. The allergen list represents the most common ingredients and processing aids that cause food allergies and intolerances across both markets.
Emphasis requirements remain aligned. Allergens must appear highlighted in ingredient lists through typographical means such as bold text, contrasting colours or font variations to ensure consumer visibility. The requirement applies whether allergens function as ingredients or processing aids, provided they remain present in the finished product [4].
Precautionary allergen labelling (PAL) follows similar voluntary frameworks in both jurisdictions. Food businesses may apply statements such as ‘may contain allergen x’ where unavoidable cross-contamination risk exists. PAL must supplement rather than replace mandatory allergen declarations. Businesses should conduct risk assessments that demonstrate unavoidable contamination risks before applying precautionary statements [6][4].
Notable differences that have emerged since Brexit
Regulatory divergence has appeared in specific technical areas. The EU amended Regulation 1169/2011 to clarify that certain emulsifiers derived from mustard seeds do not require allergen labelling owing to refined processing. Great Britain has not adopted this update. This creates a compliance gap for manufacturers using such emulsifiers in dual-market products [5].
Address requirements on labels differ between markets. Labels must include a UK address of the responsible food business operator for prepacked products sold in the UK. An EU address alone no longer satisfies UK requirements [5]. Products destined for EU markets require an EU member state address, and a UK address alone proves invalid [5]. This creates practical labelling challenges for businesses serving both markets at once.
The UK government has signalled potential for a dynamic UK-EU SPS Agreement that would realign Great Britain with EU legislation covering food allergen control, labelling and safety standards [5]. Under such an agreement, EU rules would replace current Great Britain regulations and the UK would align with future EU legislative changes. Details remain subject to negotiation. The UK intends to retain independent rules in areas supporting animal welfare standards and innovative food technologies [5].
Enforcement structures diverge as well. After Brexit, Trading Standards and local authorities enforce UK allergen regulations without EU enforcement mechanisms. The fundamental compliance principles from the original FIC framework continue to guide both systems [7].
Understanding the 14 regulated food allergens for EU exports
Annexe II allergen list requirements
Regulation (EU) No 1169/2011 identifies 14 substances in Annexe II that must always be declared when used in food products destined for EU markets [8]. These allergens require declaration whatever the quantity and even when appearing as components of compound ingredients or processing aids [5]. Scientific evidence identifying substances most likely to trigger serious allergic reactions in the European population forms the basis of the list [8].
The 14 regulated allergens include: cereals containing gluten (wheat including spelt and khorasan wheat, rye, barley, oats, or their hybridised strains), crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), nuts (almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts), celery, mustard, sesame seeds, sulphur dioxide and sulphites at concentrations exceeding 10mg/kg or 10mg/litre, lupin, and molluscs [9][5].
Certain allergen categories have specific naming conventions that apply to them. The specific cereal name must appear rather than the generic term ‘gluten’ for cereals containing gluten [10]. The exact nut type requires declaration rather than the collective term ‘nuts’ for nuts [9][10]. When wheat varieties like spelt or khorasan appear in products, labels must reference wheat explicitly, shown as ‘spelt (wheat)’ or ‘khorasan wheat’ [10].
How allergen labels must appear on packaging
Allergens must receive clear emphasis within the ingredient list itself through typographical means that distinguish them from other ingredients [5]. Businesses may select from methods including bold text, capital letters, underlining, or contrasting colour [8]. The chosen emphasis method must apply consistently throughout the ingredient list, as inconsistent formatting represents a common compliance failure during inspections [8].
Labelling must clarify the allergen for each ingredient separately where multiple ingredients originate from a single allergenic source [5]. To cite an instance, a product containing both soy lecithin and soy protein isolate requires allergen emphasis on both ingredients. Additional ‘contains’ statements prove helpful for consumers but do not replace the obligation to highlight allergens within ingredients [8].
Allergen information must appear in a language consumers in the sale country understand easily whilst meeting minimum font size requirements and remaining legible [8]. Poor contrast, overcrowded layouts, or low-quality printing undermine compliance even when correct wording appears present [8]. Ingredients lists may be omitted for packaging where the largest surface area measures less than 10cm² provided allergen presence appears using the word ‘Contains’ followed by the allergen name [10].
Exemptions from allergen labelling
Certain ingredients derived from allergenic starting materials receive permanent exemption from allergen labelling after thorough scientific evaluation [5][11]. These products contain only trace protein amounts unlikely to trigger allergic reactions in susceptible individuals under proposed use conditions [11].
Cereal-based exemptions include wheat-based glucose syrups (including dextrose), wheat-based maltodextrins, glucose syrups based on barley, and cereals used to make alcoholic distillates including ethyl alcohol of agricultural origin [9][5]. Fish exemptions cover fish gelatine used as carrier for vitamin or carotenoid preparations and fish gelatine or isinglass used as fining agents in beer and wine [9][11].
Soybean exemptions include fully refined soybean oil and fat, natural mixed tocopherols (E306), natural D-alpha tocopherol and its derivatives from soybean sources, vegetable oils derived phytosterols and phytosterol esters from soybean sources, and plant stanol ester produced from vegetable oil sterols from soybean sources [9][5]. Milk exemptions include whey used to make distillates or ethyl alcohol of agricultural origin and lactitol [9][11]. Nuts used to make alcoholic distillates receive exemption [9][11].
Sulphites and threshold levels
Sulphites represent the only allergen with a concentration threshold below which declaration becomes unnecessary [5]. Sulphur dioxide and sulphites require labelling when present above 10mg/kg or 10mg/litre in terms of total SO2, calculated for products as proposed ready for consumption or reconstituted according to the manufacturer’s instructions [9][5].
The labelling rules apply to sulphites added as preservatives or included within ingredients used in food preparation [10]. Clear declaration remains mandatory when concentrations exceed the threshold even when sulphites lack technological function in the finished product [10]. Labels must include both the function and name for products where sulphites function as additives, shown as ‘Preservative: sulphur dioxide’ [10].
Sulphites cause hypersensitivity reactions rather than true allergic responses, as they contain no proteins [10]. They may trigger respiratory problems in people with asthma, making accurate declaration essential [10]. The threshold applies to finished products and requires manufacturers to calculate total sulphite content after processing rather than relying solely on input quantities.
Natasha’s Law and UK-specific allergen requirements
PPDS labelling rules in the UK
Allergen labelling requirements came into force on 1 October 2021 [11] and brought the most important regulatory change for food businesses selling prepacked for direct sale items. Natasha’s Law, as this legislation became known, arose after the tragic death of 15-year-old Natasha Ednan-Laperouse in 2016. She suffered an allergic reaction after eating a wrapped baguette that contained unlabelled sesame [9]. The new requirements closed a longstanding gap where businesses could provide allergen information verbally rather than on packaging [9].
Three specific criteria determine PPDS classification. The food must be packaged before the consumer orders or selects it [9]. Foods made to order, sold loose, or placed into packaging after consumer selection fall outside PPDS scope. Packaging occurs on the same premises where the food is offered or sold to consumers [9]. The food must be fully or partly enclosed by packaging that cannot be altered without opening or changing it [9].
Pre-packaged sandwiches, salads and cakes selected from display units or kept behind counters qualify as PPDS [9]. Hot drinks made to order do not constitute PPDS unless pre-poured with a lid applied before consumer ordering [9]. Distance selling through online or telephone orders remains exempt from PPDS requirements, though businesses must continue meeting existing allergen information obligations [11].
PPDS labels must display the food name, a full ingredients list and any of the 14 allergens emphasised each time they appear in the list [12]. Emphasis methods include bold type, capital letters, contrasting colours or underlining [12]. The x-height must equal or exceed 1.2mm according to font size requirements, whilst small packets with largest surface areas below 80cm² permit x-heights of 0.9mm or greater [8].
How Natasha’s Law is different from EU PPDS requirements
The EU maintains different provisions for foods sold without prepackaging. EU FIC Regulation 1169/2011 requires businesses selling non-prepacked foods to make allergen information available but retains flexibility in delivery methods. Staff may communicate allergen details verbally, through menu descriptions, or via written information that is easy to access. The EU has not implemented equivalent mandatory on-pack labelling for foods prepared and sold on the same premises.
This divergence creates distinct compliance pathways. UK businesses must apply physical labels to PPDS items and require investment in labelling systems, staff training and ingredient tracking infrastructure [8]. EU businesses operating under existing FIC provisions face less prescriptive requirements for similar product categories, though they must ensure allergen information remains accessible and accurate.
Implications for dual-market products
Manufacturers serving both UK and EU markets encounter practical labelling challenges when products cross PPDS boundaries. A bakery operating in Great Britain must apply full PPDS labelling to sandwiches prepared on-site, whilst a similar operation in Dublin may provide allergen information through alternative means compliant with Irish enforcement of EU rules.
Businesses exporting PPDS-type products from the UK to EU destinations should verify whether receiving markets impose additional labelling obligations beyond baseline FIC requirements. Some EU member states apply stricter national rules that may require on-pack allergen declarations similar to UK PPDS standards.
The financial consequences of non-compliance prove substantial. UK businesses face financial fines for each PPDS labelling violation [9]. Reputational damage through social media exposure of non-compliance incidents threatens brand value and consumer confidence in today’s digital world [9]. Training requirements extend throughout organisations, from suppliers providing ingredient specifications to front-line staff handling packaged products [8].
Labelling requirements for food exports to the EU
Language and translation obligations
Products destined for EU markets must display mandatory food information in a language easy to understand by consumers in the member state where food is marketed [5]. This requirement gives individual member states authority to stipulate that particulars appear in one or more official Union languages within their territory [5]. Exporters cannot rely on English alone for continental markets. France requires French labelling, Germany requires German, and Spain mandates Spanish or co-official regional languages where applicable.
The accuracy of translated allergen information carries legal weight. Automated online translation tools may generate incorrect or misleading translations. You should not use them unless edited by professionals [13]. A mistranslation of ‘peanuts’ or incorrect declension of allergen terms in languages with grammatical cases can render labels non-compliant. This exposes exporters to rejection at borders and potential liability claims. Businesses exporting to multiple EU destinations often require separate label versions for each linguistic market. This drives up production complexity and inventory management challenges.
Font size and allergen emphasis rules
The FIC Regulation establishes precise legibility standards for mandatory particulars. Information must appear in characters with a font size where the x-height equals or exceeds 1.2mm [5]. This measurement applies to the lowercase letters’ height excluding ascenders and descenders, as defined in Annexe IV of the regulation. For packaging where the largest surface area measures less than 80cm², the minimum x-height reduces to 0.9mm [5][13].
Allergen substances require emphasis through typeset that distinguishes them from other ingredients [5][14]. Food business operators may select from bold text, capital letters, underlining, or contrasting background colour as emphasis methods [15]. The chosen method must apply throughout the ingredient list. Inconsistent formatting triggers non-compliance findings during inspections [16]. Mandatory information must remain easy to see and legible. It must not be obscured, hidden across folds, or interrupted by pictorial matter [5][17].
Ingredient declaration formatting
The ingredient list must appear preceded by a heading incorporating the word ‘ingredients’ and present all components in descending order of weight [5]. When allergens appear within this list, emphasis becomes mandatory within the list itself [13]. Additional ‘contains’ statements may supplement ingredient declarations but cannot replace the obligation to highlight allergens among ingredients [16][13]. This represents a frequent compliance error. Exporters believe by mistake that a ‘contains’ box satisfies regulatory requirements on its own.
Where no ingredient list exists, allergen presence must use the word ‘contains’ followed by the allergen name from Annexe II [13]. This provision applies to single-ingredient products or small packages exempt from full ingredient lists under space constraints.
Online and distance selling requirements
Food business operators selling prepacked foods through distance methods must provide similar allergen information levels as retail environments [18][10]. Article 14 of the FIC Regulation mandates that mandatory allergen information becomes available before purchase conclusion and at delivery [18][19]. Before consumers complete transactions, businesses must display allergen details via websites, catalogues, menus, or telephone communication [18][19].
Upon delivery, allergen information must appear through labels on packaging, receipts, delivery notes, verbal communication by delivery personnel, or direction to where information remains available [19]. The critical compliance element requires consistency between pre-purchase and delivery-stage allergen declarations [19]. This dual-stage obligation extends to imported goods and supermarkets providing online shopping services [10]. It creates additional documentation burdens for exporters managing cross-border distance sales with physical retail distribution.
Roles and responsibilities across the export supply chain
UK exporter obligations
Exporters from Great Britain bear main responsibility to ensure products comply with destination market requirements before goods leave UK territory. Any food or drink containing products of animal origin (POAO) requires an export health certificate issued by the Animal and Plant Health Agency. Processed foods may need certificates of free sale from the Rural Payments Agency [20]. The certifier invoices the government for inspection and certification costs under the Movement Assistance Scheme when moving POAO-containing foods to Northern Ireland [20].
Exporters must verify that EU or Northern Ireland-based import agents notify border control posts of incoming consignments with appropriate advance notice beyond certification [20]. Products failing inspection due to animal or public health risks face destruction at the border. Failures for other reasons permit importers to choose between destruction or return to Great Britain [20]. Businesses exporting POAO-containing foods must appear on approved business lists. Logistics hubs offer optimised border processes through centralised expert staff and documentation handling [20].
EU importer and food business operator duties
Food business operators throughout the European Union maintain legal obligations for allergen management systems that extend to imported products [11]. All businesses operating within EU borders must comply with legislation on allergen management. This requirement applies to domestic producers and importers receiving goods from third countries like the UK [11]. These operators ensure incoming products display correct allergen labelling and verify translation accuracy. They maintain traceability documentation linking allergens through distribution chains.
The SQF Code Edition 9, Module 2.7.1, sets industry standards requiring all allergens present in raw materials and finished products to be identified, documented and communicated throughout the supply chain [21]. Compliance objectives cover complete allergen inventories for all ingredients, supplier documentation verification and clear finished product labelling. Cross-contact prevention is also essential [21].
Responsible person requirements
General consumer products entering EU markets require a responsible person established within the Union under the General Product Safety Regulation since December 2024 [22]. This economic operator performs tasks including technical documentation checks, ensuring products carry instructions and safety information. They maintain traceability data and cooperate with market surveillance authorities [22]. The responsible person designation applies only to EU manufacturers, EU importers, EU authorised representatives or EU fulfilment service providers [22].
UK businesses selling to EU consumers must appoint authorised representatives within the EU to fulfil responsible person functions [22]. UK-based entities cannot serve as responsible persons for products sold in EU markets after Brexit [22]. Authorised representatives undertake verification of technical documentation, labels and batch identification numbers. They notify authorities about dangerous products and cooperate to reduce risks [23].
Documentation and record-keeping
Allergen declarations certify exported products meet international food safety standards. They prove essential to prevent health risks and ensure transparency with regulatory authorities [12]. Countries including the United States, UK, EU and Middle Eastern nations enforce strict allergen labelling laws requiring complete documentation [12]. Export documentation must include complete allergen inventories and supplier specifications confirming ingredient compositions. Batch-specific tracking records enable product recall if contamination occurs.
Local authorities provide export certification for products not covered by APHA-issued export health certificates. This includes non-animal origin items, processed meat products and manufactured foods and drinks [24]. The certification confirms products comply with domestic hygiene rules and remain fit for human consumption. Products must be available for sale within the UK [24].
Border checks and compliance verification for allergen management
SPS checks and documentary requirements
Border control posts perform sanitary and phytosanitary checks on food imports to protect biosecurity and verify compliance with EU food allergen legislation [25]. Consignments undergo documentary checks that look at health certificates and commercial documentation. Identity checks follow to verify that labelling and product identification match declared information [26]. Physical inspections may include sampling for pathogenic microorganisms and illegal contaminants. They also verify allergen labelling accuracy [26]. Port health authorities conduct these checks remotely before arrival or at inspection facilities upon entry [25].
Documentary checks for medium-risk animal products and high-risk food of non-animal origin from EU countries apply to randomly selected consignments at UK ports [9]. Importers must submit pre-notifications through designated systems and ensure consignments carry correct documentation with matching customs declarations [25]. Missing or incomplete paperwork triggers immediate rejection. Importers bear disposal costs [25].
Common rejection reasons at EU borders
Border authorities refused entry to more than 14,000 imports of products of animal origin in 2024 [8]. Improper documentation or certification, hygiene breaches and temperature abuse factored in the majority of rejections. Shipments from prohibited countries also contributed [8]. Authorities rejected over 3,200 consignments of food and feed of non-animal origin. Chemical and microbiological contamination, certification fraud and hygiene violations were cited [8].
Trading Standards and EU enforcement authority roles
EU member states designate competent authorities to organise official controls that verify operator compliance with agri-food chain legislation [27]. These authorities inspect businesses whatever their size and apply risk-based approaches to enforcement activities [27]. Trading Standards operates independently in the UK and maintains parallel enforcement structures post-Brexit.
Legal penalties and recall procedures
Regulation (EC) 178/2002 requires food business operators to withdraw unsafe food from markets and initiate recalls where products reach consumers [28]. 150 food recalls occurred in the UK in 2022. 84 related to undeclared allergens [28]. Violations attract unlimited fines under the General Food Regulations 2015. Individuals face up to two years imprisonment [28].
Allergen risk management in export production
Cross-contamination control for multi-market operations
Production facilities handling allergen-containing ingredients must implement physical separation measures to prevent unintentional allergen presence across product lines. Dedicated equipment, production lines and scheduling represent the most effective control strategies [29]. Where complete isolation proves impractical, colour-coded utensils and tools distinguish allergen-handling equipment from non-allergen production systems [30].
Production sequencing reduces contamination risks when manufacturing multiple product variants. Running non-allergen batches before allergen-containing products minimises cleaning requirements, as allergen clean-down only becomes necessary at sequence completion [31]. Storage protocols require allergenic ingredients positioned below non-allergen products to avoid accidental contamination through spillage [5].
Cleaning validation through on-site and laboratory testing confirms effectiveness of sanitation procedures [29]. Equipment should be really cleaned after running allergen-containing products before switching to non-allergen batches [31].
Precautionary allergen labelling: UK vs EU approaches
Precautionary allergen labelling remains voluntary across all 18 countries surveyed, including both UK and EU jurisdictions [32]. Statements such as “may contain” should only appear following risk assessment identifying unavoidable cross-contact risks that cannot be removed through management actions [5]. Excessive PAL use limits consumer choice and devalues warnings for those with genuine food allergen concerns [5].
Both jurisdictions prohibit PAL as substitute for good manufacturing practises [33]. Businesses must base precautionary statements on full risk assessments rather than blanket declarations [5].
Integration with HACCP and food safety systems
Allergens constitute chemical hazards under HACCP frameworks and require systematic risk-based management approaches [34]. HACCP-style risk assessments should identify incoming allergens, potential cross-contact opportunities and appropriate control measures at each process step [29]. Validation of control measures through audits and continuous improvement processes boosts allergen management effectiveness [29].
Traceability obligations across jurisdictions
Batch tracing provides visibility of affected product distribution when contamination occurs. This enables rapid notification of customers and blocks remaining stock [31]. Documentation requirements include allergen inventories for all ingredients, supplier specifications and batch-specific tracking records supporting product recall capabilities [31].
Practical compliance strategies and common mistakes to avoid
Steps for ensuring dual UK and EU compliance
Documentation systems are the foundations of compliant allergen management. Food businesses must record allergen ingredient information on product specification sheets, maintain ingredients in labelled containers, and update recipes when formulations change [35]. Version control protocols prevent the common error where recipe modifications occur but packaging artwork remains outdated [16]. Businesses serving both markets require separate label versions that address language obligations, address requirements and emphasis formatting differences.
Supplier verification and ingredient checks
Supplier specifications confirming ingredient compositions must undergo regular verification cycles. When businesses cross-check incoming materials against documented allergen inventories, they prevent inadvertent formulation changes from reaching production lines. Written protocols must require suppliers to notify them when ingredient specifications change, as unannounced substitutions represent a frequent source of non-compliance incidents.
Common export compliance errors
An Irish audit of food businesses found 32% provided no allergen information, whilst 76% of those providing information displayed inaccuracies [32]. Manual processes and fragmented information control cause these failures [16]. When businesses reuse older label templates without verifying current regulatory requirements, they trigger rejection at borders. Incorrect allergen terminology, poor translation quality and applying precautionary statements without documented risk assessments constitute additional compliance failures.
Preparing for future regulatory divergence
The European Commission expects to adopt harmonised precautionary allergen labelling rules in Q4 2027, requiring food business operators to conduct rigorous, documented risk assessments and justify PAL with quantitative allergen presence data [36]. Businesses should review current allergen management practises now, as the implementing regulation will prohibit using PAL as substitute for proper preventive measures.
Conclusion
Managing allergen compliance in UK and EU markets requires systematic documentation, supplier verification, and up-to-date knowledge of both jurisdictions. Therefore businesses must establish separate labelling protocols that address language obligations, address requirements and emphasis formatting differences. They need strong traceability systems.
The landscape continues evolving, with EU harmonised precautionary labelling rules expected in Q4 2027. Food manufacturers exporting across borders should audit current allergen management practises now rather than waiting for regulatory changes. Businesses that invest in complete allergen control systems and staff training will handle dual-market compliance successfully. They protect consumers and maintain export market access.
Key Takeaways
Understanding post-Brexit allergen regulations is crucial for UK food exporters, as compliance failures have contributed to a 22% drop in UK food exports since 2018.
• UK and EU maintain the same 14 mandatory allergens, but diverging requirements for addresses, language, and PPDS labelling create dual compliance challenges for exporters.
• Natasha’s Law requires full ingredient lists with emphasised allergens on UK prepacked-for-direct-sale foods, whilst EU markets retain more flexible allergen information provision.
• EU exports demand member state language compliance, precise font sizing (1.2mm x-height), and consistent allergen emphasis throughout ingredient lists to avoid border rejections.
• Exporters must appoint EU-based responsible persons, maintain comprehensive documentation, and implement robust supplier verification to prevent the 84 allergen-related recalls recorded in 2022.
• Future EU harmonised precautionary labelling rules in Q4 2027 will require documented risk assessments, making early preparation essential for continued market access.
Successful allergen management across both markets requires systematic documentation, regular supplier verification, and proactive preparation for evolving regulations rather than reactive compliance approaches.
FAQs
Q1. What are the main allergen labelling requirements under EU food legislation? EU legislation requires clear and consistent labelling of 14 specific allergens in both prepacked and non-prepacked foods. These allergens must be emphasised in ingredient lists through typographical means such as bold text, contrasting colours, or underlining. The regulations apply to any of the 14 major allergens listed in Annexe II when present as ingredients or processing aids in the finished product, allowing consumers with food allergies to make safe and informed choices.
Q2. How does Natasha’s Law differ from EU allergen requirements? Natasha’s Law, which came into force in the UK in October 2021, requires prepacked-for-direct-sale (PPDS) foods to display full ingredient lists with emphasised allergens directly on packaging. In contrast, the EU maintains more flexible provisions for similar foods, allowing businesses to provide allergen information through verbal communication, menu descriptions, or readily accessible written information rather than mandatory on-pack labelling.
Q3. What language requirements apply when exporting food to EU markets? Products destined for EU markets must display mandatory food information in a language easily understood by consumers in the member state where the food is marketed. Exporters cannot rely on English alone, as individual countries require their official languages—France requires French, Germany requires German, and Spain mandates Spanish or co-official regional languages. Professional translation is essential, as automated tools may generate incorrect allergen terminology.
Q4. What is the proposed UK-EU SPS agreement and when will it take effect? The new Sanitary and Phytosanitary (SPS) agreement is intended to boost trade by reducing paperwork, removing unnecessary checks, and helping fresh produce move more quickly across borders. The agreement is expected to come into force in mid-2027 and would realign Great Britain with EU legislation covering food allergen control, labelling, and safety standards, though the UK intends to retain independent rules in certain areas.
Q5. What are the most common reasons for food export rejections at EU borders? Border authorities commonly reject imports due to improper documentation or certification, hygiene breaches, temperature abuse, and shipments from prohibited countries. In 2024, over 14,000 imports of products of animal origin were refused entry. Additionally, undeclared allergens represent a significant compliance issue, accounting for 84 of the 150 food recalls in the UK in 2022.
References
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[33] – https://food.ec.europa.eu/food-safety/campaign-2026/allergies_en
[34] – https://www.siroccoconsulting.com/allergen-control-under-haccp/
[35] – https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses
[36] – https://www.twobirds.com/en/insights/2026/eu-to-harmonise-may-contain-allergen-labels-new-rules-expected-by-q4-2027