Global Requirements for Allergen Labeling
Yes, in many countries, it is a legal requirement for specific allergen ingredients to be listed clearly on food packaging. These mandatory labeling laws are crucial for protecting public health, enabling individuals with food allergies to make safe, informed decisions. However, the list of required allergens and the precise formatting rules vary by country and region.
United States Regulations: The "Big 9"
In the United States, the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) originally identified eight major food allergens. Following the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act of 2021, sesame was added, bringing the total to nine. The 'Big 9' allergens are:
- Milk
- Eggs
- Fish
- Crustacean shellfish
- Tree nuts
- Peanuts
- Wheat
- Soybeans
- Sesame
FALCPA requires manufacturers to declare these allergens on the food label in one of two ways: either in parentheses following the ingredient name in the ingredients list (e.g., 'lecithin (soy)'), or immediately after the ingredients list in a 'Contains' statement (e.g., 'Contains: Wheat, Milk, and Soy').
European Union: The 14 Major Allergens
The European Union operates under the Food Information for Consumers (FIC) Regulation (EU) No 1169/2011, which lists 14 major allergens that must be declared. These are:
- Celery
- Cereals containing gluten
- Crustaceans
- Eggs
- Fish
- Lupin
- Milk
- Molluscs
- Mustard
- Nuts
- Peanuts
- Sesame seeds
- Soybeans
- Sulphur dioxide and sulphites (at concentrations of more than 10mg/kg or 10mg/litre)
Allergenic ingredients must be emphasised within the ingredients list through font, style, or background colour, such as using bold text. The UK's Natasha's Law further requires full ingredient and allergen labeling for food that is pre-packed for direct sale (PPDS).
Australia and New Zealand: Plain English Allergen Labelling (PEAL)
Since February 2024, Australia and New Zealand have been transitioning to Plain English Allergen Labelling (PEAL). This new regulation standardizes allergen names and requires declarations in two places: within the bolded ingredients list and in a separate bold 'Contains' summary statement. This aims for greater clarity and consistency for consumers.
Comparison of Allergen Labeling Regulations by Region
| Feature | United States (FDA) | European Union (FIC) | Australia/NZ (PEAL) |
|---|---|---|---|
| Number of Allergens | 9 (milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soy, sesame) | 14 (includes celery, cereals containing gluten, molluscs, mustard, lupin, sulphites) | ~14 (includes individual tree nuts, molluscs, etc.) |
| Declaration Method | 'Contains' statement OR parentheses in ingredients list | Emphasized in ingredients list (e.g., bold, color) | Bold in ingredients list AND bold 'Contains' summary |
| Non-Prepacked Food | Information must be provided, but methods can vary | Information must be available, can be verbal with clear signposting | Information must be available upon customer request |
| Precautionary Labeling | Voluntary ('may contain') and unregulated | Voluntary, not legally regulated | Voluntary ('may contain'), not legally regulated |
Beyond Standard Labeling: Precautionary and Hidden Allergens
In addition to mandatory allergen declarations, two other factors are crucial for consumer safety: precautionary labeling and hidden allergens.
Precautionary Allergen Labeling (PAL)
PAL statements, such as "may contain" or "processed in a facility with," are voluntary warnings used by manufacturers when there is a risk of unintentional allergen cross-contamination. These warnings are not legally regulated and do not replace the need for careful ingredient management. For consumers with severe allergies, a conversation with a healthcare professional is often recommended to interpret the level of risk associated with these statements.
Hidden Allergens
Allergens can be 'hidden' within other ingredients or listed under less-obvious names. In many regions, regulations require clearer declaration, referencing the common name (e.g., 'whey (milk)') to avoid confusion. This practice ensures consumers recognize the allergen source even if it is part of a compound ingredient.
Conclusion
For food manufacturers and suppliers, the legal requirement to list allergen ingredients is a fundamental and non-negotiable aspect of business in most developed markets. While the specifics differ by region, the global trend is toward increasingly strict and transparent labeling to protect allergic consumers. For consumers, the ultimate responsibility rests on understanding the specific laws in their area and reading every label, every time, as product ingredients and processes can change. This vigilance is vital, as manufacturers continue to refine their approach to allergen management and labeling. Businesses must stay current with regulations to ensure compliance and consumer trust. Learn more about food allergen labeling and consumer protection from reputable sources like the Food and Drug Administration (FDA) in the United States.
