Do Allergens Have to Be in Bold? Understanding Global Food Labeling Rules

A single food allergy affects millions globally, necessitating clear and consistent labeling to protect consumers. For this reason, many have wondered, 'Do allergens have to be in bold?' The answer depends heavily on which country the food is sold in, as different jurisdictions have distinct—and sometimes evolving—rules for emphasizing allergenic ingredients on packaging.

Quick Summary

Food allergen labeling requirements differ across regions like the EU, Australia, and the US. Emphasis methods, including bolding, highlighting, or a separate 'Contains' statement, vary based on local regulations designed for consumer clarity.

Key Points

• Not always bold: While common, bolding allergens is not universally mandatory and depends on the country's specific food labeling laws.

• Multiple emphasis methods: The UK and EU allow for various methods of emphasizing allergens, including bolding, italics, underlining, and color.

• Strict bolding rules: Australia and New Zealand's PEAL initiative requires allergens to be declared in bold within the ingredients list and a separate 'Contains' statement.

• US flexibility: In the US, a separate 'Contains' statement or parenthetical in-list declaration is used for major allergens, with no federal mandate for bolding.

• Regional awareness is key: Both consumers and food businesses must be aware of specific local regulations to ensure safety and compliance, especially when dealing with imported products.

Regional Allergen Labeling Requirements

Food labeling standards are not uniform worldwide, with different countries implementing their own legislation to govern the declaration of allergens. This can be confusing for consumers and manufacturers alike. Understanding the specific rules in your region is crucial for making informed and safe food choices.

European Union and United Kingdom Regulations

In the European Union and the UK, manufacturers are required to highlight the presence of any of the 14 major allergens within the ingredients list. However, bolding is not the only acceptable method. The legislation allows for flexibility, stating that the allergenic ingredient must be emphasized in a way that makes it stand out from the other ingredients. This can be achieved using a variety of formats.

• Allowed emphasis methods:
  • Bolding: Ingredients: ...flour (WHEAT), egg white...
  • Italics
  • UNDERLINING
  • Contrasting colors: Allergen Advice: for allergens... see ingredients in red
• Clear reference: A less common ingredient name must be clearly referenced to the allergenic source, such as whey (milk) or tofu (soya).
• Allergy advice statement: An accompanying Allergen Advice: for allergens, see ingredients in bold statement can help clarify the emphasis method used on the label.

Australia and New Zealand Regulations

Australia and New Zealand have particularly strict and explicit rules under their Plain English Allergen Labelling (PEAL) initiative. This system was implemented to make allergen information easier to find and understand. For pre-packaged foods, bolding is explicitly required, along with a separate summary statement.

• Required emphasis: Allergens must be declared using bold font in the ingredients list and in a separate summary statement.
• Summary statement: This statement must start with the word 'Contains' and list the required name of each food allergen present. For example: Contains: milk, soy, almonds.
• Font requirements: The bold font must contrast distinctly with other text and be no smaller than the font used for other listed ingredients.
• Consistent naming: Specific names for cereals (e.g., wheat, barley) and tree nuts (e.g., almond, cashew) must be used.

United States Regulations

The US Food and Drug Administration (FDA) is governed by the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA). Unlike Australia and New Zealand, bolding is not explicitly required under federal law, but a clear declaration is mandatory. The law specifies a few methods for declaration.

• Declarations can be made in two ways:
  • In-list parenthetical declaration: The source of the allergen is listed in parentheses immediately after the ingredient name. For example: whey (milk) or flour (wheat).
  • Adjacent 'Contains' statement: A separate and distinct 'Contains' statement is placed immediately after or adjacent to the ingredients list. For example: Contains: Milk, Wheat.
• No bolding mandate: The US does not mandate bolding, but if a 'Contains' statement is used, all allergens must be listed, regardless of whether they are recognizable in the ingredients list.

Comparison of International Allergen Labeling Rules

Feature	United Kingdom / EU	Australia / New Zealand (PEAL)	United States (FALCPA)
Emphasis Method	Flexible: Bold, italics, contrasting colors, or underlining.	Mandatory: Bold font only.	Not mandatory; clear declaration is required.
Summary Statement	Voluntary Allergen Advice statement explaining the emphasis used.	Mandatory Contains statement in bold.	Mandatory Contains statement (if not declared in-list).
In-List Declaration	Emphasized within the ingredients list.	Emphasized in bold within the ingredients list.	Can be parenthetical (allergen) or relied upon if the name is clear.
Specified Allergens	14 main allergens.	A specified list requiring plain English names.	9 major allergens.
Key Legislation	Food Information to Consumers Regulation (FIC).	Food Standards Code (PEAL changes 2021).	Food Allergen Labeling and Consumer Protection Act (FALCPA).

Why Bold and Other Emphasis are Critical for Safety

The purpose of emphasizing allergens, whether by bolding or other means, is to make this vital information as clear and accessible as possible to consumers. For individuals with severe allergies, quickly and accurately identifying allergens is a matter of health and safety. Standardizing the method of emphasis, as seen in Australia/New Zealand, helps eliminate guesswork. In regions with more flexible rules, like the EU and UK, the consistency is achieved through a required, visible declaration that stands apart from the surrounding text. For consumers, this highlights the necessity of checking local rules and not relying on a single visual cue across all products.

The Role of Precautionary and 'Free From' Labels

Beyond mandatory labeling, many products include voluntary statements like May contain or Free from. These are not substitutes for mandatory declarations but provide additional information.

• Precautionary Allergen Labeling (PAL): A May contain statement is used when there is an unavoidable risk of cross-contamination, even after rigorous controls. This is voluntary and not regulated in all areas.
• Free From Statements: These are strict, voluntary claims that guarantee the absence of a specific allergen, requiring rigorous controls. The only exception is 'gluten-free,' which permits a trace amount of less than 20mg/kg.

Conclusion: The Importance of Regional Awareness

Ultimately, the question of 'Do allergens have to be in bold?' has no single, universal answer. While some countries, like Australia and New Zealand, mandate bolding and a separate 'Contains' statement, others, including the UK and EU, permit a wider range of emphasis methods. The US offers flexibility between parenthetical declarations and a 'Contains' statement. For consumers and manufacturers navigating the global food market, understanding these regional differences is paramount. It emphasizes that while the goal is universally clear communication of allergen risks, the specific legal requirements for achieving that goal vary significantly. For the most up-to-date information on UK rules, consult the official guidance from the Food Standards Agency.

How Food Allergens are Labelled Across the World

• Australia and New Zealand: Require allergens to be in bold in the ingredients list AND in a separate summary Contains statement.
• United States: Requires a clear declaration of major allergens, either in-list parentheses or a separate Contains statement, but not necessarily in bold.
• European Union and UK: Mandate that allergens be emphasised in the ingredients list, with bolding being one of several accepted methods.
• Plain English: Newer regulations, particularly PEAL in Australia, standardize allergen names to plain English to improve readability.
• Precautionary Labels: Statements like May contain are voluntary but used to communicate cross-contamination risks.
• Single-Ingredient Products: Foods consisting of a single allergen (like a bag of peanuts) do not require additional allergen declarations.

Regional Labeling Examples

Here are some examples illustrating how the declaration of milk might vary on a product label depending on the region:

UK/EU Label Example: Ingredients: Sugar, Cocoa Mass, Cocoa Butter, WHEY POWDER (milk), Emulsifier (SOYA Lecithin), Natural Vanilla Flavouring

Australia/New Zealand Label Example: Ingredients: Sugar, Cocoa Mass, Cocoa Butter, Whey Powder (milk), Emulsifier (soy lecithin), Natural Vanilla Flavouring. **Contains: Milk, Soy.**

US Label Example: Ingredients: Sugar, Cocoa Mass, Cocoa Butter, Whey Powder (milk), Emulsifier (soy lecithin), Natural Vanilla Flavoring. Contains: Milk, Soy.

Conclusion

Understanding regional differences is critical for both consumer safety and manufacturer compliance. The variation in rules, especially concerning whether allergens have to be in bold, highlights the need to remain vigilant and informed about local food labeling standards. This ensures that individuals with allergies can confidently make safe choices, and that businesses meet their legal obligations.

Frequently Asked Questions

Are allergens always in bold on food labels?

No, allergens are not always in bold. While it is a common and often required practice in some regions like Australia and New Zealand, other places like the UK and EU permit different methods of emphasis, such as underlining, italics, or contrasting colors.

What is the Plain English Allergen Labelling (PEAL) initiative?

PEAL is a set of regulations introduced in Australia and New Zealand to make allergen information clearer and easier to find. Under PEAL, allergens must be declared in bold within the ingredients list and in a separate, summary 'Contains' statement.

Is a 'Contains' statement mandatory in the United States?

In the US, a separate 'Contains' statement is one of two primary methods for declaring allergens, but it is not mandatory if the allergens are clearly declared parenthetically within the ingredients list.

What do the UK and EU require for allergen labeling?

In the UK and EU, manufacturers must emphasize allergenic ingredients within the ingredients list. This can be done using bolding, italics, a contrasting color, or by underlining.

What does a 'May contain' statement mean?

A 'May contain' or precautionary allergen labeling (PAL) statement is a voluntary advisory warning used when there is a risk of unintentional cross-contamination with an allergen, even after all preventative measures have been taken.

Do single-ingredient products need allergen labels?

No, if the food is a single ingredient and its name clearly indicates the allergen (e.g., a bag of peanuts or a box of eggs), additional allergen declarations are not required.

Can different countries have different allergen labeling laws?

Yes, different countries have distinct laws regarding allergen labeling. A product labeled for sale in the US, for example, may not meet the stricter bolding and 'Contains' statement requirements of Australia/New Zealand.