Allergen Labeling on Food Labels in the UK

With food allergies impacting many consumers in the UK and on a global level, allergen labeling on food products is becoming critical to consumer safety. The improper labeling of allergens poses significant risks to public health, as consumers can have severe and potentially life-threatening allergic reactions from the accidental consumption of allergens. 

In response to such risks, the UK has strengthened its allergen labeling regulations through key measures, including Natasha’s Law, which came into force in 2021, and new post-Brexit guidelines like the Windsor Framework, adopted in 2023. It requires clearly displaying major allergens on food labels, with manufacturers strictly enforcing these rules to avoid serious legal repercussions and reputational harm to businesses.

This article will guide you through the essential requirements, recent regulatory changes, and compliance measures for manufacturers unsure of how to label allergens or food additives.

Understanding UK Food Allergen Labeling Requirements

Legal Framework

The UK’s allergen labeling regulations require clear and prominent allergen disclosures on all pre-packed and direct-sale food items. Natasha’s Law adds to allergen regulations by mandating that any food prepared and packed on-site must show allergen information directly on the packaging. These laws aim to prevent consumers from being accidentally exposed to these allergens or harmful ingredients.

Since Brexit, the UK has added new federal regulations like the Windsor Framework. This framework governs the movement of goods from Great Britain to Northern Ireland, and requires additional compliance checks to ensure that allergen information meets the specific safety standards set in Northern Ireland.

Local authorities are responsible for enforcing these food allergen requirements by conducting regular inspections to protect consumer health. Compliance is strictly monitored and can potentially lead to penalties like fines, product recalls, or even legal action. All allergen information must also be provided in English, ensuring accessibility for all UK consumers and reinforcing the importance of accurate allergen labeling for food businesses.

The 14 Major Food Allergens

The current regulations for UK food labeling require that the 14 major allergens be shown on food packaging as a way to protect vulnerable consumers and ensure that they can clearly see the allergens present at a quick glance. 

Here’s a breakdown of each allergen:

1. Celery and Celeriac: Includes all forms, such as stalks, leaves, seeds, and roots (celeriac).
2. Cereals Containing Gluten: Refers to gluten-containing grains like wheat, rye, barley, and oats.
3. Crustaceans: Includes shellfish such as crab, lobster, and shrimp.
4. Eggs: Refers to eggs from all bird species and products containing egg-derived ingredients.
5. Fish: Applies to any fish or fish-based products.
6. Lupin: A legume that includes seeds and flour, often used in baked goods.
7. Milk: Includes milk from mammals like cows, sheep, and goats, along with all milk-based products.
8. Molluscs: Shellfish like mussels, clams, and oysters fall under this category.
9. Mustard: Covers mustard seeds, mustard powder, and oil.
10. Tree Nuts: Encompasses specific types such as almonds, walnuts, cashews, hazelnuts, and more.
11. Peanuts: Includes peanuts and all peanut-derived products.
12. Sesame Seeds: Covers whole seeds and sesame oil or paste (tahini).
13. Soybeans: Includes all soy products, from tofu to soy flour.
14. Sulphur Dioxide and Sulphites: These preservatives must be labeled if the concentrations are above 10 mg/kg or 10 mg/L.

This selection has been chosen based on scientific research that proves that these allergens cause the most severe allergic reactions. However, regulatory bodies are continually assessing threshold levels to improve consumer safety and minimize any accidental exposure to allergens.

Labeling Requirements by Food Type

Different types of food products have specific allergen labeling requirements to ensure consumers receive necessary allergen information, regardless of the food’s packaging or method of sale.

Prepacked Foods

Prepacked foods are food items that are either fully enclosed by packaging or partly wrapped by packaging. Examples of prepacked foods include cereal boxes or frozen ready-to-eat meals, which cannot be altered without having to break or change the packaging. 

These items must include a complete ingredient statement, with allergens highlighted, typically in bold or uppercase, for easy identification. Compliant labels feature clear allergen declarations to protect consumers from these potential risks. For example, a prepacked sandwich label would list all ingredients, with allergens like “wheat” or “milk” prominently highlighted.

Prepacked for Direct Sale (PPDS)

PPDS foods are items packed on the same premises from which they are sold, such as sandwiches in a deli, fresh bakery goods, or foods at a market. Following Natasha’s Law, PPDS food items must also have a full ingredient statement with clear allergen information displayed directly on their packaging. 

This requirement is particularly important for small businesses, which may sell items that were previously exempt from strict labeling. 

Non-prepacked Foods

For non-prepacked foods such as buffet food, fast food restaurants, or loose produce at a market, allergen information must be available verbally and in writing. 

For distance selling or takeaways, food businesses must provide allergen information at multiple stages. For example, allergen details should be available on ordering platforms and confirmed upon delivery, ensuring consumers are informed before they consume the food. For telephone orders, clear communication about allergens is essential, and delivery documentation should confirm this information.

Staff training is also essential so team members can inform customers about major food allergens, while documentation requirements ensure allergen information is accessible. Clearly displayed point-of-sale information, such as signs or menus for restaurant foods, provides additional transparency for consumers.

Hidden Food Allergens and Cross-Contamination 

In some cases, cross-contamination can occur during the production process, or food products can have discreet or hidden allergies contained in their ingredients. For this reason, manufacturers need to follow stringent production protocols and display accurate food labels with clear allergy statements for the consumer to easily detect.

Identifying Hidden Sources

Some food ingredients could contain hidden allergens or derivatives that might not be immediately recognizable by someone grabbing that food product off a shelf in the supermarket. Examples of these hidden allergens include:

• Common Ingredient Derivatives: Ingredients like casein (from milk) or lecithin (from soy) are found in some food products. A vulnerable individual not versed in these terms could easily develop an allergic response to a product containing these ingredients. 
• Processing Aids: Agents used in manufacturing, like enzymes or anti-caking agents, may introduce allergens even if they aren’t part of the final ingredient statement.
• Carrier Substances: Substances like maltodextrin or modified starch can sometimes carry allergens like gluten.
• Complex Ingredients: Ingredients with multiple sub-components, like additional flavorings or seasonings, may contain allergens unless specified.

Cross-Contamination Management

To prevent food allergen contamination, manufacturers implement rigorous controls. This includes:

• Production Line Controls: Factories should have separate equipment or dedicated lines for allergenic and allergen-free products to prevent accidental contamination.
• Cleaning Protocols: Comprehensive cleaning of production areas and equipment between different batches must be conducted regularly to ensure minimized cross-contact risk.
• Storage Requirements: Separate storage for allergenic ingredients and non-allergenic ingredients reduces the risk of accidental contamination.
• Staff Training Needs: Employees must be trained and educated in handling allergens carefully while adhering to hand-washing and safety protocols to further protect consumers.

Precautionary Allergen Labeling

Manufacturers should first conduct risk assessments to determine if cross-contact is likely. If cross-contamination risks cannot be avoided, manufacturers should use precautionary labeling:

• “May Contain” Statements: Manufacturers must use statements like “may contain nuts” or “may contain dairy” only if cross-contamination cannot be avoided through controls or cross-contamination management.
• Format and Positioning: Allergen warnings should be prominent and consistent on labels so reading food labels can be done quickly and easily.
• Documentation Requirements: Thorough documentation of risk assessments, labeling practices, and controls needs to be provided and up-to-date as this ensures food product-regulated compliance and consumer trust.

Best Practices for Compliance

Following best practices can help manufacturers meet legal obligations and reduce the risk of allergen-related incidents. These are key areas to focus on for effective management and compliance:

Quality Control

Quality control measures ensure the accuracy of allergen labeling and minimize risks:

• Ingredient checking: Verify supplier specifications for all ingredients to identify potential allergens.
• Label verification: Confirm that product labels clearly and accurately reflect allergen content.
• Batch control: Implement robust systems to trace and manage batches to prevent cross-contamination.
• Documentation requirements: Keep detailed records of finances and documents as required by regulatory bodies.

Supplier Management

Collaboration with suppliers is critical to allergen management:

• Allergen specification: Demand detailed allergen information from suppliers you partner with.
• Audit procedures: Conduct regular audits to ensure suppliers comply with allergen handling and manufacturing practices.
• Change notification: Require suppliers to notify you of any changes in ingredient composition or processes.

Free-From Claims

«Free-from» claims, particularly for allergens like gluten, require rigorous adherence to standards:

• Requirements for use: Ensure claims are based on verifiable scientific evidence.
• Testing protocols: Regularly test products for allergen presence, especially for gluten-free claims.
• Documentation needs: Record testing outcomes and maintain evidence to substantiate claims.
• Special considerations for gluten-free claims: Follow strict guidelines set by the Food Standards Agency.

How Food Label Maker Simplifies Compliance 

Managing compliance with food allergen labeling can be complex, but tools like Food Label Maker simplify the process. Here’s how it helps:

• Allergen identification: Their platform quickly and automatically identifies major food allergens in ingredient lists.
• Compliance checking features: Validates labels against current UK food labeling laws.
• Documentation storage: Securely stores records related to allergen management and testing.
• Update notifications: Stay informed of regulatory changes with timely alerts.
• Training resources: Access materials via their Regulatory Hub or their blog to educate staff and manufacturers on food allergy requirements.
• Support services: They offer assistance from their selection of expert nutritionists for troubleshooting and compliance advice.

With Food Label Maker, food businesses can streamline compliance, enhance consumer safety, and focus on delivering quality products.

Conclusion

Labeling food allergens is essential for protecting vulnerable consumers and building trust in your brand. Key responsibilities include clear allergen declarations, robust staff training, cross-contamination prevention, and diligent documentation maintenance.

By prioritizing consumer safety and adhering to good manufacturing practices, food producers can meet regulatory standards while reducing risks. Looking ahead, evolving regulations may bring additional challenges, but tools and software aimed at food allergy safety provide valuable support in navigating these complexities.

Visit Food Label Maker’s website and explore their features to take the next step in ensuring compliance and safeguarding human health.