The 14 Allergens Under UK Law: A Complete Reference Guide

UK retained food law (derived from EU FIC Regulation 1169/2011) requires declaration of 14 major allergens in food. Here is a complete reference for each allergen, including the ingredients that trigger the declaration requirement.

The 14 Allergens

1. Celery — includes celery stalks, leaves, seeds, celeriac, and celery salt. Present in many stocks, soups, and spice blends. 2. Cereals containing gluten — wheat, rye, barley, oats (subject to contamination risk), spelt, kamut. Triggers the gluten declaration. 3. Crustaceans — shrimps, prawns, crabs, lobster, crayfish, barnacles. Must declare specific type. 4. Eggs — all bird eggs and egg products. 5. Fish — all fish, must declare specific type. Fish hydrolysates and surimi count. 6. Lupin — lupin flour and seeds, used in some gluten-free and high-protein products. Growing use in plant-based foods. 7. Milk — all mammalian milk including cow, sheep, goat; butter, cream, cheese, yoghurt, whey, casein, lactose. 8. Molluscs — clams, mussels, oysters, scallops, squid, octopus, snails. Must declare specific type. 9. Mustard — mustard plant seeds, leaves, flowers, oils; mustard powder and paste. 10. Peanuts — groundnuts and products thereof. 11. Sesame — sesame seeds, sesame oil, tahini, sesame paste. 12. Soybeans — soy in all forms including tofu, tempeh, miso, soy sauce. 13. Sulphur dioxide and sulphites — at concentrations above 10mg/kg in the finished product. Common in dried fruits, wines, and preserved foods. 14. Tree nuts — must declare specific type: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts, Queensland nuts.

Key Differences from US FALCPA

UK law requires 14 allergens vs FALCPA's 9. The additional UK allergens not covered by FALCPA are: celery, lupin, molluscs, mustard, and sulphur dioxide/sulphites.

How Allergen Declaration Works in Practice

Under UK retained food law, allergens must be emphasised relative to the surrounding ingredient text. The standard method is to print the allergen name in bold, a different typeface, or a contrasting colour within the full ingredients list. You cannot simply list allergens separately in a "Contains" box and consider the obligation met — the emphasis must appear within the ingredients declaration itself. This applies to pre-packed food sold through any channel, including online Shopify stores where product descriptions serve as the legal label.

For pre-packed for direct sale (PPDS) food — the category that Natasha's Law directly addressed — the full ingredients list with emphasis became mandatory in England, Wales, and Scotland from 1 October 2021. PPDS covers items packaged at the same premises from which they are sold: think bakery goods, deli items, and meal kits prepared and dispatched by the same business. If your Shopify store sells products you prepare and pack yourself before dispatch, PPDS rules almost certainly apply to your operation, and full ingredient labelling is not optional.

Loose food sold without any packaging — such as items sold at markets or served at food stalls — follows separate rules requiring allergen information to be available on request, either verbally or via written notices. However, as soon as you apply any wrapping or container before the customer receives it, the food is likely to be classified as PPDS rather than loose. For food businesses selling across multiple formats, keeping a single up-to-date allergen matrix for each product makes it straightforward to populate labels, online listings, and staff information sheets from one reliable source.

The Allergens Most Commonly Missed by Food Businesses

Celery is frequently overlooked because its presence in a product is not always obvious. Celery salt used in spice blends, stock powders, and seasoning mixes can easily be listed under a generic "spices" or "seasoning" descriptor by an upstream supplier, meaning the allergen does not appear to be present until a business reviews full technical data sheets from their ingredient suppliers. Any product containing ready-made stock, bouillon, or a spice blend should be investigated carefully before an allergen-free claim is made.

Lupin is another allergen that catches food businesses off guard, particularly those selling gluten-free or high-protein products. Lupin flour has become increasingly common as a wheat substitute in baked goods and as a protein booster in pasta, bread, and plant-based meat alternatives. Customers with peanut allergies are at elevated risk of cross-reacting to lupin due to structural similarity between the proteins, which makes accurate declaration especially important. Always request allergen declarations specifically for lupin when sourcing novel ingredients for reformulated or health-positioned products.

Sulphur dioxide and sulphites cause confusion because the declaration threshold — above 10mg/kg or 10mg/litre expressed as SO₂ — applies to the concentration in the finished product, not in individual ingredients. If multiple sulphite-containing ingredients each contribute a small amount, the combined level in the finished product could cross the threshold even when no single ingredient appears problematic in isolation. Dried apricots, wine, cider vinegar, and certain pre-made sauces are common contributors. Food businesses should calculate cumulative sulphite levels across all ingredients rather than reviewing each ingredient in isolation.

Understanding "May Contain" and Precautionary Allergen Labelling

Precautionary allergen labelling (PAL) — statements such as "may contain traces of nuts" — is not currently governed by specific positive law in the UK in the same way as intentional allergen declaration. The Food Standards Agency has published guidance encouraging businesses to use PAL only when a genuine, assessed risk of cross-contamination exists, and to avoid using it as a blanket disclaimer that undermines its credibility for allergic consumers. Overuse of "may contain" statements reduces trust among the very customers who rely on them most, and it can also deter purchases from people who could safely consume the product.

The practical standard applied by enforcement authorities and the food industry is that PAL should reflect a documented risk assessment of your production environment, cleaning procedures, ingredient storage, and shared equipment. If your kitchen processes peanuts on the same surfaces used for peanut-free products, and cleaning validation has not been carried out, a "may contain peanuts" statement is both legally defensible and genuinely informative. If peanuts are never present on your premises, the same statement is misleading and potentially in breach of food information regulations because it provides false information to consumers about the nature of the food.

For online food retailers using Shopify, precautionary allergen labelling needs to appear in the product listing as well as on the physical label, because the online description constitutes pre-contractual information that the consumer uses to make their purchase decision. A customer with a severe allergy reading your product page cannot inspect the physical packaging before committing to buy. Keeping your online allergen information synchronised with your physical labels is not just good practice — it is a legal requirement under the Distance Selling provisions of UK food information law. Allergen Matrix is designed to make that synchronisation automatic across your Shopify catalogue.

Natasha's Law and What Changed for Online Food Sellers

Natasha's Law — formally the amendment to the Food Information Regulations 2014 — was named after Natasha Ednan-Laperouse, who died in 2016 after suffering an allergic reaction to a sesame-containing baguette that carried no allergen information on its packaging. The legislation that followed tightened labelling requirements specifically for PPDS food, closing a gap that had allowed businesses to sell pre-packaged items with minimal or no ingredient information. For online food sellers, the law reinforced the principle that consumers deserve full ingredient transparency regardless of whether they are buying in person or through a digital storefront.

The practical impact on Shopify food stores is significant. Any merchant selling homemade baked goods, artisan condiments, meal kits, or prepared foods they have packaged themselves must now provide a full ingredients list with allergen emphasis on the product label. For products sold online, that same information must be available before the customer completes their purchase — displaying it only on the packaging that arrives after the order is placed is not sufficient. This means product pages, not just fulfilment labels, need to carry complete and accurate allergen information at all times.

Keeping allergen information current across a Shopify catalogue becomes particularly challenging when recipes change, suppliers change, or new products are added frequently. A single ingredient substitution — swapping one brand of stock powder for another, for example — can change the allergen profile of multiple finished products simultaneously. Food businesses that manage allergen information in spreadsheets or document files often discover these gaps only after a complaint or an enforcement visit. Building allergen management into your product workflow from the start, rather than treating it as a labelling task completed once at launch, is the approach that keeps both customers and businesses protected.

Displaying Allergen Information on Your Shopify Product Pages

UK food information law requires that allergen details are available to the consumer before purchase when food is sold at a distance, which includes all Shopify transactions. The information must be provided free of charge and must not require the customer to take additional steps — such as contacting the seller by email or phone — in order to access it. Displaying allergen information clearly on the product page itself is the simplest and most legally robust approach, and it also improves trust and conversion among allergen-aware shoppers, who are often highly engaged and loyal customers when they find a brand they can rely on.

The format of online allergen information does not need to replicate a physical label exactly, but it must be accurate, legible, and complete. A structured allergen table, a clearly formatted "Contains" and "May Contain" section within the product description, or a dedicated allergen information block within the page layout are all acceptable approaches. What matters is that a customer can identify at a glance which of the 14 allergens are present before they add the product to their cart. Consistency between your product pages and your physical labels eliminates the risk of contradictory information reaching the customer through different channels.

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