Top 10 Allergen Labelling Mistakes Food Businesses Make Online
From outdated information to missing sub-ingredient checks, these are the most common allergen labelling mistakes online food businesses make — and how to fix them.
Top 10 Allergen Labelling Mistakes Food Businesses Make Online
Allergen labelling mistakes are not just compliance failures — they are safety failures. For the estimated 2 million people living with a food allergy in the UK, and the 32 million in the US, an error in your allergen information could trigger an allergic reaction ranging from discomfort to anaphylaxis. Online food businesses face particular challenges because the label-to-customer journey involves multiple touchpoints: product page, order confirmation, packaging, and delivery note.
Here are the ten most common allergen labelling mistakes food businesses make online, and how to fix them.
1. Not Listing Allergens at All on Product Pages
The most fundamental mistake: relying on the physical label to carry all the allergen information without displaying it on your website. Under UK FIC regulations, EU Regulation 1169/2011, and US FDA guidance, allergen information must be available before purchase for food sold online. A customer ordering on your Shopify store cannot see the label — you must bring the label to them.
Fix: Display full allergen information on every product page, clearly formatted and easy to find.
2. Incomplete Sub-Ingredient Checking
You know your primary ingredients. But have you checked every sub-ingredient? A bought-in vegetable stock powder might contain celery. A spice blend might contain mustard. A glaze might contain wheat. FALCPA and EU regulations require you to declare allergens present in sub-ingredients, not just top-level ingredients.
Fix: Obtain full ingredient declarations and allergen matrices from every supplier. Review sub-ingredients systematically for every recipe.
3. Outdated Information After Recipe Changes
A supplier changes their formulation. You switch to a new brand of soy sauce. You add a new ingredient to improve flavour. Any of these changes can introduce a new allergen — or remove one — without your website or packaging reflecting the change.
Fix: Build a process that links recipe changes to label and website updates. No recipe change should be approved without a corresponding review of allergen declarations.
4. Missing Allergens Hidden in "Natural Flavours" or "Spices"
Collective terms like "natural flavourings," "spices," "herbs," or "seasonings" can conceal allergens. Under FALCPA, allergens present in flavours or other ingredients must be declared — they cannot be hidden behind collective names. Under EU and UK law, the same applies.
Fix: Require full ingredient breakdowns for any bought-in flavour, seasoning, or blend. Do not accept "proprietary formula" as a reason to omit allergen information.
5. Incorrect Emphasis on Allergens in Ingredients Lists
EU and UK law requires allergens to be emphasised — typically in bold — within the ingredients list. Simply including the allergen is not enough if it is not distinguishable at a glance. A customer scanning quickly for their allergen may miss it if it looks the same as every other ingredient.
Fix: Audit your ingredients list formatting. Every allergen should be clearly bolded or otherwise emphasised, following the legal requirements for your market.
6. Using "May Contain" as a Blanket Disclaimer
Some businesses add "may contain all 14 allergens" or an equivalent blanket statement to every product to avoid the work of proper allergen assessment. This is not only unhelpful to allergic consumers — it may not satisfy legal requirements if it is used in place of proper allergen management, and it effectively prices out every allergy-affected customer from your entire range.
Fix: Use precautionary allergen labelling only where a genuine, assessed cross-contact risk exists. Be specific about which allergens are involved.
7. No Allergen Information on Confirmation Emails or Delivery Notes
A customer may not save their order confirmation, or they may be ordering for someone else who is not the one who read the product page. Allergen information should be reiterated at every key touchpoint — confirmation email, delivery note, and packaging label.
Fix: Include a summary of allergen information in your order confirmation emails and delivery notes. Your packaging must carry complete label information.
8. Assuming B2B Customers Don't Need Allergen Information
If you sell wholesale to offices, caterers, or food service businesses, you might assume that allergen responsibility passes to them. In many cases, it does — but you still have obligations to provide accurate allergen information to your B2B customers so they can discharge their own duties. Failing to do so leaves them — and their end consumers — exposed.
Fix: Provide full allergen declarations with every wholesale order, ideally as part of your product data sheet or delivery documentation.
9. Not Training Staff Who Handle Allergen Enquiries
A customer calls or emails to ask about allergens. The staff member who responds gives incorrect or incomplete information, either because they don't know the products well or because the internal information is not easily accessible. This is a real risk in businesses where allergen data lives in a spreadsheet that only one person can find.
Fix: Make allergen data accessible to everyone who deals with customer enquiries. Consider using a centralised allergen management tool that all staff can access.
10. Ignoring Cross-Contact Risks in Shared Facilities
You might make a nut-free product — but if your facility also handles nuts and your cleaning procedures haven't been validated to eliminate cross-contact risk, your nut-free claim is not defensible. Customers with severe nut allergies may rely on your claim and suffer consequences.
Fix: Conduct a proper allergen risk assessment for your facility. Validate your cleaning procedures. Only make "free from" claims for allergens you can genuinely control.
Why Online Stores Face Greater Allergen Risk Than Physical Shops
Brick-and-mortar food businesses benefit from direct human interaction at the point of sale. A customer with a sesame allergy can ask a question in person, and a trained staff member can consult the recipe card or packaging on the spot. That immediate, tactile feedback loop simply does not exist in an online environment. When a customer adds a product to their basket on your Shopify store, there is no counter conversation, no physical label to pick up, and no opportunity for spontaneous clarification unless your product page proactively provides every piece of information they need.
The consequences of this distance are significant. Research consistently shows that food-allergic consumers spend more time reading information online than in-store, precisely because they cannot rely on staff interactions. If your product page buries allergen information below lengthy marketing copy, or formats it in a way that is difficult to scan, customers may either miss it or make assumptions. Both outcomes carry real risk. The responsibility for clear, accessible, pre-purchase allergen disclosure sits entirely with the merchant — and that responsibility intensifies with every new product you add to your catalogue.
The multi-channel nature of online retail compounds the problem further. Many Shopify merchants list products across their own storefront, a marketplace, and social commerce channels simultaneously. Each platform has its own product description format, character limits, and display conventions. An allergen statement that displays correctly on your Shopify product page may be truncated on a marketplace listing or absent entirely from a social shopping tag. Maintaining consistency across all channels requires a centralised source of allergen truth — not a copy-and-paste approach that breaks the moment you update one channel and forget the others. Using Allergen Matrix to manage this centrally is one of the most effective steps an online food merchant can take.
The Legal Landscape: What UK and US Food Businesses Must Know
The UK Food Information Regulations 2014, incorporating retained EU law from Regulation 1169/2011, require that the 14 major allergens are declared whenever they are present as ingredients or sub-ingredients in a prepacked food. Following Natasha's Law, which came into force in October 2021, prepacked for direct sale foods — such as products made and packaged on the same premises where they are sold — must carry a full ingredients list with allergens emphasised. Online sellers must provide allergen information prior to the completion of purchase and confirm it at the point of delivery. There is no grey area here: pre-purchase disclosure is a legal requirement, not a best practice recommendation.
In the United States, the Food Allergen Labelling and Consumer Protection Act of 2004 mandates declaration of the eight major allergens: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans. The FASTER Act of 2021 added sesame as a ninth major allergen, with compliance required from January 2023. For online food businesses operating across both markets — or planning to expand — the practical implication is that your allergen management system needs to be flexible enough to handle different regulatory requirements without creating two completely separate workflows. A single centralised allergen data system with market-specific display rules is far more sustainable than maintaining parallel manual processes.
Penalties for non-compliance are not theoretical. UK enforcement authorities can issue improvement notices, prohibition orders, and prosecutions under the Food Safety Act 1990. In the US, the FDA can initiate recalls and take enforcement action against businesses that mislabel allergens. Beyond regulatory penalties, the reputational and human cost of an allergen incident — particularly one that results in hospitalisation — can be devastating for a small food business. Compliance is not a bureaucratic burden; it is the baseline standard of care that every food business operating online owes to its customers.
How to Build an Allergen Review Process That Actually Works
The gap between knowing your allergen obligations and consistently meeting them at scale is almost always a process problem rather than a knowledge problem. Most small food businesses understand that they need to declare allergens — the failure point is the absence of a structured, repeatable process that ensures allergen data is reviewed, updated, and published every time something changes. Building that process starts with defining clear ownership: one named person, or one named role, is responsible for allergen accuracy. Without explicit ownership, allergen review falls between responsibilities and gets missed during busy periods or staff transitions.
Supplier management is the second critical process component. Every ingredient you buy carries allergen risk, and your supplier's formulation can change without prior notice. Building a supplier review calendar — where you proactively request updated specifications at least annually, and require notification of any reformulation — gives you a structured mechanism to catch changes before they reach your product pages. Pair this with a master ingredient register that records the allergen status of every bought-in ingredient, updated whenever a new specification arrives, and you have the foundation of a defensible allergen management system rather than a reactive one.
The third component is a pre-launch checklist for every new product. Before any new product goes live on your Shopify store, it should pass through a documented checklist that confirms: full sub-ingredient allergen review completed, allergen emphasis applied correctly in the ingredients list, precautionary labelling assessed and documented, product page allergen display verified, and confirmation email template updated if necessary. This checklist does not need to be complex — a simple shared document or task in your project management tool is sufficient. What matters is that it is mandatory, not optional, and that no product launches without it being completed and signed off.
Fixing Allergen Labelling at Scale
As your product range grows, maintaining accurate allergen information manually across your website, packaging, and order communications becomes error-prone. The best solution is a system that holds your allergen data centrally and surfaces it consistently across every touchpoint.
SafeServe, our allergen labelling app for Shopify, and Allergen Matrix, our compliance display tool, work together to ensure your allergen information is always accurate, always visible, and always up to date.
Try Allergen Matrix free at saltai.app — no credit card required.
SaltAI Team
SaltAI builds focused Shopify apps for food merchants and general merchants. Every app is tested in production at a real food store — including Vanda's Kitchen — before it ships.