Tree Nut Allergen Labelling: A Complete FAQ for Food Producers
Tree nut allergen labelling generates more questions than almost any other allergen category. Here are the most common questions answered for food producers in the UK and US.
Tree nut allergies are among the most common and most serious food allergies. They also generate more labelling questions than almost any other allergen category, partly because of the variety of tree nuts and the need for specific declaration.
Which nuts are classified as tree nuts for labelling purposes? In the UK (under retained EU law), "tree nuts" as an allergen category includes: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts. Chestnuts and coconut are also classified as tree nuts for labelling purposes. Peanuts are a legume and are separately declared.
Do I need to name each tree nut specifically? In the UK, you must name the specific tree nut within the ingredient list (e.g., "almonds" or "cashew nuts"). In the US under FALCPA, each tree nut must also be declared by its specific common name.
What about coconut? Coconut is classified as a tree nut for allergen labelling purposes in both the UK and US, despite being botanically a fruit. It must be declared as a tree nut allergen where present.
What if my product is made on shared equipment with tree nuts? If there is a meaningful cross-contact risk, a precautionary statement (e.g., "May contain traces of almonds") should reflect the specific nut involved, not just "tree nuts."
Is pine nut a tree nut? Yes. Pine nuts (also called pignoli or piñon) are a tree nut for labelling purposes.
How Should Tree Nuts Be Emphasised in Your Ingredient List?
Under UK retained food law, allergens must be emphasised within the ingredient list using a typographic format that sets them apart clearly from surrounding text. This typically means using bold, italics, underlining, or a contrasting colour. The emphasis must be applied directly to the allergen name itself — for example, "mixed trail mix (almonds, sunflower seeds, cashew nuts)" — and must be consistent across all allergen declarations on the same label. Using emphasis selectively or inconsistently can create compliance risk and customer confusion.
It is important to remember that emphasis alone is not sufficient if the allergen name itself is ambiguous or abbreviated. You cannot write "mixed nuts (may include tree variety)" and consider your obligation met. Each specific tree nut present must be named in full in plain English, and that name must be emphasised. Common abbreviations or trade names are not acceptable substitutes for the recognised common names listed in the legislation. Almonds must appear as "almonds," not as "prunus dulcis" or a branded ingredient reference.
For online retailers selling through Shopify, the same principle applies to digital product listings. The allergen information presented on a product page must match what appears on the physical label, and it should be just as legible and clearly formatted. Failing to align your online and on-pack declarations creates inconsistency that may draw scrutiny from enforcement bodies and erodes trust with customers who rely on that information to make safe purchasing decisions.
What Are the Rules Around Compound Ingredients Containing Tree Nuts?
Compound ingredients — pre-made mixtures used as components in your product, such as a bought-in pastry, sauce, or flavouring — can introduce tree nut allergens in ways that are easy to overlook. Under UK food labelling law, if a compound ingredient makes up less than 2% of the finished product, you are generally exempt from listing its sub-ingredients. However, this exemption does not apply to allergens. If a compound ingredient contains a tree nut allergen, you must still declare that allergen in the ingredient list of your finished product, regardless of the quantity of the compound ingredient used.
This is a common area of non-compliance for small food producers who receive compound ingredients from suppliers without fully scrutinising the allergen documentation. A bought-in caramel sauce, for example, may contain hazelnut paste as a minor flavouring component. If you incorporate that sauce into your product, hazelnuts must appear in your ingredient list with the appropriate emphasis. Requesting up-to-date allergen declarations and full ingredient specifications from every supplier is not optional — it is a fundamental part of managing your legal obligations.
When reformulations occur on the supplier side, allergen content can change without obvious notification. Best practice is to build a review process into your supplier relationships, requiring written notification of any recipe or ingredient change and updating your own labels accordingly before the affected batch goes to market. A reliable system for tracking ingredient-level allergen data is essential for any producer working at scale, and tools like Allergen Matrix can help centralise that information for your Shopify product catalogue.
How Do You Handle Tree Nut Allergens in Flavourings and Processing Aids?
Flavourings are another area where tree nut allergens can enter a product unexpectedly. Natural flavourings derived from tree nuts — such as almond extract or marzipan flavouring — must be declared as allergens in the ingredient list. You cannot list them simply as "flavouring" or "natural flavouring" if they contain or are derived from a regulated allergen. The source must be named, so "almond flavouring" or "flavouring (contains almonds)" would both be acceptable formats, but an unspecified "flavouring" entry would not meet the standard where a tree nut allergen is present.
Processing aids present a slightly different consideration. Processing aids are substances used during manufacture that are not present in the finished product in functional form. In theory, if a processing aid is genuinely removed or rendered inactive before the product is packaged, it may not require declaration. However, if there is any residual presence of a tree nut allergen from a processing aid, it should be treated as an ingredient for labelling purposes. The burden of proof rests with the producer to demonstrate that the substance is truly absent from the finished product, which is a difficult standard to meet in practice.
For producers making flavoured baked goods, confectionery, or snacks, it is worth auditing every single flavouring used to confirm its allergen status in writing with your supplier. Do not rely on category descriptions or informal assurances. Flavouring formulations can and do change, and a product that was previously free from tree nut allergens may no longer be so after a supplier updates their recipe. Keeping documented records of these supplier confirmations also supports your due diligence position if a compliance question ever arises.
What Should You Know About Tree Nut Labelling for Natasha's Law and PPDS Foods?
Natasha's Law, which came into force in England, Wales, and Northern Ireland in October 2021, introduced full ingredient labelling requirements for prepacked for direct sale (PPDS) foods. Before this legislation, many foods sold directly to consumers in the same premises where they were made — such as sandwiches, cakes, and pastries — could be sold with minimal allergen information on the packaging. Under Natasha's Law, all PPDS foods must carry a full ingredient list with allergens emphasised, bringing them in line with the requirements for pre-packaged foods.
For producers of PPDS foods containing tree nuts, this means you can no longer rely on verbal communication alone, point-of-sale notices, or staff knowledge to convey allergen information. Every individual package must carry the full ingredient declaration with the specific tree nut clearly emphasised. If you bake and sell hazelnut brownies in individual cellophane bags from your premises, each bag must carry a label showing "hazelnuts" in bold within the ingredient list. The legislation applies even to very small producers and sole traders, and enforcement has increased since the law came into force.
Online food businesses that offer PPDS-style products dispatched directly to customers should pay particular attention to how their digital listings and physical packaging align. The allergen information visible on your Shopify product page sets customer expectations, and the label on the item they receive must be consistent with that. Discrepancies — even minor ones — can undermine consumer trust and create legal exposure. Reviewing your full product range against Natasha's Law requirements is a worthwhile investment of time, particularly if your catalogue has grown organically without a formal labelling audit.
How Should You Approach Tree Nut Labelling When Exporting?
Exporting food products adds a layer of complexity to tree nut allergen labelling because requirements vary significantly between markets. In the European Union, the regulatory framework for allergen labelling is set out in EU Food Information Regulation 1169/2011, which mirrors much of the UK's retained approach but is now a separate legal instrument. In the United States, FALCPA governs allergen declarations, and the FASTER Act of 2021 added sesame as a ninth major allergen, reflecting how these frameworks continue to evolve independently of one another.
For tree nuts specifically, the list of regulated nuts can differ slightly between jurisdictions, and the declaration formats — where the allergen name must appear, whether a "Contains" statement is required, and how emphasis must be applied — are not identical. Producers exporting to multiple markets therefore need separate label versions for each destination market, reviewed against the current legislation in that jurisdiction. Assuming that a UK-compliant label will automatically satisfy US or EU requirements is a risk that has caught out many small producers expanding internationally.
Beyond the ingredient list, export markets may also have specific requirements around font size, language, and the placement of allergen information on the packaging. Working with a food labelling consultant or regulatory specialist is advisable when entering a new export market, particularly one with active enforcement. Maintaining a well-organised digital record of your allergen data for each product — accessible and exportable — makes the process of adapting labels for different markets significantly more manageable.
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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.