When you are responsible for quality in a workshop, allergens are not "bureaucracy": they are one of the few things on which you cannot afford a mistake, because the health of the people who eat your products is at stake. In the years I followed quality in production I learned one thing: the problem is almost never not knowing the law. The problem is keeping everything up to date while the workshop is running at full pace.
European legislation identifies 14 substances that must always be declared. Here you will find the list, how they are shown on the label (and on loose products) and the mistakes that, in practice, happen most often.
What the law asks for, in plain words
The obligation comes from EU Regulation 1169/2011. In day-to-day terms: if one of these 14 allergens is present in the product — even as a derivative of an ingredient — it must be declared. Always, regardless of the quantity. There is no threshold "below which it is not needed".
The 14 allergens to always keep an eye on
- Cereals containing gluten — wheat, rye, barley, oats, spelt, kamut and their hybridised strains, and derived products.
- Crustaceans and products based on crustaceans.
- Eggs and products based on eggs.
- Fish and products based on fish.
- Peanuts and products based on peanuts.
- Soya and products based on soya.
- Milk and products based on milk (including lactose).
- Tree nuts — almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts and derived products.
- Celery and products based on celery.
- Mustard and products based on mustard.
- Sesame seeds and products based on sesame seeds.
- Sulphur dioxide and sulphites at concentrations above 10 mg/kg or 10 mg/litre (expressed as SO₂).
- Lupin and products based on lupin.
- Molluscs and products based on molluscs.
The point on which I have seen people stumble most often is precisely the last word of many entries: derivatives. Lactose is "milk", lecithin is "soya", malt is "barley" and therefore gluten. When you check a recipe you cannot stop at the name of the ingredient: you have to trace it back to the source substance. That is where the forgotten allergen hides.
How to show them on the label
On prepacked products, allergens must be written within the list of ingredients and highlighted, so that they stand out at a glance from the rest — usually in bold, but capital letters or a different typeface are fine too, as long as the contrast is clear. The idea is simple: someone who is allergic must be able to find the word without having to look for it.
On loose or non-prepacked products (sales counter, delicatessen, catering) the information remains mandatory, but you can provide it in another way: a sign, a register that customers can consult or a menu listing the allergens of each preparation.
Real allergens and "traces": they are not the same thing
One thing is the allergen present as an ingredient — mandatory, it goes on the label highlighted. Another thing is possible cross-contamination, that is, the allergen that could end up in the product because you work in the same environment or with the same tools. Wordings such as "may contain traces of…" are there to flag that risk.
In the workshop I have often seen the temptation to write "may contain traces of everything" to be on the safe side. It is a mistake: the information no longer says anything useful, and above all it does not replace the real control of contamination between one production run and the next. The wording is voluntary; the control in production is not.
The mistakes that happen most often in production
- Forgetting derivatives. Lecithin, lactose, barley malt, flavourings that contain allergens: all of them must be traced back to the source substance.
- Not updating when the recipe or the supplier changes. You change the supplier of a semi-finished product and there is a new allergen inside: if the label stays the same as before, it is wrong. In a working workshop this happens more often than you would think.
- Not highlighting the allergen. Writing it among the ingredients without bold (or other emphasis) is not enough to meet the obligation.
- Managing everything from memory. With dozens of products, keeping in mind which allergen is in which recipe is the surest way to get it wrong sooner or later.
How to keep it under control without going crazy
The safest way I have found is not to manage allergens "separately", but to have them come straight from the recipe: that way, every time you change an ingredient, the declaration updates itself. This is exactly what KoreLab's automatic allergen management does: the 14 allergens are collected from the ingredients and reported, already highlighted, in the technical sheet prepared under EU Reg. 1169/2011. You change an ingredient and the allergens are recalculated from the recipe; a sheet that has already been issued is flagged "to be updated" and you regenerate it with the new data, without starting over.
You can try it for free on your first products: create a free account.
In short
The 14 allergens of EU Reg. 1169/2011 must always be declared when present, derivatives included: on the label in the list of ingredients and highlighted, with a sign or register for loose products. But theory is the easy part. The real mistakes arise in production — a derivative that slips through, a label not updated after a supplier change — and they are avoided in only one way: by deriving the allergens from the recipe, so they always stay correct without depending on memory.