Food allergen labels explained: US, UK and EU rules compared

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In the US, federal law requires most packaged food to declare nine major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. In the UK and the EU the list is fourteen, which adds celery, mustard, lupin, sulphites and mollusks and widens wheat to the gluten cereals: wheat, rye, barley and oats. In all three places the allergen has to be named in plain words on the pack.

What isn't standardized is everything around that. “May contain” is voluntary on both sides of the Atlantic, with no agreed wording or threshold. Restaurants and loose food follow different rules. And labels change. So the method is the same wherever you shop: read the whole label every time, and treat a precautionary statement as a real warning.

The three lists side by side

Here are the lists in one place. The US column follows the FDA's nine major food allergens. The EU and UK columns follow the fourteen allergens in Annex II of Regulation (EU) No 1169/2011 and the UK Food Standards Agency's guidance.

Read down the US column and the gaps are plain: mollusks, celery, mustard and lupin are not major allergens there, and sulphites are handled by their own rule. Two differences are subtler. A barley or rye ingredient triggers an allergen declaration in the UK and EU but not in the US, where only wheat does. And the named tree nuts differ: the FDA's list runs to 12, the EU's to eight.

The five extras aren't exotic. They sit in ordinary weeknight cooking, which matters if you buy imported food, travel, or cook for someone who was diagnosed under one system and shops under another. In our catalog of 148 dinners, celery alone carries a flag on 57, mostly through broth.

Reading a US label: nine allergens, one recent addition

US allergen labeling rests on the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA), which applied to any food labeled on or after January 1, 2006. It named eight major allergens. Sesame became the ninth under the FASTER Act, signed on April 23, 2021, with the requirement taking effect on January 1, 2023.

The law covers most packaged foods but not everything. It excludes meat, poultry and egg products (USDA regulates those), alcoholic beverages under the Alcohol and Tobacco Tax and Trade Bureau, raw agricultural commodities, highly refined oils, and most food sold at retail or in food service that isn't prepackaged with a label. The definitions also move. In January 2025 the FDA published a revised edition of its allergen guidance that shortened the tree nuts that count from 23 to 12, with coconut no longer among them, and widened “milk” to include milk from other ruminants such as goats and sheep, and “egg” to include eggs from birds other than chickens. One more rule helps if you worry about hidden ingredients: FALCPA applies to flavorings, colorings and incidental additives, so an allergen inside a “natural flavor” still has to be declared.

Reading a UK or EU label: fourteen, emphasized

The EU and UK take a different route. Instead of a separate line, the allergen has to be emphasized inside the ingredient list, by font, style or background color. The FSA gives bold, italics, contrasting colors and underlining as examples, and says allergenic ingredients must be emphasized every time they appear. An ingredient such as whey has to point back to milk, and tofu to soy.

Where a product has no ingredient list, as with many alcoholic drinks, the label uses the word “contains” followed by the allergen. And loose food is covered. In the EU, allergen information must be provided for food sold without packaging, in restaurants, cafés and at deli counters. It can be given verbally, but there must be a clear signpost to how you get it, and it has to be available in writing on request. The FSA says the same for the UK: when you eat out or order a takeaway, the restaurant or café must provide allergen information.

What “may contain” means, and what it doesn't

Precautionary allergen labeling, the technical name for “may contain” and “made in a facility that also processes,” is voluntary in the US, the UK and the EU. It exists because of cross-contact, when a food that doesn't contain the allergen as an ingredient meets it on shared equipment or surfaces. The FDA says these statements are not legally required and lack uniformity, and it has said they are not to be used instead of good manufacturing practices. In a 2013–2014 FDA survey of dark chocolate products, the type of advisory statement did not correlate with the presence or absence of the allergen.

Regulators are still working on it. The FDA has not established thresholds for any major food allergen, and it held a public meeting on the subject in February 2026. The EU has no harmonized rule either, and the European Commission has been consulting on uniform conditions for these statements. The EU's own guidance says they must rest on a thorough risk assessment, and the FSA says the same: use one only if the risk of cross-contamination is real and cannot be removed.

So what should a shopper do with the line? Take it as the manufacturer's own warning, and don't read its absence as a guarantee either. If you're feeding someone with an allergy, ask your allergist how to handle products with advisory statements. Tonight's Strict setting takes the same cautious view: it leaves out dishes that may carry traces.

Natasha's Law, restaurants and loose food

Natasha's Law is the informal name for the UK's rules on food prepacked for direct sale, or PPDS: food that is packaged at the same place it is offered or sold and is already in its packaging before you order or choose it. Think of a sandwich made and wrapped in the shop. Since October 1, 2021 that food must carry a label with the name of the food and a full ingredient list, with the 14 allergens emphasized.

The law is named for Natasha Ednan-Laperouse, who was 15 when she died on July 17, 2016 after eating a baguette bought at an airport. Sesame seeds were baked into the dough, and the packaging did not list sesame. The FSA's guidance for England, Northern Ireland and Wales calls the requirements Natasha's Law, and Food Standards Scotland has its own guidance with the same October 2021 start.

The US has no equivalent in FALCPA. Most food served in restaurants isn't covered by it, and for unpackaged items the FDA's advice is to ask store personnel for allergen information. Ask specifically, every visit, since a menu that was right last month may not be right now.

Labels change, so read them every time

The FDA's advice is to check the label on every purchase, because a product's ingredients can be changed at any time. The sesame rule shows why. In December 2022, ahead of the January 2023 deadline, FARE said it was disappointed and concerned that many baking companies were intentionally adding sesame flour to their products to avoid the cost of cleaning their lines. Sesame flour is invisible to the eye. A bread that was sesame-free last year may not be now, and the label is the only way to find out.

One more distinction. “Gluten-free” is its own claim, with its own limit: below 20 parts per million of gluten in the US, and 20 ppm or less in the UK. An allergen declaration is about a named allergen such as wheat. The two overlap but aren't the same, so ask your doctor which one matters for you.

Tonight's recipe flags are a best effort. They cover the US nine and go on to celery, mustard, sulphites and other items from the UK and EU list, and they lean toward leaving a dish out. They're checked ingredient by ingredient, but they can't see the brand you actually bought, which is why the pack in your hand has the last word.

To go further, Allergies are rules, not suggestions explains how the check works, How Tonight decides puts it in the wider order of things, and cooking for mixed diets covers tables where one dinner has to suit everyone. Tonight is a planning tool, not medical advice, and the FAQ says so too. Next time you shop, read the allergen line before you read anything else on the pack.