Cereals containing gluten
Wheat, rye, barley, oats
Crustaceans
Prawns, crab, lobster
Eggs
All forms
Fish
All species
Peanuts
Including oils
Soybeans
Refined oil exempt
Milk
Including lactose
Tree nuts
Almonds, cashews…
Celery
Including celeriac
Mustard
Seeds, oil, flour
Sesame seeds
Including oil
Sulphites
>10 mg/kg SO₂
Lupin
Flour and seeds
Molluscs
Mussels, oysters…
01 — Cereals containing gluten
Legal definition: Wheat (including spelt and khorasan wheat), rye, barley, oats, and their hybridised strains, and products thereof.
Where it hides: Soy sauce (most contain wheat), malt vinegar, some spice blends and seasoning mixes, many processed sauces and gravies, oats contaminated during processing, surimi (imitation crab meat), some ice creams and frozen desserts.
Exemptions: Wheat-based glucose syrups including dextrose; wheat-based maltodextrins; barley-based glucose syrups; cereals used for making alcoholic distillates.
Practical notes: Gluten is the protein complex found in these cereals. Coeliacs react to gliadin (in wheat) and similar proteins in rye and barley. People with wheat allergy may react differently to those with coeliac disease — both groups need disclosure. Oats are included because standard oat products are almost universally cross-contaminated; certified gluten-free oats exist but are a separate product category.
02 — Crustaceans
Legal definition: Crustaceans and products thereof.
Where it hides: Seafood stocks and bouillons, paella and some rice dishes, some Asian condiments and pastes (shrimp paste), Caesar salad dressing, surf and turf dishes, some crisps and flavoured snacks.
Exemptions: None.
Practical notes: Crustaceans include prawns, shrimp, crabs, crayfish, lobster, barnacles, and krill. Reactions can be severe and life-threatening. Notably, crustaceans and molluscs are separate allergen categories — a shrimp allergy does not automatically mean a mussel allergy, but the two categories are often confused.
03 — Eggs
Legal definition: Eggs and products thereof.
Where it hides: Mayonnaise and mayonnaise-based sauces (tartare, aioli, Caesar), pasta (fresh egg pasta), glazed pastries and baked goods (egg wash), some wines and beers (egg white used as fining agent), marshmallows and some confectionery, hollandaise and béarnaise sauces, some ice creams, binding agents in burgers and meatballs.
Exemptions: Egg-based lysozyme used in wine; egg albumin used as a fining agent in wine and cider.
Practical notes: Egg allergy is particularly common in young children, though many outgrow it. Egg white and egg yolk contain different proteins; some people are allergic to one and not the other, though this distinction is not required in labelling. Heating can reduce but not eliminate allergenicity.
04 — Fish
Legal definition: Fish and products thereof, except fish gelatine used as a carrier for vitamin or carotenoid preparations.
Where it hides: Worcestershire sauce (contains anchovies), Caesar salad dressing, some Asian sauces (fish sauce, oyster sauce), bouillabaisse and seafood soups, some pizza toppings, surimi products, some dietary supplements (omega-3 fish oil), certain Bloody Mary mixes.
Exemptions: Fish gelatine used as a carrier for vitamin or carotenoid preparations.
Practical notes: Fish allergy encompasses all finfish species. A person allergic to one species may or may not react to others, but food labelling does not distinguish. Tuna, salmon, and cod are among the most common trigger species. Fish and shellfish (crustaceans/molluscs) are separate allergen categories.
05 — Peanuts
Legal definition: Peanuts and products thereof.
Where it hides: Satay sauce, some curry sauces and pastes, ground nut oil (unrefined), some African and Asian dishes, certain confectionery and snack bars, some mixed nut products (cross-contamination), certain baked goods and cookies.
Exemptions: Refined peanut (arachis) oil and fat.
Practical notes: Peanuts are legumes, not tree nuts, but severe cross-reactions with tree nuts are possible. Peanut allergy is associated with some of the most severe anaphylactic reactions. Unlike some other allergens, peanut allergy is rarely outgrown. Even trace amounts — measured in milligrams — can trigger a severe reaction in sensitised individuals.
06 — Soybeans
Legal definition: Soybeans and products thereof.
Where it hides: Most soy sauce (also contains wheat), miso paste and tofu, edamame, many processed meats (soy protein used as a filler), some bread and baked goods (soy flour), many plant-based dairy and meat alternatives, some infant formulas, Asian noodle dishes.
Exemptions: Fully refined soya oil and fat; natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soya sources; vegetable oils derived from soya plant sterols and sterol esters; plant stanol ester produced from vegetable oil sterols from soya sources.
Practical notes: Soy allergy is common in infants and young children, with many outgrowing it by adulthood. However, adult-onset soy allergy does occur. Soy is increasingly present in processed foods as a cheap protein source, making it one of the most common hidden allergens.
07 — Milk
Legal definition: Milk and products thereof (including lactose).
Where it hides: Butter and ghee (clarified butter, though casein content is very low), casein and caseinate in processed meats and deli products, whey protein in protein supplements and sports foods, many bread and baked goods (milk powder), some margarines, caramel colourings derived from milk, some crisps and snack seasonings, non-dairy creamers (many contain milk protein).
Exemptions: None.
Practical notes: Milk allergy (immune-mediated response to milk proteins, primarily casein and whey) is distinct from lactose intolerance (inability to digest lactose). Both are covered by this allergen category. The regulation does not distinguish between the two. Milk proteins can remain in heavily heated or processed products — ghee and clarified butter contain trace casein and should be disclosed.
08 — Tree nuts
Legal definition: Almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts, and Queensland nuts, and products thereof.
Where it hides: Pesto (pine nuts are not tree nuts under the regulation — but almonds, walnuts, and cashews are sometimes used), marzipan and almond paste, praline and nougat, some curry pastes (cashews), flavoured coffees and syrups (hazelnut), some chocolates and desserts, nut oils used for cooking or dressings, dukkah spice blends.
Exemptions: Nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin.
Practical notes: Note that the regulation specifies eight named tree nuts, not all tree nuts. Pine nuts, coconut, and chestnut are not in Annex II (though some people are allergic to these). Cross-reactions between different tree nuts are common but not universal. Reactions can be severe and anaphylactic.
09 — Celery
Legal definition: Celery and products thereof.
Where it hides: Many spice blends and mixed seasonings, stock cubes and bouillons, some soups and sauces, certain cured meats and sausages, celeriac (root celery) often overlooked as a celery source, some salads (waldorf salad), celery salt.
Exemptions: None.
Practical notes: Celery allergy is more prevalent in Central Europe than in Ireland or the UK. Celery allergens are not destroyed by cooking, meaning cooked celery in soups and stocks is as much a risk as raw celery. Celeriac (celery root) is explicitly included and is a commonly overlooked source.
10 — Mustard
Legal definition: Mustard and products thereof.
Where it hides: Many salad dressings and vinaigrettes, some marinades and pickles, certain spice blends and curry powders, some sausages and processed meats, mayonnaise (some recipes), beer mustard and beer-based sauces, Worcestershire and similar sauces.
Exemptions: None.
Practical notes: Mustard allergy can be triggered by mustard seeds, leaves, flower, oil, and flour. Even very small amounts of mustard can trigger reactions in sensitised individuals. Mustard is commonly present in products where it is not the primary flavour, making it one of the most frequently overlooked hidden allergens.
11 — Sesame seeds
Legal definition: Sesame seeds and products thereof.
Where it hides: Tahini (sesame paste) in hummus, baba ganoush; sesame oil used in Asian cooking; bread rolls and burger buns with sesame topping; some breads with mixed seed coatings; halvah; some Asian condiments and sauces; certain spice blends; some crackers and biscuits.
Exemptions: None.
Practical notes: Sesame allergy is rising in prevalence globally and is increasingly associated with severe reactions. Sesame seeds can appear as an ingredient, as sesame oil or tahini, or as a minor ingredient in spice mixes. Sesame oil — unlike soy and peanut oils — is not exempt under the FIC Regulation.
12 — Sulphur dioxide and sulphites
Legal definition: Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO₂.
Where it hides: Wine (one of the highest sources — typically 100–200 mg/L), beer and cider, dried fruit (especially apricots, raisins, sultanas), pickled vegetables, some fruit juices and soft drinks, certain preserved meats, prawns and shellfish (added to prevent discolouration), some vinegars.
Exemptions: None (but the 10 mg/kg / 10 mg/L threshold applies — products below this do not require disclosure).
Practical notes: Sulphites are preservatives added to many foods and drinks. The 10 mg/kg or 10 mg/litre threshold is important — products below this level do not require allergen disclosure. Reactions to sulphites are more accurately described as intolerances (triggering asthma, urticaria) rather than IgE-mediated allergic responses, though they are included in the regulated list.
13 — Lupin
Legal definition: Lupin and products thereof.
Where it hides: Gluten-free flour blends (lupin flour used as a substitute), some pasta products, certain bread and baked goods, some sauces and soups, plant-based meat products, certain cereal bars and snack products.
Exemptions: None.
Practical notes: Lupin is an increasingly common ingredient in gluten-free products, where it is used as a high-protein flour substitute. This creates an ironic double risk — a coeliac seeking gluten-free options may unknowingly consume lupin, which cross-reacts with peanut in some individuals. Lupin was added to the Annex II list in 2006 due to increasing prevalence in food products and the severity of reactions reported.
14 — Molluscs
Legal definition: Molluscs and products thereof.
Where it hides: Oyster sauce (used extensively in Asian cooking), some seafood stocks and paella, Worcestershire sauce (some varieties contain oyster extract), certain sushi and Japanese dishes, some chowders and bisques.
Exemptions: None.
Practical notes: Molluscs include mussels, oysters, scallops, clams, squid, cuttlefish, octopus, snails, and abalone. Molluscs are a separate category from crustaceans. Oyster sauce is a commonly overlooked source — widely used in stir-fries, noodle dishes, and marinades. Some people with shellfish allergies react to both crustaceans and molluscs; others react to only one category.
Key principles for food businesses
All forms must be disclosed
If milk is listed as an allergen, this includes all milk derivatives — cream, butter, cheese, whey, casein, lactose, and milk powder. You cannot list "milk" only to mean liquid milk. The allergen category covers all forms.
Processing does not remove the obligation
Highly processed derivatives of allergens may be exempt (see the specific exemption lists above), but in general, cooking, fermenting, or processing an allergen does not remove your obligation to disclose it. Casein in ghee, proteins in refined oils where not specifically exempted — these still require disclosure.
Ingredient-level knowledge is required
You cannot comply with this regulation without knowing what is in every ingredient you use. Compound ingredients — sauces, stocks, spice blends — must be traced to their component allergens. "I didn't know it was in there" is not a defence.
Supplier specifications are your evidence
Your allergen claims are only as good as your ingredient data. Keep up-to-date supplier specifications for every ingredient. When a supplier changes their formulation, you need to know — establish a supplier change notification process.
The threshold for sulphites is the only numeric threshold
For 13 of the 14 allergens, any presence requires disclosure — there is no minimum threshold. The sole exception is sulphur dioxide and sulphites, which only require disclosure at concentrations above 10 mg/kg or 10 mg/L.
This list is fixed — but food science evolves
The EU Commission periodically reviews the Annex II list. Alpha-gal syndrome (red meat allergy triggered by tick bites) and allergies to new novel foods are areas of active scientific discussion. Subscribe to FSAI and EFSA updates to stay informed of any regulatory changes.