Guides / Allergen emphasis
Do I have to emphasise allergens on a home bakery label?
Published 22 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.
On a prepacked or prepacked-for-direct-sale label, yes: each of the 14 allergens in Annex II must appear in the ingredient list in a typeset that clearly distinguishes it from the rest of the list. That is Article 21(1) of the food information regulation, which applies in the EU and, as assimilated law, in Great Britain. What a home bakery has to put on the label depends on how the food is sold: a wrapped cake posted to a customer is prepacked and carries the full label; a cake boxed on your premises before it is ordered is "prepacked for direct sale" and carries the name, the ingredient list and the emphasised allergens; a cake cut and sold loose, or boxed on your premises at the customer's request, needs the allergen information by other means. The 14 are the same in every case.
The rule itself
Article 9(1)(c) makes mandatory the indication of "any ingredient or processing aid listed in Annex II ... used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form". Article 21(1) says how: (a) in the list of ingredients, "with a clear reference to the name of the substance or product as listed in Annex II", and (b) with that name "emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour". Where several ingredients derive from one Annex II substance, each is made clear. Where there is no ingredient list, the word "contains" followed by the Annex II name replaces it. The indication is not required where the name of the food already clearly refers to the substance.
The 14 substances of Annex II
- Cereals containing gluten, namely wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof, with listed exceptions
- Crustaceans and products thereof
- Eggs and products thereof
- Fish and products thereof, with listed exceptions
- Peanuts and products thereof
- Soybeans and products thereof, with listed exceptions
- Milk and products thereof (including lactose), with listed exceptions
- Nuts, namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts, and products thereof, with the listed exception
- Celery and products thereof
- Mustard and products thereof, with the listed exception in the EU and Northern Ireland (Regulation (EU) 2024/2512)
- Sesame seeds and products thereof
- Sulphur dioxide and sulphites at more than 10 mg/kg or 10 mg/litre as total SO2
- Lupin and products thereof
- Molluscs and products thereof
The reference is to the name as listed: "wheat", not "gluten"; "almonds", not "nuts". A bakery's usual suspects are the cereals, eggs, milk, nuts, peanuts, soya (in chocolate and margarine), sesame and sulphites (in dried fruit).
How it is sold decides the label
| How the food reaches the customer | What the rules require (England) |
|---|---|
| Prepacked: packed before sale, sold at a distance or through another business (posted orders, a wholesale delivery to a cafe) | The full Article 9 particulars on the pack: name, ingredient list with emphasised allergens, net quantity, durability date, storage, business name and address, and the rest. |
| Prepacked for direct sale: the regulation uses the term without defining it; it is read as food packed on the premises where it is sold, before the customer asks for it (boxed cakes on a stall, wrapped brownies on a counter) | Regulations 6A and 5A: the name of the food (6A) and the ingredient list with the Annex II allergens emphasised (5A), "directly on the package or on a label attached to the package". This is the 2021 change often called Natasha's Law. |
| Not prepacked, or packed on the sales premises at the customer's request, sold face to face (a slice cut from a tray, a cake ordered at the counter and boxed for that customer) | Regulation 5: the allergen particulars "by any means the operator chooses, including ... orally", but where given orally there must be a written indication, on a label, notice, menu or ticket, that details can be obtained from staff. |
Article 2(2)(e) defines prepacked food as an item "consisting of a food and the packaging into which it was put before being offered for sale" and carves out food "packed on the sales premises at the consumer's request or prepacked for direct sale". Article 44(1) is what allows the Member States and the UK nations to set the rules for those carved-out foods; the regulations cited here are England's, and Wales, Scotland and Northern Ireland have their own equivalents. Where a case sits on the line between the rows, the local authority that enforces food law is the one to ask. Regulations 5 and 5A both apply only to food offered for sale "otherwise than by means of distance communication", so an order taken by phone, message or website falls under neither of the last two rows: Article 44(1)(a) still makes the allergen particulars mandatory for food that is not prepacked, but the "any means ... including orally" route of regulation 5 does not cover it. A home bakery that posts orders is in the first row for those orders, however small the business; the exemptions attach to how the food is sold, not to who sells it.
Doing it well
- Emphasise the allergen word, not the whole ingredient. "Wheat flour" with wheat in bold tells the reader which part matters.
- Every occurrence. Butter, milk chocolate and whey powder each carry a milk emphasis.
- Compound ingredients open out. "Milk chocolate (sugar, cocoa butter, milk powder, ...)" carries the emphasis inside the brackets too. Our food tool has nested rows for exactly this.
- Copy the emphasis when you copy the list. Pasting the list into a listing or a spreadsheet strips the bold; re-apply it wherever the list is reproduced as a label.
- Print size. An x-height of 1,2 mm, or 0,9 mm on a pack whose largest surface is under 80 cm² (Article 13).
The United States
The federal rule is built differently. 21 U.S.C. 343(w) requires, for the nine major food allergens, either the word "Contains" followed by the food source, printed immediately after or adjacent to the ingredient list in type no smaller than the list, or the food source in parentheses after the ingredient's name within the list. There is no emphasis rule, and the list of allergens is different: wheat rather than all gluten cereals, tree nuts, sesame since the FASTER Act, and no celery, mustard, lupin, molluscs or sulphites. Our food tool writes the Contains statement when you choose the US.
Related questions
Which typeset counts as emphasis?
Article 21(1)(b) says the allergen's name must be "emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour". Bold is the usual choice because it survives photocopying and small print; capitals, italics, underlining or a highlight also qualify as long as the allergen stands out from the words around it. Emphasise the allergen word itself, for example "wheat flour" with wheat in bold, not the whole ingredient.
Do I have to emphasise it every time it appears?
Yes, where several ingredients derive from the same Annex II substance the labelling must make it clear for each one: butter (milk), whey (milk) and milk chocolate each carry their emphasis. The reference must be to the name as listed in Annex II, so "wheat" or "barley", not "gluten" on its own, and "almonds" or "hazelnuts", not just "nuts".
Can I write a separate "Contains: milk, eggs" line instead?
Only where there is no ingredient list at all: Article 21(1) says that in the absence of a list the particulars "shall comprise the word 'contains' followed by the name of the substance or product as listed in Annex II". Where the list exists, the emphasis goes inside it, and a "contains" line on top is an addition, not a substitute. In the United States the rule is the other way round: 21 U.S.C. 343(w) accepts either a "Contains" statement after the list or the food source in parentheses within it.
How small can the print be?
Article 13(2) requires the mandatory particulars in a font whose x-height is at least 1,2 mm, dropping to 0,9 mm under Article 13(3) where the largest surface of the pack is under 80 cm². Our food tool measures the x-height of the font you pick and warns you when the print falls below it.
Tell me if the allergen rules change
The 14 allergens and the emphasis rule have stood since 2014, and the prepacked-for-direct-sale duty since October 2021. If either the EU or the UK changes them, we will email you.
No spam, no account. One email when a rule behind your labels changes. How we handle your address is in the privacy policy.
Sources
- Regulation (EU) No 1169/2011 on the provision of food information to consumers, as it applies in Great Britain (assimilated law): Article 2(2)(e), Article 9(1)(b) and (c), Article 13(2) and (3), Article 21(1), Article 44(1) and Annex II, legislation.gov.uk (the EU text of Articles 9, 13 and 21 carries the same wording)
- The Food Information Regulations 2014 (SI 2014/1855, England), regulation 5 (foods that are not prepacked, offered for sale otherwise than by means of distance communication) and regulations 5A and 6A (prepacked for direct sale: duty to list ingredients and to name the food) as inserted by The Food Information (Amendment) (England) Regulations 2019 (SI 2019/1218), in force 1 October 2021
- 21 U.S.C. 343(w) (major food allergen labelling) and 21 U.S.C. 321(qq) (the nine major allergens including sesame under the FASTER Act), for the United States
The documents this answer rests on. A labelling reference, not legal advice; you remain responsible for your product's labelling.