Allergen labelling for supplements: US vs UK

United States: nine major food allergens

US law defines nine major food allergens: milk, egg, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame was added by the FASTER Act and took effect on 1 January 2023. They are declared in one of two ways:

• a “Contains” statement immediately after or next to the ingredient list, for example “Contains: Milk, Soy”; or
• in parentheses within the ingredient list, for example “whey (milk)”.

For tree nuts, fish and crustacean shellfish, the specific type or species must be named, for example “Tree nuts (almonds)” or “Fish (cod)”.

United Kingdom: 14 allergens, emphasised in the list

Annex II of Regulation (EU) 1169/2011, as retained in GB law, lists 14 substances: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites (above 10 mg/kg or 10 mg/litre), lupin and molluscs. Article 21 requires them to be emphasised within the ingredient list, for example in bold. Only when there is no ingredient list is “Contains” followed by the allergen name used.

Supplement-specific points

• Check carriers and excipients, not only the actives. Soy lecithin, milk-derived lactose, fish gelatin and fish oil all count.
• Capsule shells and coatings can contain allergens.
• “May contain” statements are voluntary in both markets and should be based on a documented risk assessment.

Draft a statement with the allergen statement generator.