The 14 Allergens & Food Law

Which of these is NOT one of the 14 allergens that UK food law requires businesses to declare?

• ASesame seeds
• BChestnuts✓
• CLupin
• DMolluscs

Answer: Chestnuts are not on the Annex II list of 14 allergens, even though they can cause allergic reactions in some people. Sesame seeds, molluscs and lupin seeds are all named Annex II allergens that must be declared. Foods like chestnuts, pine nuts and coconut are sometimes mistaken for regulated allergens simply because they contain the word 'nut'.

A customer asks whether a dish contains any tree nuts. Which of the following is a tree nut under the Annex II allergen list?

• AChestnut, not part of Annex II
• BMacadamia (Queensland nut)✓
• CPeanut, a legume rather than a nut
• DPine nut, excluded from Annex II

Answer: Macadamia, also known as the Queensland nut, is one of the eight tree nuts named in Annex II, alongside almond, hazelnut, walnut, cashew, pecan, Brazil nut and pistachio. Peanuts are a legume and are listed as a completely separate allergen from tree nuts. Chestnuts and pine nuts are not named in Annex II and must not be emphasised as allergens.

Under the Annex II allergen list, peanuts and tree nuts are treated as:

• ATwo separate allergens, each requiring its own declaration✓
• BSub-types of the lupin entry, since both are classed as legumes
• CA single combined allergen, declared simply as 'nuts' on the label
• DRequired to be declared once they exceed 1% of the total recipe

Answer: Peanuts and tree nuts appear as two distinct entries on the Annex II list of 14 allergens, so each must be declared in its own right. Labelling peanuts under a general 'nuts' warning is not sufficient, because peanuts are legumes rather than tree nuts. Neither allergen becomes optional to declare based on the quantity used.

Cereals containing gluten, as listed in Annex II, include wheat, rye, barley and which other cereal?

• AOats✓
• BRice
• CSoya
• DMaize

Answer: Oats are named alongside wheat, rye and barley as a cereal containing gluten under Annex II. Rice, maize and soya are not gluten-containing cereals under the allergen rules. Wheat's hybridised strains, such as spelt and Khorasan wheat, must also be declared as wheat.

Which product made from a gluten-containing cereal is specifically exempted from allergen declaration under Annex II?

• AWheat flour, used as a thickener in gravy
• BWheat-based glucose syrup, including dextrose✓
• COat bran, added to a cereal bar recipe
• DMalted barley, used to brew traditional beer

Answer: Wheat-based glucose syrup, including dextrose, is one of the named exceptions because the processing removes the allergenic protein. Wheat flour, malted barley and oat bran are not exempt and must still be declared wherever they are used as ingredients. The other gluten exceptions are wheat-based maltodextrins, barley-based glucose syrups, and cereals used to make alcoholic distillates.

Under Annex II, which use of fish is exempt from allergen declaration?

• AFish sauce used as a seasoning in stir-fries
• BFish stock used as the base for a soup or sauce dish
• CIsinglass used as a fining agent in beer or wine✓
• DAnchovies used as a topping for a large mixed salad

Answer: Isinglass, derived from fish and used as a fining agent to clarify beer or wine, is specifically exempted from the fish allergen declaration under Annex II. The only other fish exemption is fish gelatine used as a carrier for vitamin or carotenoid preparations. Fish stock, anchovies and fish sauce are all ordinary uses of fish and must be declared.

Which milk-derived substance does Annex II exempt from allergen declaration?

• ACasein
• BLactitol✓
• CWhey powder
• DLactose

Answer: Lactitol is one of two named milk exceptions under Annex II, because it is not considered to pose an allergenic risk. The other milk exception is whey used in making alcoholic distillates. Whey powder, lactose and casein are all ordinary milk derivatives and must be declared with a clear reference to milk.

Which of these soya-derived substances does Annex II exempt from allergen declaration?

• ATofu, a common soya ingredient
• BFully refined soybean oil✓
• CSoya flour, often used in baking
• DSoy sauce, used as a seasoning

Answer: Fully refined soybean oil is exempt because the refining process removes the allergenic protein, leaving no meaningful risk to people with a soya allergy. Tofu, soya flour and soy sauce are ordinary soya products and must be declared with a clear reference to soya. Other exempt soya derivatives include the tocopherols, phytosterols and plant stanol ester named in Annex II.

Nuts used for making alcoholic distillates, such as a nut-flavoured spirit, are treated under Annex II as:

• AExempt only when the spirit is below 1.2% strength
• BExempt for peanuts, but not tree nuts
• CExempt from the nut allergen declaration✓
• DStill requiring a full nut declaration

Answer: Nuts used for making alcoholic distillates, including ethyl alcohol of agricultural origin, are specifically exempted from the nut allergen declaration under Annex II. This exception applies to the nuts allergen itself and is not linked to the alcohol strength of the finished drink. Similar distillate exceptions exist for gluten-containing cereals and for milk whey.

Sulphur dioxide and sulphites must be declared as an allergen once they are present in the food, as consumed, above which concentration?

• A1 mg per kilogram or 1 mg per litre, calculated as total sulphur dioxide
• B10 mg per kilogram or 10 mg per litre, calculated as total sulphur dioxide✓
• C50 mg per kilogram or 50 mg per litre, calculated as total sulphur dioxide
• D100 mg per kilogram or 100 mg per litre, calculated as total sulphur dioxide

Answer: Sulphur dioxide and sulphites only need declaring as an allergen once the level in the food, as proposed ready for consumption or as reconstituted, exceeds 10 mg per kilogram or 10 mg per litre, calculated as total sulphur dioxide. Levels at or below this threshold do not require an allergen declaration. This is the only one of the 14 allergens defined by a concentration threshold rather than simple presence.

Around what proportion of the UK adult population is estimated to have a food allergy, not including intolerances?

• AAbout 1%
• BAbout 35%
• CAbout 20%
• DAbout 6%✓

Answer: Around 6% of UK adults are estimated to have a food allergy, a figure that does not include people with food intolerances. This is separate from coeliac disease, which affects roughly 1 in 100 people. Because reactions can be triggered by very small amounts of an allergen, accurate allergen information matters even for a small quantity of food.

Coeliac disease is best described as:

• AA genetic autoimmune disease triggered by gluten✓
• BA temporary intolerance that resolves with age
• CA reaction caused only by eating raw, unprocessed gluten
• DA food allergy to wheat protein

Answer: Coeliac disease is a genetic and autoimmune disease, triggered by eating gluten, that damages the lining of the gut and causes malabsorption. It is estimated to affect around 1 in 100 people and is distinct from a wheat allergy, since it does not produce anaphylactic shock. There is no cure, so the only way to manage it is strict avoidance of gluten in the diet.

How small a quantity of an allergen can be enough to trigger an allergic reaction in a sensitive person?

• AA full portion of the allergenic food, rather than a trace
• BA tiny amount, such as a drop of milk or a fragment of peanut✓
• CAt least a full teaspoon or more of the allergenic ingredient
• DAn amount large enough to be the dish's main ingredient

Answer: An allergic reaction can be produced by a tiny amount of a food ingredient, such as a drop of milk, a fragment of peanut, or one or two sesame seeds. This is why even trace cross-contamination in a kitchen can be dangerous for an allergic customer. It is not necessary for the allergen to be a main ingredient, or present in any significant quantity, for a reaction to occur.

Under Article 9(1)(c) of the Food Information to Consumers regulation (FIC), food business operators must:

• ADeclare allergens only for food that is sold inside a supermarket
• BDeclare only the allergens that are used as a primary ingredient in the recipe
• CDeclare the presence of any of the 14 major allergens used as an ingredient or processing aid✓
• DDeclare allergens only when a customer specifically asks about them

Answer: Article 9(1)(c) of the FIC places a duty on all food business operators to declare the presence of any of the 14 major allergens listed in Annex II, whether the substance is used as an ingredient or as a processing aid. This duty applies regardless of the quantity used or whether a customer asks. It applies across manufacturing, retail and catering, not just to supermarket products.

The Food Information Regulations 2014 (FIR) relate to the Food Information to Consumers regulation (FIC) by:

• AApplying to businesses in Scotland rather than in England
• BCovering nutrition labelling, but leaving allergens to other laws
• CReplacing the FIC with a new, separate set of UK allergen rules
• DEstablishing the enforcement measures for the FIC in the UK✓

Answer: The Food Information Regulations 2014, together with the Welsh and Northern Ireland equivalents, establish the enforcement measures for the FIC, which sets out the underlying allergen labelling duties. The FIR does not replace the FIC or create a separate set of allergen rules. This technical guidance applies to England, Wales and Northern Ireland, with a separate publication covering Scotland.

A sandwich is made and wrapped in a shop, then placed on a shelf for customers to pick up before ordering. How is this food classified for allergen labelling?

• AExempt from allergen labelling
• BNon-prepacked (loose) food
• CPrepacked for direct sale (PPDS)✓
• DFully prepacked food from a manufacturer

Answer: Food that is packed on the same premises before being offered for sale, and before a customer selects or orders it, is classed as prepacked for direct sale (PPDS) food. Non-prepacked food is unpackaged, and fully prepacked food is packaged elsewhere, such as by a manufacturer, before reaching the shop. No allergen exemption applies to a sandwich packed and displayed in this way.

What must appear on the label of a PPDS (prepacked for direct sale) sandwich?

• AThe name of the food and a full ingredients list with allergens emphasised✓
• BA single 'may contain' warning statement listing the 14 allergens on the packaging
• CA sign directing customers to ask staff about allergens
• DThe name of the food and a best-before date, but no ingredients list

Answer: PPDS food must be labelled with the name of the food and a full ingredients list, with allergenic ingredients emphasised every time they appear, for example in bold or a contrasting colour. A verbal sign directing customers to ask staff is a method used for non-prepacked food, not PPDS. A blanket 'may contain' statement covering every allergen is not an acceptable substitute for a proper ingredients list.

A cafe serves meals cooked to order, with no packaging involved. How may it legally provide allergen information to customers?

• ABy any means, including a full written list or a verbal explanation backed by a signposted notice✓
• BOnly if a qualified nutritionist is present on site to advise every customer
• COnly by providing a full written ingredients list, with no other method ever permitted
• DOnly by removing every dish that contains any allergen from the menu entirely

Answer: For non-prepacked food such as a meal cooked to order, allergen information can legally be provided by any means, including full written information or an oral explanation from staff supported by a clear, visible notice signposting how to ask. A written ingredients list for every dish is good practice but is not the only lawful route. There is no requirement for a nutritionist to be present, and dishes containing allergens do not need to be removed from the menu.

A group of volunteers wants to sell homemade cakes at a one-off charity fundraiser. Regarding allergen law, they should:

• ATreat the event as exempt from allergen law, because it is a one-off charity fundraiser
• BRegister the stall with the Food Standards Agency head office before the sale
• CFollow the allergen rules once the event's takings pass a set financial threshold
• DCheck with their local authority, since charity food providers may still need to follow the legal requirements✓

Answer: Occasional or voluntary food providers, such as volunteers at a charity cake sale, may still need to follow the legal allergen requirements, so it is best practice to check with the local authority's environmental health department if unsure. It would be wrong to assume charity events are automatically exempt from allergen law. There is no financial threshold above which the rules start to apply, and any food business registration is made with the local authority rather than the Food Standards Agency.

Which body is responsible for enforcing allergen labelling requirements against a food business?

• AThe customer's own GP
• BThe Food Standards Agency
• CThe manufacturer's office
• DThe local authority✓

Answer: Local authorities, through their environmental health or trading standards departments, are responsible for enforcing allergen information requirements. Non-compliance can lead to an improvement notice, which the business has 14 days to appeal, and in some cases prosecution. The Food Standards Agency produces national guidance but does not itself carry out local enforcement visits.