EU FIC 1169/2011: Exceptions to Allergen Labelling

Elvira Odorizzi
EU FIC 1169/2011: Leitfaden für Ausnahmen der Allergenkennzeichnung

There are clearly defined exceptions in the EU regulation about food allergen labelling that hospitality establishments are responsible for providing to their guests. 

Legal exceptions to allergen labelling under the EU FIC 1169/2011 regulation

There are labelling exceptions for specific ingredients:

Exceptions to labelling cereals containing gluten:

  • wheat based glucose syrups (incl. dextrose),
  • wheat based maltodextrins,
  • glucose syrups based on barley,
  • cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin.

Exceptions to labelling fish:

  • fish gelatine used as the carrier for vitamin or carotenoid (a.k.a. colouring) preparations,
  • fish gelatine or Isinglass used as fining agent in beer and wine.

Exceptions to labelling soybeans:

  • fully refined soybean oil and fat,
  • natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural D-alpha tocopherol succinate from soybean sources,
  • vegetable oils derived phytosterols and phytosterol esters from soybean sources,
  • plant stanol ester produced from vegetable oil sterols from soybean sources.

Exceptions to labelling milk (including lactose):

  • when used for making alcoholic distillates including ethyl alcohol of agricultural origin,
  • lactitol.

Exceptions to labelling nuts:

  • when used for making alcoholic distillates including ethyl alcohol of agricultural origin.

Exceptions to labelling sulphur dioxide and sulphites:

  • when below 10 mg/kg or 10 mg/litre (in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers).

 

Additional exceptions

Allergen name is stated in the dish name:

When the name of the food clearly refers to the substance or product causing allergies or intolerances (e.g. "Eggs Benedict", "Salad with mustard dressing" or "Chocolate cake with peanuts"), it is not necessary to label the concerned substance or product.

Dairy products are considered clear references to Milk (incl. lactose)

Additionally to the exceptions listed in "Exceptions to labelling milk (including lactose)" above, dairy products do not need to be marked with "Milk (including lactose)".

Be considerate of the following products, as consumers from a different cultural background (e.g. tourists) might not recognise them as dairy products:

  • kephir,
  • koumiss,
  • viili,
  • smetana,
  • fil.

 Best is to name them descriptively:

  • kephir fermented milk drink,
  • koumiss fermented milk,
  • viili yogurt,
  • smetana sour cream,
  • fil fermented milk.

 

For further information on allergen labelling, you can always drop an email to our friendly team. In the prospect of simplifying compliance to EU FIC 1169/2011, you can always rely on our service Menutech.

 

Automated allergen labelling for menus in hotels, restaurants and caterings

The Menutech software is a tool for hotel, restaurant and catering owners to make the writing of menus easier and faster. The software, compliant with EU FIC 1169/2011 regulation, allows users to both minimise overlaps and redundancies, and increase the clarity and consistency of their allergen labelling activity.

 

 

Sources: 

Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers

European Commission - Directorate for Health and Food Safety: Guidelines relating to the provision of information on substances or products causing allergies or intolerances as listed in Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers

European Commission - Directorate for Health and Food Safety, 2013: Questions and Answers on the application of the Regulation (EU) N° 1169/2011 on the provision of food information to consumers