Allergens
How often does a food label say “may contain”, allergen by allergen?
Tree nuts are named in a “may contain” line on 117,647 products in Open Food Facts, 2.9 times as many as list them in the recipe.
Allergens
How to read a food label for allergens: EU, UK, US and Gulf rules
Read three places: the ingredient list, the “Contains” line and the “may contain” line. Here is what each means under EU, UK, US and Gulf rules.
- Ingredients: every allergen is named in the list, here in bold.
- Contains: a summary line that repeats them.
- May contain: a voluntary warning about cross-contact.
Key takeaways
- The EU and UK name 14 allergens that must always be declared; the US names 9, after sesame was added on 1 January 2023.
- The 2013 English text of the Gulf standard GSO 9 lists 14 allergen groups, the same groups as the EU, including sesame, mustard, celery, lupin and molluscs.
- “May contain” is voluntary in the EU, UK and US, and no legal threshold triggers it.
- Many allergens hide behind other names: whey is milk, semolina is wheat, arachis oil is peanut, albumin is egg.
- A “gluten-free” claim on the front is a threshold claim (under 20 ppm in the US, 20 mg/kg in the EU and UK); it never replaces the allergen list on the back[11][12].
The short answer
An allergen label has three parts to read. The ingredient list must name the allergens in the recipe. A “Contains” line often repeats them. A “may contain” line is a voluntary warning about cross-contact. In the Gulf, the 2013 text of the GSO 9 standard lists the same 14 allergen groups as the EU.
Which allergens must be declared, market by market?
Each market keeps its own list of allergens that must be named whenever they are used, whatever form they take[1][4][5]. The lists overlap but are not the same, so one product can carry different allergen wording from one country to the next.
| Market | Allergens that must be declared | Good to know |
|---|---|---|
| EU and UK | 14: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphites (10 mg/kg or more), lupin, molluscs[4][6] | Emphasised inside the ingredient list, for example in bold[4]. In the UK, Natasha’s Law extends full ingredient labelling to food prepacked for direct sale[7]. |
| United States | 9: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, sesame[5] | Sesame became the ninth major allergen on 1 January 2023 under the FASTER Act. Declared in the ingredient list or in a “Contains” statement[5]. |
| UAE, Saudi Arabia and the GCC | 14 groups in the 2013 English text of GSO 9: cereals containing gluten (wheat, barley, oats, rye, spelt), crustaceans, eggs, fish, peanuts, soybeans, tree nuts (written “walnuts”), milk including lactose, sulphites at 10 ppm or more, celery, mustard, sesame, molluscs (written “clams”) and lupin[1] | The current edition is GSO 9:2022, with Amendment 1 approved on 22 April 2025[2][3]. Labels must be in Arabic, and any second language must match it[1]. |
| The international reference | The 2024 revision has one list that must always be declared and a second list set by region or country[8]. Reports of the revised text say sesame joined the first list and soy moved to the second[9]. | The international food standard is a reference that countries write into their own rules; it does not apply to a pack by itself. |
Where on the pack are allergens listed?
Allergens are listed in three places on a pack: the ingredient list, a “Contains” statement under it, and any “may contain” line.
- Ingredient list: allergens are named, and in the EU and UK emphasised, for example “wheat flour”, “milk powder”, “soy lecithin”[4].
- “Contains” statement: a summary line under the ingredients. In the US it is one of the two legal ways to declare an allergen[5]. It repeats the allergens and never replaces the list.
- “May contain” or “made in a facility that also handles…”: a precautionary warning about cross-contact during production[7].
- Front-of-pack claims: “gluten-free” means 20 mg/kg of gluten or less in the EU, UK and US[11][12], but it sits next to the ingredient list, not instead of it.
What does “may contain” mean, and is it required?
“May contain” is a voluntary warning that an allergen could be present through cross-contact. In the EU, UK and US no legal threshold triggers it, so one factory may print it while another with the same risk does not[5][7]. The UK Food Standards Agency asks businesses to use it only after a real risk assessment, never as a blanket disclaimer[7].
For someone with a severe allergy, “may contain” deserves the same weight as “contains”. For someone avoiding an ingredient by choice, it is a judgement call. This is why Bravoora keeps the two apart in its answer: “Not for you” when the ingredient is listed, “Heads up” when only a warning mentions it.
How does the Gulf list word tree nuts and molluscs?
The English text of GSO 9/2013 says “walnuts” where the EU says tree nuts, and “clams” where the EU says molluscs[1]. Bravoora reads “walnuts” as the whole tree-nut group, the way the EU list does.
In Saudi Arabia, the Saudi Food and Drug Authority oversees food and publishes its regulations online[10]. Imported products often carry the EU or US wording as well as the Gulf one.
What real product listings show about allergens
- Of 111 real products sold in the Gulf that list E322 (lecithin), 85% had the retailer declaring soy. The code alone doesn’t name the source, so read the “Contains” line.
- Sulphites often appear as a code rather than the word: E223 was printed on 15 packs and E224 on 4.
- An oat drink declared “Contains oat (gluten)” over a list of water, oat, sunflower oil and sea salt. Oats count as a gluten cereal in the GSO 9 list[1].
Method: real product listings from an online supermarket in the Gulf, compared with the retailer’s own allergen field (20–21 September 2026)[13]. These facts describe what labels say, not how often any brand gets it right. A listing can differ from the pack in your hand.
Which words on the label point to allergens?
- Contains: the summary line that repeats the allergens in the recipe.
- May contain, made in a facility that also handles: a precautionary warning about cross-contact, not an ingredient.
- Gluten (wheat, barley, rye, oats): the cereal is named, and the word gluten often sits in brackets.
- Whey, casein, lactose: all milk. Albumin: egg. Benne, gingelly oil: sesame.
- Groundnut, arachis oil: peanut. E220 to E228: sulphites.
- Gluten-free: a threshold claim, not an allergen declaration.
How do you check a label in 30 seconds?
- Find the ingredient list and read it to the end. Allergens can be near the bottom.
- Check the “Contains” line, then the “may contain” line.
- Translate the hidden names with the table above, or paste the list into the free label checker.
- If the label is unclear, or the language you read isn’t on the pack, treat the product as unverified.
- Recipes change. Re-read a familiar product when its packaging changes.
How does Bravoora check a label for allergens?
Bravoora looks for these names in the ingredient list and “may contain” lines, and shows you the words it matched. It then compares them with the profile you build, so the answer is about the person you are checking for. The methodology shows how it is tested.
The same label dictionary runs today in the free label checker, and it is published as open data[13].
Let Bravoora read the label with you.
Tell it once what matters: your allergens, your diet, the ingredients you watch. Every answer then shows the words it is based on.
Scope and limits
This guide covers allergen labelling on prepacked food sold in the EU, the UK, the US and the Gulf states. It does not cover restaurant menus, loose food or supplements.
Sources were checked on 22 September 2026. The Gulf list is quoted from the English text of GSO 9/2013; GSO 9:2022 and its 2025 amendment are the current editions, and the place to check for any change since 2013[2][3].
This is general label information, not medical advice. With a diagnosed allergy, follow your clinician’s plan.
Frequently asked questions
Do the Gulf allergen rules match the EU?
Closely. The 2013 English text of GSO 9 lists the same 14 groups as the EU and UK, including sesame, celery, mustard, lupin and molluscs. The wording differs in places: it says “walnuts” for tree nuts and “clams” for molluscs. Imported products often carry the EU or US wording as well.
Is “may contain” required by law?
No. In the EU, UK and US it is a voluntary precautionary statement, and the 2013 text of GSO 9 sets no rule for it. It should reflect a real risk of cross-contact, but no legal threshold applies, so its absence doesn’t prove a product is free of that allergen.
Are “gluten-free” and “dairy-free” claims regulated?
“Gluten-free” is regulated in the EU, UK and US and means 20 mg/kg of gluten or less. “Dairy-free” has no single legal definition, so read the ingredient list as well.
Sources
- GSO 9/2013 Labeling of Prepackaged Food Stuffs (English text): the allergen list and the language clause
- GSO 9:2022 Labeling of prepackaged food stuffs
- GSO 9:2022/Amd1:2025, amendment to GSO 9:2022
- Regulation (EU) No 1169/2011 on the provision of food information to consumers (Article 21 and Annex II)
- Food Allergies (including the FASTER Act)
- Allergen labelling for food manufacturers
- Food allergen labelling and information requirements: technical guidance
- FAO/WHO Codex Alimentarius Commission adopts new standards (47th session)
- Codex publishes updated general standard for the labeling of prepackaged foods
- Laws and regulations
- Gluten-Free Labeling of Foods
- Commission Implementing Regulation (EU) No 828/2014 on gluten-free claims
- Bravoora label dictionary (public data file, English edition, version 1.5.1)
Change log
- Examples changed to names printed on packs in the US, UK and Europe; the Gulf row moved to the end of the market table.
- Figures redrawn in English and the label words section rewritten: it now lists the names as they are printed on English-language packs. Every dictionary count is read from the published English file, and the byline names the Bravoora team.
- Corrected the Gulf allergen list to the 14 groups in GSO 9/2013 and named GSO 9:2022 with its 2025 amendment as the current edition. Added the 2024 revision of the international standard, the labelling-language rule and facts from real labels. Rewrote “How does Bravoora check a label” to say exactly what it matches.
- First published.
Ingredient guides for this topic
SesameTiny seeds used whole, pressed into oil and ground into a paste.Read the guide
MilkMilk and its proteins hide under many names on ingredient lists.Read the guide
GlutenA protein in wheat, barley and rye, and in foods made from them.Read the guide
Lecithin (E322)The emulsifier in almost every chocolate bar, from four possible sources.Read the guideRelated articles
All articlesAllergens
Which nuts count as tree nuts on a food label?
The EU names eight tree nuts, the US twelve. Almond is on 43,612 products in Open Food Facts; coconut, on 33,931, is a tree nut on no list.
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