Technical guidance on new allergen labelling and information rules to support SMEs

The FSA is seeking views on draft technical guidance primarily aimed at food businesses that are small and medium sized enterprises (SMEs). The guidance gives SMEs information about changes in European Union food allergen labelling for prepacked foods and allergen information for non-prepacked foods.

About the proposed guidance

The draft guidance, which can be found via the link towards the bottom of this page, covers new rules on food allergen labelling and the provision of food allergen information which will apply across the European Union, including the UK, from 13 December 2014. The guidance aims to support SME food producers, manufacturers, importers, distributors, wholesalers, retailers and caterers, in following these rules.

Two-phase consultation

A consultation is currently taking place to allow stakeholders to comment on the guidance. It is a two-phase consultation. Phase one ran from 15 May 2014 to 5 June 2014 and asked the following questions:

  • Do you think this guidance helps you develop your understanding of the new allergen requirements? Is it also helpful in assisting SMEs to comply with the requirements?
  • Based on initial estimates, the FSA believes that it will take an average of 2 hours for businesses to read and familiarise themselves with the whole guidance. Do you agree?
    When commenting, please consider that the time taken to read the guidance depends on the particular business (i.e. prepacked foods or non-prepacked foods) and for some not all parts of the guidance will apply.
    Your views on this assessment as well as any supporting evidence will be welcomed.
  • Any suggestions for improving its content (layout, wording, examples etc.).

We have amended the guidance in light of the responses received from phase one and we are now seeking further comments in phase two of the consultation which runs from Friday 4 July 2014 to Thursday 24 July 2014.

Phase one outcome

We received a total of 36 responses, all of which were carefully considered.

A number of respondents commented that the guidance was too detailed and technical for SMEs. We would like to clarify that the guidance aims to provide detailed interpretations covering specific scenarios relating to allergen labelling of prepacked foods and the presentation of allergen information for non-prepacked foods. Last month the FSA issued leaflets and tools for SMEs containing shorter advisory information in these areas. These can be downloaded via the 'See also' link on this page.

We also received a number of specific comments relating to typographical errors and various legal interpretations in the guidance.

A summary of the responses can be found via 'Related Items' link towards the bottom of this page.

Main changes to draft guidance

In general we have amended the draft guidance by:

  • correcting typographical errors
  • amending the layout
  • reviewing references to other legislation
  • providing greater clarity in distinguishing between legal requirements and best practice
  • sense checking legal status advice and elaborating where appropriate
  • including further examples where appropriate

The amended draft guidance can be found via 'Related Item' link towards the bottom of this page.

Phase two

You are invited to comment on the amended draft guidance. In particular, please send comments regarding the following:

  1. Do you consider the layout with the split across prepacked and non-prepacked foods helpful for SMEs reading this guidance?
  2. Do you think the revised wording makes the distinction between mandatory requirements and voluntary approaches/best practice clearer?
  3. Do you think the guidance establishes a sound basis for SMEs to develop their understanding of the requirements?
    • If you are a trade organisation, do you consider the guidance will enable you to develop specific guidance where necessary? If not, what areas would you like us to consider in future?

Comments should be sent to Ned Mazhar ( by Thursday 24 July 2014.

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What area the proposal applies to:

  • additives and supplements
  • allergy and intolerance
  • dairy products and vegetable oils
  • fish and shellfish
  • food law, monitoring and controls
  • imports


Deadline for submitting phase one comments has passed. A summary of the responses received and an amended version of the guidance are available to download (see 'Related Items').

Phase two has commenced and runs from Friday 4 July 2014 to Thursday 24 July 2014. Your comments on the amended draft guidance are now invited.

Details of the final review and the final guidance itself are expected to be published on Thursday 31 July 2014.


Chun-Han Chan
Food Allergy and Intolerance Branch

Government regulatory initiative that applies:

Accountability for Regulator Impact initiative.

More information about this initiative can be found via the link below.

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