Side by side
| Allergen | US | EU |
|---|---|---|
| Milk | Yes | Yes |
| Eggs | Yes | Yes |
| Fish | Yes, with the species | Yes |
| Crustaceans, such as crab, lobster and shrimp | Yes, with the species | Yes |
| Tree nuts | Yes, with the type of nut | Yes: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamias |
| Peanuts | Yes | Yes |
| Wheat | Yes | As part of cereals containing gluten: wheat, rye, barley, oats, spelt and kamut |
| Soy | Yes | Yes |
| Sesame | Yes, since January 1, 2023 | Yes |
| Celery | Not required | Yes |
| Mustard | Not required | Yes |
| Lupin | Not required | Yes |
| Mollusks, such as mussels, oysters and squid | Not required | Yes |
| Sulfites | Declared at 10 ppm or more, though not a major allergen | Yes, above 10 mg/kg |
The US list comes from the Food Allergen Labeling and Consumer Protection Act, which named eight foods, and the FASTER Act, which made sesame the ninth from January 1, 2023. US labels must also name the type of tree nut and the species of fish or crustacean.1 The EU list is Annex II of its food information regulation.2
Two that can hide under “spice” in the US
Under US rules, celery seed and mustard flour both count as spices, and spices can be declared on the ingredient list simply as “spice.”3 Neither celery nor mustard is a major allergen in the US, so when they’re used as a spice, nothing requires them to be named. On an EU label, both would have to be named and emphasized.
Colors from insects, in the US
The FDA also requires cochineal extract and carmine, red colors made from insects, to be declared on the label of all food and cosmetic products, because they’ve been identified as allergenic.1
How they’re shown
A US label names the allergen in parentheses after an ingredient or in a “Contains” line. An EU label emphasizes it inside the ingredient list, usually in bold. More on reading a label.