Food Safety

Food Allergen Labeling for Small Bakeries (US and UK)

By Robert Roessler, Food Scientist · Published 14 November 2026

Flour, eggs, milk, nuts, seeds and soy are everyday bakery ingredients, and every one of them is an allergen. A missing or wrong declaration can harm a customer and force a recall. This guide explains which allergens must be declared in the United States and the United Kingdom, how the rules differ for packaged and loose products, and how to handle cross-contact in the bakehouse. Every statement about rules names its source.

1. Why allergens matter in a bakery

The U.S. Food and Drug Administration (FDA) enforces the labeling rules for major food allergens and also inspects whether food facilities have controls against allergen cross-contact, the unintended transfer of an allergen into a food that does not contain it as an ingredient (FDA). In the earlier HACCP guide on this site we noted that undeclared allergens are reported as a leading reason for bakery recalls; allergen control belongs in your food safety plan from the start (HACCP for Small Bakeries).

2. United States: the nine major allergens

The FDA lists the major food allergens as milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame (FDA: Food Allergies). Sesame became the ninth allergen through the FASTER Act, signed on 23 April 2021 and effective from 1 January 2023, and all FDA requirements for major allergens, including labeling and manufacturing requirements, apply to it (FDA).

Under the Food Allergen Labeling and Consumer Protection Act (FALCPA), foods that contain a major allergen must name its source on the label. This is satisfied if the common name of an ingredient already shows the allergen, such as "sesame paste". Otherwise the source is stated once, either in brackets after the ingredient, for example "tahini (sesame)", or in a "Contains" statement next to the ingredient list, for example "Contains sesame" (Shield HealthCare summary of the FDA requirement).

The FDA states that FALCPA's labeling requirements extend to retail and food service establishments that package, label and offer products for human consumption (FDA). The federal labeling duty therefore applies to the wrapped products of a retail bakery. A secondary source notes that foods sold at retail or food service locations that are not pre-packaged fall outside this federal requirement (Shield HealthCare). Unwrapped items can still be covered by state or local rules, so ask your health department what it expects.

Two further points from the FDA's guidance matter for bakers. An ingredient derived from a major allergen that contains no protein from that allergen is not subject to the labeling requirement, and the requirements also apply to bulk containers that are shipped business-to-business for further processing (Covington & Burling summary of the January 2025 guidance).

3. United Kingdom: the 14 allergens

GOV.UK names 14 allergens that food businesses must tell customers about when they are used as ingredients: celery; cereals containing gluten (wheat, rye, barley and oats); crustaceans; eggs; fish; lupin; milk; molluscs; mustard; nuts; peanuts; sesame seeds; soya beans; and sulphur dioxide or sulphites above 10 mg per kilogram or per litre (GOV.UK: Allergen labelling).

Three situations are handled differently:

Prepacked food carries a full ingredients list, and the allergens must be emphasised each time they appear, for example in bold, italics or a different colour (Food Standards Agency).
Loose (non-prepacked) food, such as bread and cakes on open shelves, needs allergen information for every item containing any of the 14 allergens. It can be given verbally or in writing; if it is verbal, the business must tell the customer where to find written confirmation (GOV.UK). The FSA advises that written information supported by a conversation works best (FSA: Allergen guidance for food businesses).
Prepacked for direct sale (PPDS) is food that is packed on the premises where it is sold, before the customer chooses it. Since 1 October 2021 it needs a label with the name of the food, a full ingredients list and emphasis on the allergens present. This rule is known as Natasha's Law (FSA: PPDS changes for bakers).

4. Is it PPDS? Examples for bakers

The FSA explains that packaging, for this purpose, must fully or partly enclose the food so that it cannot be changed without opening or altering the packaging. A cake completely wrapped in cling film is an example. The FSA's bakery guidance gives these cases (FSA):

PPDS (full label needed)	Not PPDS (allergen information on request)
Bread, cakes, pasties and sandwiches packed on the premises before the customer selects them	Loose items on open shelves or behind a counter
Multi-packs of rolls or sausage rolls packed on site	Made-to-order food
Leftover cupcakes put in packaging before they are ordered	Food packed at the customer's request, such as a slice of cake
Small domed cakes presented with the dome on	A large cake under a dome that will be sliced; packaging that can be altered without opening it, such as an open tray

Food packed at another site or by another business is not PPDS, but it still needs a full label. Food sold online or by phone for delivery or collection is exempt from the PPDS rules, although labelling it is allowed, and home bakers selling at a distance must still give allergen information before ordering and on delivery (FSA). The FSA also offers a decision tool for PPDS and a labelling guide with details on type size and naming (FSA: Introduction to allergen labelling for PPDS food).

5. Cross-contact in the bakehouse

Labeling the intended ingredients is only half the job. Flour dust, shared mixers, tins, scoops, brushes and ovens can carry allergens from one product to the next. Practical controls that your local authority and the FSA mention include separate storage, labelled and covered containers, cleaning between products and planning the production order (FSA). In baking, sesame is a known difficulty: even with thorough cleaning, trace amounts may remain, according to the American Bakers Association (FoodNavigator, February 2026).

The FDA has not set a threshold for any allergen (FDA). It held a public meeting on allergen thresholds in February 2026, so this area may change (Food Safety Magazine).

6. "May contain" labels

Advisory statements such as "may contain" or "produced in a facility that also uses" are not required by law in either country (FDA; GOV.UK). Both authorities treat them as a last step, not a shortcut:

In the United States, an advisory statement is not a substitute for good manufacturing practice or food allergen preventive controls. An allergen that is an intentional ingredient should not also appear in an advisory statement, and a product with an "allergen-free" claim should not carry a "may contain" statement for the same allergen (Covington & Burling; Hutchison Law summary). An allergen present only through cross-contact cannot be listed in the ingredient list or the "Contains" statement (Hutchison Law).
In the United Kingdom, a precautionary label should be used only when an unavoidable risk of cross-contamination has been found in a risk assessment and cannot be controlled sufficiently by measures such as segregation and cleaning (FSA technical guidance). Businesses that make "free-from" or "allergen-free" claims must follow strict processes to prevent cross-contamination (GOV.UK).

7. Build an allergen matrix

An allergen matrix lists each product against each allergen. The FSA offers a free template for this purpose (FSA). The example below shows the layout with three simple recipes. The recipes are illustrations only; fill in your own matrix from the labels of the ingredients you actually use, and check compound ingredients such as fillings, glazes, improvers and seed mixes.

Product (example recipe)	Gluten cereals	Egg	Milk	Sesame	Other
Plain white loaf: wheat flour, water, yeast, salt	●				check flour treatment agents
Butter croissant with egg wash	●	●	●
Sesame seed roll	●			●	check improver for soya

The columns for celery, crustaceans, fish, lupin, molluscs, mustard and sulphites are left out here for space; a complete matrix for the UK has all 14, and one for the US has the nine major allergens. Update it whenever you change a recipe or a supplier.

8. A short checklist to start

Find out which rules apply to each product: wrapped, loose, PPDS or made to order.
Collect the allergen statements of every ingredient and every supplier.
Build the matrix and keep it where staff can find it.
Check each label against the matrix before products leave the bakehouse.
Decide on cleaning and production order to control cross-contact, and write it into your HACCP plan.
Train staff to answer allergy questions the same way every time and to point to the written information.
Review the matrix and labels whenever a recipe, a supplier or a pack changes.

Summary

Know your allergen list (nine in the US, fourteen in the UK), work out for each product whether it is packaged, loose or PPDS, and keep a matrix that you update with every recipe or supplier change. Treat "may contain" as a last resort after real cross-contact controls, and ask your local authority when a rule is unclear.

Sources

Information current as of 14 November 2026. This guide is general information and does not replace advice from your local health department, trading standards or food safety authority, or a lawyer. Rules change; check the current text before you print labels.