9 or 14? US and UK allergen rules, side by side

If you cook across both sides of the Atlantic — a cruise line, a hotel group, an international caterer — you're operating under two allergen regimes that overlap heavily but don't match. Getting the difference wrong is an easy way to under-declare.

Note: this is general information, not legal advice — confirm your obligations in each jurisdiction with a suitably qualified professional.

The United States: 9 major allergens

The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) identified eight major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat and soybeans. (Source: FDA, "Food Allergies", fda.gov.)

Sesame then became the ninth. The FASTER Act, signed on 23 April 2021, declared sesame the 9th major food allergen, and as of 1 January 2023 sesame must be labelled as an allergen on packaged foods in the US. (Source: FDA, "The FASTER Act: Sesame Is the Ninth Major Food Allergen", fda.gov.)

The UK and EU: 14 allergens

The UK and EU require 14 allergens to be declared, under Regulation (EU) No 1169/2011, Annex II. The 14 cover the US nine and add five more — celery, mustard, sulphur dioxide and sulphites, lupin, and molluscs — and where the US lists "wheat," the UK/EU list the broader "cereals containing gluten." (Source: Regulation (EU) No 1169/2011, Annex II — legislation.gov.uk.) For the UK labelling rules that sit on top of this — including Natasha's Law — see Natasha's Law, explained.

Why it matters if you operate across both

The safe-direction takeaway: a card built to the UK/EU 14 already covers the US nine — but a card built only to the US nine can miss celery, mustard, sulphites, lupin or molluscs, which are commonplace (celery in stock, mustard in dressings, sulphites in dried fruit and wine, molluscs in a seafood mix).

So for a multi-jurisdiction operation, the practitioner move is simple: build to the broader standard and you're covered in more ports. (That's our view, not a legal instruction — local rules always govern.) The fuller breakdown of the 14 is in the allergen matrix guide.

Where PlateProof fits

PlateProof uses the UK/EU 14 as its baseline — the broader set — so a card produced for a UK kitchen already accounts for the US majors, and a named chef signs off the declaration either way. One standard, evidenced, in every galley. See it on your own dishes.

Sources

• FDA — The FASTER Act: Sesame Is the Ninth Major Food Allergen: https://www.fda.gov/food/food-allergies/faster-act-sesame-ninth-major-food-allergen
• FDA — Food Allergies: https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/food-allergies
• Regulation (EU) No 1169/2011 on the provision of food information to consumers, Annex II — legislation.gov.uk