Allergens on a beer label in Ireland: barley, not "gluten"

Almost every beer contains an allergen, and it is in the base of the recipe: the malt. Beer over 1.2% vol needs no ingredients list, which makes the allergens easy to forget – but the list is optional for stronger beer, and the allergens are not.

The rules are the EU's: Article 21 and Annex II of Regulation (EU) No 1169/2011, which lists 14 groups of substances that must be declared. In Ireland, leaving them off a prepacked food is an offence under S.I. 556/2014 (regulation 7(1)(c)), and the Food Safety Authority of Ireland explains how to declare them on its page Labelling – Allergens. Like the rest of the label, the allergen information is in English.

Barley, wheat, oats and rye

The first group in Annex II is cereals containing gluten: "wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof". For a brewer that means almost every malt in the grist is an allergen.

What counts is the cereal, not the name of the malt. The FSAI is direct about it: "The cereal name e.g., 'wheat', must be declared and highlighted, not 'gluten'." So "Maris Otter", "crystal malt", "chocolate malt" or just "malt" isn't enough; write barley malt, wheat malt, oat malt or rye malt.

A few products of these cereals are exempt: wheat-based glucose syrups including dextrose, wheat-based maltodextrins, glucose syrups based on barley, and cereals used for making alcoholic distillates (Annex II, point 1(a) to (d)). Dextrose for priming is therefore not an allergen; maltodextrin made from barley is. Maize, rice, sorghum and millet are not on the list.

Without an ingredients list: "Contains barley."

Beer over 1.2% vol needs no list of ingredients (Article 16(4)). Without a list, the allergens are declared with "the word 'contains' followed by the name of the substance or product as listed in Annex II" (Article 21(1)). The FSAI gives the brewer's example itself: "Where a food is not required to have a list of ingredients, e.g., alcohol, the allergen indication must include the word 'contains' followed by the name of the allergen, e.g., 'contains barley'."

So: "Contains barley." for a pale ale, "Contains barley and wheat." for a wheat beer. The line is one of the mandatory particulars, so it needs an x-height of at least 1.2 mm (Article 13(2)), but it doesn't have to be in the same field of vision as the name, strength and volume (Article 13(5)).

With an ingredients list: emphasise them in it

If you give a list of ingredients – which a beer at 1.2% vol or less must have – the allergens are named in it and emphasised "through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour" (Article 21(1)(b)). Bold, capitals or a contrasting colour all work:

Ingredients: Water, Barley malt, Wheat malt, Oats, Hops, Yeast.

Then there is no separate "Contains" line: the FSAI's booklet Food Information on Prepacked Foods says that indicating allergens in an "allergen box" or allergen panel is not permitted under the regulation. Don't emphasise anything else in the list either – if the hops are also in capitals, the allergens no longer stand out.

Where several ingredients come from one allergen, each must make it clear (Article 21(1)): "Barley malt, Torrefied barley".

Why "barley" and not "gluten"

"Contains gluten" doesn't say which cereal it is, and the regulation asks for the name in Annex II – barley, wheat, rye, oats. The same goes for beer treated with an enzyme to break the gluten down: it is still brewed from barley, and barley must be declared.

"Gluten-free" may only be used when the beer as sold contains no more than 20 mg of gluten per kilogram, and "very low gluten" no more than 100 mg/kg, for food made with ingredients specially processed to reduce the gluten (Regulation (EU) No 828/2014, Annex). The cereal is still declared: the FSAI's own example with gluten-free oats keeps "oats" highlighted, "as they are considered an allergen".

Examples from common beer styles

Style	Allergens	In an ingredients list	Without a list
Dry stout	Barley	Barley malt, Roasted barley	Contains barley.
Red ale, pale ale, lager	Barley	Barley malt	Contains barley.
Wheat beer	Barley, wheat	Barley malt, Wheat malt	Contains barley and wheat.
Oatmeal stout	Barley, oats	Barley malt, Oats	Contains barley and oats.
Rye IPA	Barley, rye	Barley malt, Rye malt	Contains barley and rye.
Milk stout	Barley, milk	Barley malt, Lactose (milk)	Contains barley and milk.

Lactose in a milk stout

Annex II, point 7, is "milk and products thereof (including lactose)", so a milk stout or pastry stout made with lactose must declare milk: "Lactose (milk)" in a list, or "Contains barley and milk." without one. The regulation doesn't require the declaration "where the name of the food clearly refers to the substance or product concerned" (Article 21(1)) – whether "Milk Stout" does so clearly enough is a judgement, and declaring milk is the safe choice. "Pastry stout" certainly doesn't.

Fruit, nuts, sulphites and finings

Most fruit and spices are not allergens: raspberries, cherries, mango, orange peel, coriander, vanilla and honey aren't in Annex II. A few things are worth watching.

Nuts. The list is closed: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia nuts (Annex II, point 8), and the FSAI asks for the nut's name, "not 'nuts'". A Christmas ale with almonds declares "almonds". Peanuts are a group of their own (point 5). Coconut, chestnuts and pine nuts aren't on the list.

Sulphites. Sulphur dioxide and sulphites must be declared at more than 10 mg/kg or 10 mg/litre, as total SO₂ (Annex II, point 12). The FSAI adds that they appear under their chemical names, not E-numbers, and that "preservative: E220" is not enough: "preservative: sodium metabisulphite". It can apply to a fruit beer made with a sulphited purée – ask your supplier – and it applies to most wine: "All wines contain sulphites", the FSAI notes, and above 10 mg/L they are declared.

Finings. Isinglass and fish gelatine "used as fining agent in beer and wine" are exempt (Annex II, point 4(b)).

Celery, mustard, sesame, lupin, soya, eggs, fish, crustaceans and molluscs complete the list – rare in beer, but keep them in mind when a recipe gets experimental: an oyster stout brewed with real oysters contains molluscs.

"May contain"

A "may contain" statement is voluntary and "must not take the place of good manufacturing practices", says the FSAI: if cross-contamination can't be ruled out even with them, you may consider one. Name the allergen: "may contain wheat".

A way to work

Go through the recipe one ingredient at a time and ask which Annex II group it belongs to. Then decide: no ingredients list and a "Contains" line, or a list with the allergens emphasised and nothing else.

With Brewlabel, the labelling check in Plus checks that the allergens in an ingredients list are emphasised and nothing else is, and suggests switching off the "Contains" line when the list already shows them. You remain responsible for the label.

Last checked: 23 October 2026

This guide explains labelling and is not legal advice. Rules can change – if you sell your drink, check with the FSAI (Advice Line 0818 33 66 77) or your local environmental health officer.