Allergens on a beer label: how to get them right

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. The list is optional for stronger beer; the allergens are not.

The rules are in assimilated Regulation (EU) No 1169/2011, mainly Article 21 and Annex II. The annex lists 14 groups of substances that must be declared. The Food Standards Agency explains how in its technical guidance on allergen labelling (for England, Wales and Northern Ireland). Like the rest of the label, the allergen information must be 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 made from them. 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 FSA asks for the specific name of the cereal (paragraph 29), and gives "barley malt extract" as an example of emphasising it (paragraph 30). So "Maris Otter", "crystal malt", "chocolate malt" or just "malt" isn't enough; write "barley malt", "wheat malt", "oat malt" or "rye malt". Spelt and khorasan need a clear reference to wheat, such as "spelt (wheat)" or "khorasan wheat" (paragraph 29).

A few products of these cereals are exempt: wheat-based glucose syrups including dextrose, wheat-based maltodextrins and barley-based glucose syrups (Annex II, point 1(a) to (c)). Wheat dextrose, for example for priming, is therefore not an allergen. Maltodextrin made from barley is not exempt. Maize, rice, sorghum and millet are not on the list.

Why "barley" and not "gluten"

"Contains gluten" doesn't say which cereal it is. The FSA's guidance says the cereal must be named, so that people who are allergic to a specific cereal know to avoid the food. In the ingredients list you may add the word "gluten" voluntarily after the cereal, but it is the cereal that is emphasised: "barley (gluten)" (paragraphs 29 and 30).

The same goes for beer treated with enzymes 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 (assimilated Regulation (EU) No 828/2014, Annex), and even then the cereal must still be declared – and emphasised, if there is an ingredients list (FSA, paragraph 31). The only other statement about the gluten content that is allowed is "very low gluten", at no more than 100 mg/kg, for food made with ingredients specially processed to reduce the gluten. Trading standards' guidance on Business Companion adds that you need regular testing and procedures to prevent contamination to back the claim up.

Emphasis in the ingredients list

If the beer has an ingredients list, the allergens are emphasised in it with a typeset that clearly distinguishes them from the rest of the list, for example by font, style or background colour (Article 21(1)(b)). Bold, capitals, a contrasting colour or underlining all work:

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

Where an ingredient is several words, only the allergen needs emphasis: "barley malt" (FSA, paragraph 62). Where the allergen is part of a single word, you can emphasise just that part: "sodium metabisulphite" (paragraph 61). The list starts with a heading that includes the word "ingredients", and runs from the heaviest ingredient to the lightest (Article 18(1)).

Don't emphasise anything else. Article 21(1)(b) asks for a typeset that clearly distinguishes the allergens from the rest of the list, so if the hop varieties are also in capitals – "Hops (CITRA, MOSAIC)" – or in bold because it looks good, the allergens no longer stand out. Write the hops in plain type: "Hops (Citra, Mosaic)".

You can add a line that explains the emphasis, such as "Allergy advice: for allergens, see ingredients in bold" (FSA, paragraph 59).

When do you need a "Contains" line?

It depends on whether the label has an ingredients list.

Without an ingredients list – the usual case for beer over 1.2% vol – the allergens are declared with the word "contains" followed by the name from Annex II (Article 21(1)): "Contains barley." or "Contains barley and wheat." The regulation doesn't ask for a line of its own, but it makes the information easy to find. The allergens in a "Contains" statement don't need emphasis, though you may emphasise them if you like (FSA, paragraph 70). The line needs the same minimum x-height as the other mandatory particulars, 1.2 mm (Article 13(2)), but it doesn't have to be in the same field of vision as the name, strength and quantity (Article 13(5)).

With an ingredients list, there is no "Contains" line. The FSA says the regulation does not permit a voluntary statement such as "Contains: wheat, egg and milk" that repeats the allergens already in the list (paragraph 71). An "Allergy advice" line that only explains the emphasis is fine.

Examples from common beer styles

Style	Allergens	In the ingredients list	Without a list
Bitter, 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, covers "milk and products thereof (including lactose)", so a milk stout or a pastry stout with lactose must declare milk. The FSA says components made from milk, such as lactose, must have a clear reference to milk (paragraph 42): "Lactose (milk)". Without an ingredients list, the line reads "Contains barley and milk."

Article 21 does not require the declaration when the name of the food clearly refers to the allergen, and Business Companion gives "Milk Stout" as an example. A name such as "Pastry stout" doesn't, so it needs the declaration.

Fruit, spices and other additions

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

Nuts. A Christmas ale with almonds or a brown ale with hazelnuts must declare them: "almonds", "hazelnuts". Peanuts are a group of their own, so a peanut butter stout needs "peanuts". The nuts are a closed list (Annex II, point 8): the FSA notes that coconut, chestnuts and pine nuts are not named, and that they must not be emphasised in the ingredients list (paragraph 43). A coconut porter needs no allergen declaration for the coconut.

Sulphites. Sulphur dioxide and sulphites must be declared at more than 10 mg/l, counted as total SO₂ in the drink as consumed (Annex II, point 12). According to the FSA, this applies to sulphites that have been added, including those carried over in an ingredient, and below 10 mg/l no declaration is needed (paragraphs 48 and 50). It can apply to a fruit beer made with a sulphited fruit purée, so ask your supplier how much it contains. If the sulphite still works as a preservative in the beer, the ingredients list names it with its function, as in "Preservative: sulphur dioxide" (paragraph 49).

Celery, mustard, sesame and lupin are on the list too. They are rare in beer, but keep them in mind when a recipe gets experimental.

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

"May contain"

A precautionary statement such as "may contain wheat" is voluntary. The FSA says to use one only when a risk assessment has found a real risk of cross-contamination that can't be controlled by cleaning and segregation, and that it can be misleading if there is no real risk (paragraphs 24 and 25 and the best-practice note after them). Name the allergen, and within a group such as cereals or nuts the specific one: "may contain wheat" rather than "may contain cereals" (paragraphs 65 and 66).

A way to work

Go through the recipe one ingredient at a time and ask which cereal or which Annex II group it belongs to. Then write the ingredients from heaviest to lightest and emphasise only the allergens. If you don't want an ingredients list, gather the allergens in a "Contains" line.

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

Last checked: 21 October 2026

This guide explains labelling and is not legal advice. Rules can change – if you sell your drink, check with your local authority's trading standards or environmental health team.