From January 2026, stricter requirements will come into force in the European Union regarding the listing of allergens on food labels. Manufacturers, private-label brands and importers are obliged to provide allergen information in a clearer, more consistent and more comprehensive manner than before. This article answers the most frequently asked questions about the new allergen legislation and what it means in practical terms for your brand or range of supplements.
What specific changes will come into effect from January 2026?
From January 2026, stricter requirements will apply to the visual presentation and completeness of allergen information on food labels within the EU. Allergen legislation requires that the fourteen recognised allergens must henceforth be highlighted even more clearly in relation to the other ingredients, for example by using a different font, bold text or a different colour. In addition, there are stricter requirements regarding the communication of potential cross-contamination.
In practical terms, this means that the presentation of allergen information must meet stricter requirements regarding legibility and layout. Whereas some manufacturers previously made do with a generic “may contain traces of” statement, more specific guidelines are now expected on how and when such statements may be used. This has a direct impact on how product labels are designed and approved.
Furthermore, for companies operating in several EU countries, it is important to be aware that implementation may vary slightly from one Member State to another in terms of enforcement and interpretation, even though the underlying European regulation is uniform. It is advisable to check for any additional national requirements in each target market.
Which allergens have been newly added to the mandatory list?
The mandatory list of fourteen allergens under EU legislation (Regulation 1169/2011) has not been expanded to include entirely new categories as of January 2026, but the application and verification of existing categories have been tightened up. However, active research is being carried out at European level into the possible extension of the list to include substances such as sesame seeds, mustard and lupin, which are already on the current list but for which enforcement is set to become stricter.
The fourteen allergens that must be listed remain:
- Gluten (wheat, rye, barley, oats and derivatives)
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soya
- Milk (including lactose)
- Nuts (almonds, hazelnuts, walnuts, cashew nuts, pecans, Brazil nuts, pistachios, macadamia nuts)
- Celery
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites
- Lupin
- Molluscs
The main change lies in the documentation requirement: manufacturers must now be able to demonstrate that their allergen management system is up to date and that cross-contamination risks are actively monitored and documented.
How do these regulations affect private-label supplement manufacturers?
For private-label supplement manufacturers, the new rules have direct implications for both production management and label design. Manufacturers are responsible for ensuring a comprehensive and up-to-date allergen management system, which means that raw material suppliers must be reassessed, production processes must be documented, and labels must be revised if the current layout does not meet the new legibility requirements.
The risks are particularly high in the supplements sector, as many products contain ingredients that naturally contain allergens, such as whey (milk), soya protein or nuts in functional blends. However, even products that do not themselves contain allergens may be at risk of cross-contamination due to shared production lines. This must be clearly and accurately stated on the label.
Private-label brands that outsource their production bear contractual responsibility for the accuracy of the labelling information. It is therefore essential that the agreements with the production partner set out in writing who is responsible for allergen validation, documentation and label approval.
What are the consequences of failing to comply with the new rules?
Failure to comply with allergen legislation can result in serious legal, financial and reputational damage. The most immediate consequences are product recalls, fines imposed by national food authorities and sales bans. In serious cases where a consumer suffers harm as a result of an undeclared allergen, criminal liability may apply.
In addition to the direct sanctions, there are also indirect consequences. Retailers and distributors are increasingly demanding demonstrable compliance as a condition for working together. A brand that cannot demonstrate that its labels are correct and up to date runs the risk of being removed from the shelves or losing contracts. For private-label brands operating in supermarkets or via major e-commerce platforms, this is a real risk.
The Netherlands Food and Consumer Product Safety Authority (NVWA) actively carries out checks on allergen labelling, both at manufacturers and retailers. Non-compliant products are publicly reported via the NVWA reporting centre, which results in immediate reputational damage.
When must existing labels and packaging be updated?
Existing labels and packaging must be amended by the date the new requirements come into force at the latest; for most of the stricter requirements, this is January 2026. There is no formal transition period for products already in circulation with existing stock, unless national authorities explicitly state otherwise.
In practice, this means that companies still holding stock with outdated labels must use it up or relabel it as soon as possible. It is advisable to contact your production partner and label designer straight away to determine what changes are required and how quickly they can be implemented.
For new product launches, labels must now comply with the new requirements from the outset. It is therefore not an option to launch a new product with a label that is not compliant, even if the product itself has already been developed and manufactured.
How do you prepare a private-label brand for the changes to allergen labelling?
A private label brand can best prepare for the new allergen legislation by following a structured compliance approach that starts with the raw materials and ends with the approved label. This requires collaboration between the brand owner, the manufacturing partner and, where necessary, a food safety adviser.
A practical approach consists of the following steps:
- Carry out an allergen audit For all your current products: which allergens are present and what are the risks of cross-contamination?
- Check all raw material suppliers Check the latest allergen specifications and request updated technical data sheets.
- Rate all labels in terms of layout and completeness: do they meet the new readability and disclosure requirements?
- Amend the food safety plan so that allergen control is demonstrably documented.
- Have labels validated by an expert before you commission the production of new batches or continue to sell existing stock.
The sooner you start this process, the lower your risk of costly delays or product recalls. Don’t wait for an inspection or a complaint before taking action.
How MixMasters helps with allergen compliance
We understand that the new allergen legislation presents a significant administrative and technical challenge for many private-label brands. As a full-service manufacturing partner for powdered food supplements, we actively support our clients in complying with all applicable food safety requirements, including allergen regulations.
What we offer in concrete terms:
- BRCGS-certified production, with allergen control forming an integral part of our quality system
- A comprehensive food safety plan (HACCP-based), drawn up in collaboration with certified consultants and specifically tailored to your product range
- Label support, including checks on legally required information such as allergen labelling, layout and legibility
- Traceability of raw materials and batches, so that you can always show which ingredients are used in which product
- Advice on product development, taking allergen risks and cross-contamination control into account at an early stage
Whether you’re an established brand looking to have your supplements range tested for compliance, or you want to launch a new private-label range that meets the 2026 requirements straight away: we’ll guide you from concept to a compliant product. Take a look at our comprehensive service or Please contact us directly for a no-obligation chat about your situation.
Frequently Asked Questions
Does the new allergen legislation also apply to products that I had already placed on the market before January 2026?
Yes, the new requirements apply to all products placed on the market after the effective date, regardless of when they were manufactured. Products with outdated labels that are still in your stock may, in principle, no longer be sold once the rules come into force. It is advisable to take stock of your remaining stock and work with your manufacturing partner to determine whether relabelling is required before you distribute those products further.
What is the difference between a 'contains' statement and a 'may contain traces of' statement, and when should I use which one?
Een ‘bevat’-vermelding gebruik je wanneer een allergeen daadwerkelijk als ingrediënt in het product aanwezig is; dit is wettelijk verplicht voor alle veertien erkende allergenen. Een ‘kan sporen bevatten van’- of ‘geproduceerd in een omgeving waar ook X wordt verwerkt’-vermelding is bedoeld voor kruisbesmettingsrisico’s die voortkomen uit gedeelde productieruimtes of apparatuur. Onder de aangescherpte regels mag deze laatste vermelding niet meer als standaard disclaimertekst worden gebruikt zonder een aantoonbare risicobeoordeling die het gebruik ervan onderbouwt.
How do I know if my current label design already meets the new legibility and layout requirements?
Check whether the fourteen mandatory allergens in the list of ingredients are clearly distinguished from the other ingredients, for example by using bold text, capital letters or a different colour. If the allergens are difficult to distinguish during a quick visual scan, or if the font size is smaller than the legally required minimum, your label is likely to be non-compliant. If in doubt, have the design assessed by a specialist labelling expert or your production partner before having new batches printed.
What specific provisions should I include in my contract with my production partner regarding responsibility for allergens?
Ensure that the contract specifies, at the very least, who is responsible for drawing up and keeping the allergen management system up to date, who approves the labels to ensure they comply with the law, and what the procedure is in the event of a change to raw materials or the production environment. Also stipulate that the production partner is obliged to inform you immediately should any changes occur that could affect the allergen labelling on your product. Without these agreements in writing, you, as the brand owner, run the risk of being held liable yourself in the event of non-compliance.
My supplement does not contain any of the fourteen allergens — do I still need to make any changes?
Mogelijk wel, afhankelijk van je productieomgeving. Zelfs als jouw product zelf geen allergenen bevat, ben je verplicht om kruisbesmettingsrisico’s te beoordelen en te documenteren als je product wordt geproduceerd op lijnen waar ook allergenen worden verwerkt. Als uit die beoordeling een reëel risico blijkt, moet dit correct op het etiket worden vermeld. Is er aantoonbaar geen risico, dan hoef je geen kruisbesmettingsvermelding toe te voegen — maar die conclusie moet wel schriftelijk zijn onderbouwd.
What common mistake must private-label brands absolutely avoid when transitioning to the new rules?
One of the most common mistakes is blindly accepting allergen information from the manufacturing partner without verifying it yourself. As the brand owner, you bear ultimate responsibility for the accuracy of the labelling information, even if the error was made by a supplier. Always check yourself — or have an expert check — that the allergen specifications you have received are correct and up to date, and document this verification process in writing as part of your quality system.
Are there specific rules regarding the listing of allergens on English-language labels for the Dutch market?
For products sold in the Netherlands, the mandatory labelling information — including allergen information — must be provided in Dutch, unless the information is understandable to the average consumer even without a translation. In principle, English-language labels are not permitted on the Dutch market without a Dutch-language supplement. For brands operating in several EU countries, a multilingual label or a market-specific sticker is the most practical solution, provided that all mandatory information is correctly and fully displayed in each language.
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