Allergen Labelling Law in the UK
UK Food Information Regulations require the 14 major allergens to be declared on pre-packed food. The 14 allergens are: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites, tree nuts.Natasha's Law (in effect since October 2021) extended mandatory allergen labelling to pre-packed for direct sale (PPDS) food — sandwiches, bakery items, and foods packaged on the premises before sale.
Important: QR codes cannot replace mandatory on-pack allergen labelling for pre-packed and PPDS foods under current UK law. All 14 allergens must be declared in text on the physical label. QR codes are a supplement providing additional depth, not a replacement.
Where QR Codes Add Value for Allergen Information
Full ingredient list: Where packaging space is limited (very small pack, cosmetics-style format), a QR linking to the full ingredient list and allergen information provides depth beyond what fits in print. The mandatory allergen declaration still appears on-pack.Recipe and reformulation tracking: When a recipe changes, a QR-linked digital ingredient page can be updated immediately. Consumers who scan get the current formulation. Printed packs in circulation with the old recipe still have the mandatory label — the QR provides advance notice of any change.
Multilingual allergen information: A QR links to the ingredient and allergen information in multiple languages — critical for imported products or products sold in multilingual markets. The UK legal requirement is fulfilled in English; additional languages via QR serve a broader consumer audience.
Detailed severity guidance: The mandatory label says "Contains gluten." A QR-linked page can explain: "This product is manufactured in a facility that also processes peanuts — there is a risk of cross-contamination. Not suitable for consumers with severe peanut allergy." This depth of information cannot reasonably fit on a physical label.
The FSA and QR Code Allergen Guidance
The Food Standards Agency has published guidance on QR codes for allergen information. Key points:- QR codes are not permitted as the sole mechanism for allergen disclosure on pre-packed food - They are acceptable as supplementary channels for additional detail - Any information accessible via QR that contradicts the on-pack mandatory label is a compliance risk
Review the most current FSA guidance before designing QR allergen communications.
