Allergen labelling in the Union is governed by Regulation (EU) No 1169/2011 on the provision of food information to consumers. Any of the fourteen substances or products listed in Annex II that is used as an ingredient or processing aid must be named in the ingredient list and emphasised typographically so it stands out from the rest of the list.
Why it works this way
The list is closed and specific, and three points in it are misread constantly in this category.
The tree nut entry names eight nuts: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia. A nut outside that list is not a listed allergen in the Union.
Coconut is not listed in the EU. It is treated as a tree nut for labelling purposes in some other jurisdictions, including the United States, so a product sold into several markets cannot rely on one rule.
Soybeans are listed and peas are not. The exemptions in Annex II cover fully refined soybean oil and fat and certain soy-derived tocopherols; they do not cover soy lecithin.
Precautionary statements such as “may contain traces of nuts” are a separate matter. There is no Union threshold, no defined wording and no requirement to apply one. Article 36 of the same regulation requires only that voluntary information must not mislead or be ambiguous, which means a statement applied by reflex rather than by risk assessment is the weaker legal position, not the safer one.
What follows in practice
Base any precautionary statement on a documented cross-contact risk assessment, keep the site allergen list and the label review linked, and require written notification from suppliers before a new allergen enters shared equipment. Allergen management in mixed facilities covers the controls behind the label, and the VITAL 3.0 assessment covers the framework most often used for the decision.