Allergens
“May contain” vs “contains”: what is the difference?
“Contains” is a legal requirement. When one of the 14 Annex II allergens is used deliberately as an ingredient, it must be declared and emphasised in the ingredient list — with no threshold.
“May contain” is voluntary. It signals possible unintentional presence, and it is not harmonised: two manufacturers can use it — or omit it — for very different situations.
Last reviewed: Written and reviewed by the PRODX team against the sources listed below.
What “contains” guarantees you
Regulation (EU) No 1169/2011 requires that any ingredient listed in Annex II — the list of 14 allergenic substances — appears in the ingredient list and is 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”.
The essential point: this requirement carries no threshold (the exception being sulphur dioxide and sulphites above 10 mg/kg or 10 mg/l). If the allergen is an ingredient, it is declared, however small the quantity.
What “may contain” does not guarantee
Precautionary allergen labelling — “may contain”, “may contain traces of”, “made in a facility that also handles” — concerns the unintentional presence of an allergen: cross-contact on a production line, a shared ingredient, a shared facility.
These phrases are not among the regulation’s mandatory particulars. They remain permitted, but no EU rule currently defines when to use them or what they imply. The direct consequence: their absence does not prove the absence of risk, and their presence quantifies nothing.
Under Article 36 the European Commission has the power to adopt implementing rules for this voluntary labelling, and work towards harmonisation is under way.
How to read the two together
- Look for the allergen inside the ingredient list first, in bold or otherwise emphasised. That is the regulated information.
- Then read the precautionary statement, usually placed after the list. That is a manufacturer’s decision.
- Do not treat the absence of a precautionary statement as a guarantee. It is not one.
Read this before relying on this page
This page describes an EU labelling regulation. It does not tell you whether a product is safe for you, and it is neither medical nor allergy advice.
Rules differ between jurisdictions, and manufacturers change recipes and production sites without notice. The current physical packaging is the authority. For an allergy, follow the guidance of your doctor or allergist.
How PRODX shows the two
PRODX shows declared allergens and “may contain” statements separately, precisely because their regulatory status differs. A result with no conflict means the absence of a known conflict, not clearance — and the packaging remains the reference.
Sources
- 1.Regulation (EU) No 1169/2011 on the provision of food information to consumers — Article 9(1)(c), Article 21, Annex II — European Parliament and Council, 2011
- 2.Food information to consumers — legislation and allergen labelling — European Commission, Directorate-General for Health and Food Safety, 2026
Check this on a real product
Reading about a label is one thing. Scanning the pack in front of you and seeing it read against your own profile is the other half.
Allergen scanner