Labelling of allergens in unpackaged bread products

In Germany, the law requires you to provide a clear declaration of allergenic ingredients (Allergene), even when you sell unpackaged bread and bakery products (lose Brotwaren) – such as baked goods displayed behind glass or on open shelves.

This obligation is governed by:

• the Food Information Regulation (Lebensmittelinformationsverordnung – LMIV, EU Regulation No. 1169/2011)

• enforced locally by municipalities through food control authorities (Lebensmittelüberwachung)

Does the obligation also apply to non-prepacked products?

Yes. Even without any packaging or label, the customer must be able to see clearly whether a product contains one or more of the 14 mandatory allergens.

What are the 14 mandatory allergens? (according to LMIV – Annex II)

• Gluten-containing cereals (such as wheat, barley, rye, spelt, malt, etc.)

• Crustaceans (e.g. shrimp)

• Eggs

• Fish

• Peanuts

• Soybeans (soya)

• Milk (including lactose)

• Tree nuts (e.g. almonds, walnuts, hazelnuts, etc.)

• Celery

• Mustard

• Sesame seeds

• Sulphur dioxide and sulphites (at concentrations of 10 mg/kg or more)

• Lupin

• Molluscs (e.g. mussels, clams, squid)

How should allergens be declared for bread and bakery products?

Form – Allowed? – Remarks

• No label and no verbal information
  – Not allowed
  – Direct and clear violation of the law

• Written list next to the shelf
  – Yes
  – Must be clearly visible, easy to read and kept up to date

• Sign stating that allergen information is available verbally
  – Yes
  – Only if staff are fully trained and able to provide accurate information

• Separate list at the checkout or in a folder
  – Yes
  – Provided it is clearly presented to the customer before purchase

Official recommendation:
In practice, authorities recommend that there should always be a printed written allergen list next to the products.

Practical example:

For a flaxseed bread (Leinsamenbrot), the allergen information might read:

Allergens:
Contains: wheat (gluten), sesame, milk
May contain traces of: eggs, soya, tree nuts.

Your responsibilities as a bakery:

Obligation – Explanation

• Prepare a list of ingredients and allergens for each product
  – Should be reviewed and approved by the production manager or master baker.

• Train your staff
  – Employees must understand each product and its main ingredients so they can give correct and reliable information to customers.

• Update regularly
  – Whenever a recipe changes, the allergen declaration and any displayed lists must be updated immediately.

• Keep a copy available for inspections
  – Local food control officers may request to see the current allergen and ingredient lists at any time.

What are the consequences if you do not comply with allergen disclosure rules?

• Violation of food hygiene and information regulations

• Fines of up to €5,000

• Public naming of the bakery on authority websites under headings such as
  “Violations of food law (Verstöße gegen Lebensmittelrecht)”

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The editorial team of this website strives to provide accurate information based on thorough research and consultation of multiple sources. Nevertheless, errors may occur or some information may be incomplete or not fully verified. Therefore, please regard the information in these articles as an initial point of reference and always contact the competent authorities for definitive and binding guidance.