Is soybean oil an allergen under Annex II?

Fully refined soybean oil and fat are exempt. Unrefined or cold-pressed soy oil, and other soy products such as soy sauce, tofu and soy lecithin, must still be declared.

Are pine nuts or coconut in the EU allergen list?

No. The nuts entry names only almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia (Queensland) nuts. Pine nuts and coconut are outside Annex II, but you should still answer guests' questions about them accurately.

Does the sulphite threshold apply to the wine or the dish?

To the food as it is ready for consumption. A dish containing wine, dried fruit or treated seafood may exceed 10 mg/kg of total sulphur dioxide even if each ingredient seems minor, so declare it when in doubt and check supplier data.

Yes. Article 21(2) requires the Commission to keep the list under review against scientific evidence and lets it amend the annex by delegated act. Check the consolidated text on EUR-Lex rather than relying on an old printout.

EU 1169/2011 Annex II: the 14 allergens, word for word, with the exemptions

Q: How many allergens are in Annex II of EU 1169/2011?

Fourteen: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin and molluscs.

By the Menulta editorial team · Facts checked 15 October 2026 · Updated 15 October 2026

The short answer

Annex II of Regulation (EU) No 1169/2011 is the list of 14 substances or products causing allergies or intolerances that must be declared on food sold in the EU: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre, lupin and molluscs. Several entries carry narrow exemptions, such as fully refined soybean oil and wheat-based glucose syrups, which do not need to be declared.

Why Annex II matters more than any other part of the regulation

Article 9(1)(c) makes allergen information mandatory, and Article 21 sets out how it is shown, but both point back to Annex II for the actual list. If a substance is not in Annex II, the regulation does not require it to be declared as an allergen. If it is, it must be declared whether the food is prepacked or served loose in a restaurant, under Article 44.

The annex covers ingredients and processing aids. A substance used in production that is still present in the finished food, even in altered form, counts. That is why a stock made with celery or a sauce thickened with wheat flour must be declared even when nobody can see the celery or the flour on the plate.

The 14 entries and their exemptions

The table follows the order and wording of Annex II. The exemptions column lists the specific derived products the annex excludes. They are excluded because processing removes almost all of the allergenic protein. Nothing outside these exemptions is excused.

Regulation (EU) No 1169/2011, Annex II, summarised
No.	Annex II entry	Exemptions written into the annex
1	Cereals containing gluten: wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof	Wheat-based glucose syrups including dextrose; wheat-based maltodextrins; glucose syrups based on barley; cereals used to make alcoholic distillates
2	Crustaceans and products thereof	None
3	Eggs and products thereof	None
4	Fish and products thereof	Fish gelatine used as a carrier for vitamin or carotenoid preparations; fish gelatine or isinglass used as a fining agent in beer and wine
5	Peanuts and products thereof	None
6	Soybeans and products thereof	Fully refined soybean oil and fat; certain natural tocopherols (E306) and phytosterols from soybean sources; plant stanol ester from soybean sterols
7	Milk and products thereof (including lactose)	Whey used to make alcoholic distillates; lactitol
8	Nuts: almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts, and products thereof	Nuts used to make alcoholic distillates
9	Celery and products thereof	None
10	Mustard and products thereof	None
11	Sesame seeds and products thereof	None
12	Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of total SO2	Below the threshold, calculated for the product as ready for consumption or as reconstituted
13	Lupin and products thereof	None
14	Molluscs and products thereof	None

Exemptions kitchens get wrong

The exemptions are narrow and they apply to specific derived products, not to whole families of food. Reading them too broadly is one of the commonest ways a restaurant's allergen record goes wrong.

Refined versus cold-pressed soy oil. Only fully refined soybean oil is exempt. A cold-pressed or unrefined soy oil, soy sauce, tofu or soy lecithin is still a declarable soy product.
Glucose syrup is not the same as flour. The wheat-based glucose syrup in a bought-in dessert is exempt, but the same supplier's wheat-flour sponge is not.
Spirits are exempt, liqueurs may not be. Cereals, whey and nuts used to make alcoholic distillates are exempt. A nut liqueur flavoured with nut extract after distillation, or a cream liqueur, still needs checking against its own label.
Isinglass in beer, not fish in the kitchen. The fish exemption covers fining agents in beer and wine. It does not cover anchovy in a dressing or fish sauce in a marinade.
Sulphites depend on the plate, not the bottle. The 10 mg/kg threshold applies to the food as served. A wine reduction, dried apricots, some vinegars or a prawn treated with sulphites can push a dish over it.

What counts as 'products thereof'

Almost every entry ends with 'and products thereof'. Anything made from the allergen is covered unless an exemption names it. Butter, cream, cheese and whey powder are milk. Tahini and halva are sesame. Mayonnaise, aioli and fresh egg pasta are egg. Pesto made with cashews is nuts. Soffritto, stock cubes and celery salt are celery.

The nuts entry is a closed list of eight named nuts. Pine nuts, chestnuts and coconut are not in Annex II, so the regulation does not require them to be declared as allergens. Guests can still be allergic to them, and answering their questions accurately is part of good practice and your general duty not to mislead.

Using Annex II to build a dish-level allergen record

The reliable method is to go recipe by recipe, ingredient by ingredient, including the components you buy in: stocks, sauces, breads, pastes and desserts. For each one, check the supplier's label for the 14 and copy any that apply to the dish. Do not work from memory or from the dish name.

Record the specific source where it helps a guest choose. 'Gluten (barley)' or 'nuts (pistachio)' is more useful than a bare category, because some guests react to one cereal or one nut and not another. Review the record whenever a supplier, recipe or menu item changes. Most allergen incidents in restaurants follow an unannounced ingredient swap, not a missing column.

Sources

This guide is general information, not medical or legal advice. Guests with an allergy should follow their doctor's advice. Operators should confirm their own setup with their food safety adviser or local authority.