Allergen labelling
How to label compound ingredients
A compound ingredient is an ingredient that has its own ingredients. Chocolate, jam, mayonnaise, bought-in bread. They belong in your list with their own contents in brackets — and getting this wrong is behind most incorrect labels.
Reviewed against official guidance.SourcesNot legal advice.
What counts as a compound ingredient
Anything you put in that is itself made of more than one thing. If you bought it and it has an ingredients list on the back, it is compound.
| Compound | What is usually inside |
|---|---|
| Dark chocolate | cocoa mass, sugar, cocoa butter, emulsifier (often soya lecithin) |
| Bought-in bread | wheat flour, water, yeast, salt, emulsifier, sometimes soya flour |
| Mayonnaise | rapeseed oil, egg yolk, vinegar, mustard |
| Pesto | basil, oil, nuts, hard cheese, garlic, salt |
| Jam | sugar, fruit, gelling agent, acidity regulator |
| Stock | salt, vegetables (often celery), yeast extract, flavourings |
| Ready-to-roll icing | sugar, glucose syrup, fat, glycerine, emulsifiers |
How to write it
The compound ingredient’s own name, then its ingredients in brackets, in their own order of weight. Allergens inside the brackets get emphasised exactly as they would outside.
Dark chocolate (cocoa mass, sugar, cocoa butter, emulsifier: SOYA lecithin)
The compound ingredient sits in the main list according to its own total weight — 200 g of chocolate is 200 g, however that divides up inside the brackets.
Cocoa butter is not dairy
A classic false positive. Cocoa butter is a plant fat with no milk in it. The same applies to shea butter, peanut butter and butter beans — and to coconut, almond and oat “milk”, none of which are milk for allergen purposes.
The 2% exemption
Guidance allows exemptions for compound ingredients that make up less than 2% of the finished product, subject to conditions. It is narrower than people hope, and it comes with one absolute limit:
Allergens are never exempt
Whatever the quantity, an allergen present in the product must be declared. The 2% exemption never removes an allergen from a label.
In a small kitchen the exemption is rarely worth using. Working out whether a flavouring is 1.8% or 2.1% of a traybake takes longer than writing the three extra words, and it gives you something else to re-check every time the recipe moves.
A worked sandwich
A sandwich is almost entirely compound ingredients — which is why it is the hardest thing on most counters to label.
Chicken & Pesto Sandwich
Ingredients: Bread (WHEAT flour, water, yeast, salt), Cooked chicken breast, Pesto (basil, sunflower oil, CASHEW nuts, hard cheese (MILK), garlic, salt), Mayonnaise (rapeseed oil, EGG yolk, vinegar, MUSTARD), Rocket.
Three compound ingredients, each carrying allergens of its own:
- Bread — wheat, and sesame if it is seeded
- Pesto — a named nut, and milk from the cheese
- Mayonnaise — egg, and mustard almost always
Miss the brackets on any one of them and the label is wrong in a way that matters.
Getting the information
- Use the declaration on the pack, not the product name or a spec-sheet summary.
- Photograph it when you open a new batch. Faster than transcribing, and it is evidence.
- Date it. A declaration is a snapshot of one batch.
- Re-check when the packaging design changes. New artwork is often a sign of a new recipe.
Common mistakes
- Writing just “chocolate”. The soya disappears, and so does everything else in the tub.
- Flattening the brackets. “dark chocolate cocoa mass sugar soya lecithin” — now nobody can tell where the chocolate ends.
- Using the brand name. A customer cannot look up what is in your supplier’s product.
- Forgetting the emphasis inside the brackets. The soya in there needs it as much as the wheat outside.
- Copying last year’s brackets. The declaration you transcribed in 2024 may not describe the tub you opened this morning.
The last one is a maintenance problem rather than a writing problem — here is the routine for catching it.
Questions
Do I have to break out every compound ingredient?
What if a compound ingredient contains another compound ingredient?
Official sources
Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.
- Labelling guidance for prepacked for direct sale (PPDS) food productsFood Standards Agency / GOV.UK
- Food allergen labelling and information requirements technical guidanceFood Standards Agency / GOV.UK
- Food labelling: giving food information to consumersGOV.UK
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