Guide
US vs UK food labeling: the differences that actually matter
The US has nine major allergens and usually wants Nutrition Facts, net quantity and a business address on packaged food. The UK PPDS pack wants the name and a full ingredients list with 14 allergens emphasised. Sesame is in both lists; celery, mustard, lupin, molluscs and sulphites are UK majors, not FALCPA majors.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
The US has nine major allergens and usually wants Nutrition Facts, net quantity and a business address on packaged food. The UK PPDS pack wants the name and a full ingredients list with 14 allergens emphasised. Sesame is in both lists; celery, mustard, lupin, molluscs and sulphites are UK majors, not FALCPA majors.
Where this shows up in a real kitchen
Brands that sell in Brooklyn and Hackney keep one InDesign file. That file is wrong in at least one country every time. UK emphasis (bold/caps) is not a FALCPA requirement. US Contains lines are not a UK legal format. Nutrition Facts are not UK traffic lights.
The US rule
FALCPA + 21 CFR 101 vs retained FIC / UK PPDS rules. FASTER Act sesame vs UK sesame as Annex II. FDA sulphites 10 ppm labeling vs UK sulphites as a major allergen with emphasis. USDA BE disclosure has no UK twin of that shape. Cite FDA and FSA separately; do not blend them into “Western food law”.
How to apply it
Keep two matrices. Keep two pack templates. Translate soya/soy, sulphur/sulfur, colour/color in the customer-facing language of that market. Never tell a US inspector you followed Natasha’s Law instead of FALCPA.
- Split SKUs or at least split art files by market.
- Run the nine-allergen US check and the 14-allergen UK check separately.
- Add US Nutrition Facts and net quantity only on US retail packs.
- Have a native reader proof each language, not Google Translate in the legal block.
Worked example
The same mustard-and-celery slaw: UK PPDS pack emphasises MUSTARD and CELERY (and any wheat, egg, milk). US FDA pack lists mustard and celery as ordinary ingredients, declares any of the nine majors, and adds Nutrition Facts and net quantity if it is retail packaged food. Mustard is not a FALCPA Contains name.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| Sesame is on both, with the right legal furniture | US Contains vs UK emphasis. |
| Celery is not in the US Contains line by default | It is a UK major. |
| Nutrition Facts only on the US pack | Do not glue a 101.9 panel onto a UK PPDS ticket unless you mean to. |
| Soy vs soya matches the market | Shoppers search the word they know. |
One “global allergen box” with 14 names on a US granola
You will declare UK-only majors as if they were FALCPA, and you may still miss US net quantity. Two honest packs beat one muddled pack.
What LabelClear can and cannot print
LabelClear is built around UK PPDS emphasis. For a US pack, use it to get the ingredients list honest, then apply FALCPA names, Nutrition Facts and net quantity.
Questions
Can I sell the UK pack as-is in a US store?
Is sesame new in both places?
Do both countries require bold?
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.
- Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA)U.S. Food and Drug Administration
- Food allergiesU.S. Food and Drug Administration
- Food Labeling GuideU.S. Food and Drug Administration
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