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'Gluten-free' vs 'may contain': UK allergen labelling explained

What 'gluten-free', 'very low gluten' and 'may contain' mean on UK food labels, how allergens are emphasised and what Natasha's Law changed, with FSA sources.

Published Last reviewed 4 min read

Food labels are your most important tool on a gluten-free diet. UK law is actually quite helpful here. Once you know the four or five things to look for, checking a pack takes seconds.

1. The ingredients list: allergens must be emphasised

There are 14 allergens that food businesses must tell you about, and “cereals containing gluten” is one of them. Gov.uk lists these as including wheat, rye, barley and oats.

On prepacked food (a packet of crisps, a loaf of bread), any of the 14 allergens used as an ingredient must be emphasised in the ingredients list, for example in bold, italics or a different colour.

Coeliac UK adds that manufacturers name the specific cereal, so the words to scan for are:

  • wheat (and types of wheat such as spelt and khorasan/Kamut®)
  • rye
  • barley
  • oats

Even if only a tiny amount is used, it must still be listed.

Some cereal-derived ingredients are fine

Coeliac UK lists some ingredients that come from gluten-containing cereals but have the gluten removed during processing, so they are safe for people with coeliac disease: glucose syrup derived from wheat or barley (including dextrose), wheat-based maltodextrins, and distilled ingredients such as spirits (source).

2. “Gluten-free” and “very low gluten” are legally defined

These aren’t marketing phrases. They’re controlled terms under retained Regulation (EU) No 828/2014, summarised in the FSA’s technical guidance:

Claim What it means
Gluten-free No more than 20 mg/kg (20 parts per million) gluten in the food as sold
Very low gluten No more than 100 mg/kg, only for foods containing cereal ingredients specially processed to reduce gluten

The NHS says that for most people with coeliac disease, the trace amounts allowed in “gluten-free” food will not cause a problem.

The FSA guidance also says these rules apply to all foods, including non-prepacked food such as restaurant meals, and that no other statements describing the absence or reduced presence of gluten are permitted.

Gluten-free products can still list a cereal

You might see wheat, barley or oats in bold on a pack that also says “gluten-free”. The FSA explains that when a specially processed cereal ingredient (for example gluten-free oats) meets the legal requirements, the product can be called gluten-free, but the cereal must still be emphasised in the ingredients list. The “gluten-free” claim is what tells you it’s suitable.

3. “May contain”: precautionary allergen labelling (PAL)

“May contain wheat”, “made in a factory that handles cereals containing gluten”, “not suitable for people with a wheat allergy”… these are precautionary allergen labels (PAL).

Key facts from gov.uk’s guidance for businesses:

  • PAL is voluntary. Businesses are not legally required to use it.
  • It should only be used where a risk assessment finds a cross-contamination risk that cannot be controlled.
  • Vague statements such as “may contain allergens” should not be used.
  • A business should not use PAL together with a free-from claim for the same allergen.

Coeliac UK says that when you see one of these statements, the manufacturer has decided there is an unavoidable risk of cross-contamination with gluten. You can contact the manufacturer for more information.

The absence of a "may contain" warning is not a guarantee

Because PAL is voluntary, a product with no “may contain” statement hasn’t necessarily been tested for gluten. If a product is important to you and isn’t labelled gluten-free, check with the manufacturer or use Coeliac UK’s food information service.

“Gluten-free” plus “may contain”? It can happen

The FSA technical guidance gives an example where a product is labelled “gluten-free” and “may contain wheat (cereal)”. Testing has shown gluten below 20 mg/kg, but there’s a risk of trace cereal that could matter to someone with a cereal allergy. Such a product would be suitable for people with coeliac disease, but not for people allergic to that cereal.

4. Natasha’s Law: food made and packed on site

Since 1 October 2021, food that is prepacked for direct sale (PPDS) must carry a full label. Think sandwiches, salads or cakes made and packed on the premises before you order. The FSA explains that the label must show the name of the food and a full ingredients list, with any of the 14 allergens emphasised. This is known as Natasha’s Law.

5. Loose food: ask, and you must be told

For food that isn’t prepacked, such as bakery counter items, deli food or restaurant meals, businesses must still give you allergen information for any of the 14 allergens. Gov.uk says this can be given verbally or in writing. If it’s given verbally, they must tell you where to find written confirmation.

A 10-second label check

  1. Does it say gluten-free? If yes, it’s suitable for a gluten-free diet.
  2. If not, scan the ingredients for emphasised wheat, rye, barley, oats, spelt or khorasan.
  3. Check for a “may contain” statement mentioning a gluten cereal.
  4. Check every time. Coeliac UK warns that recipes and manufacturing processes can change without warning.

Ready to put this into practice? Read our starter guide to gluten-free shopping in UK supermarkets. Shopping abroad? See travelling abroad with coeliac disease for how labels work elsewhere. Drinks are labelled slightly differently; see gluten-free beer: what the labels mean.

Frequently asked questions

What does 'gluten-free' mean legally in the UK?

A 'gluten-free' claim can only be used if the food as sold contains no more than 20 mg/kg (20 parts per million) of gluten. 'Very low gluten' means no more than 100 mg/kg and applies only to foods containing specially processed gluten cereals.

Is 'may contain' labelling a legal requirement?

No. Gov.uk says food businesses are not legally required to use precautionary allergen labelling (PAL). It should only be used after a risk assessment identifies a cross-contamination risk that cannot be controlled.

Can a product say 'gluten-free' and 'may contain wheat'?

Yes, in some cases. FSA technical guidance gives the example of a product that might be contaminated with barley but has been tested and shown to contain less than 20 mg/kg gluten. It can be safe for people with coeliac disease but still be a risk for people with a cereal allergy.

What is Natasha's Law?

Since 1 October 2021, food that is prepacked for direct sale (PPDS), such as sandwiches made and boxed on the premises, must carry the name of the food and a full ingredients list with the 14 allergens emphasised.

Sources

  1. Understanding food labelling: allergen labelling, GOV.UK. Accessed 4 October 2026.
  2. Food labelling and packaging: precautionary allergen labelling (PAL), GOV.UK. Accessed 4 October 2026.
  3. Food allergen labelling and information requirements: technical guidance, Food Standards Agency. Accessed 4 October 2026.
  4. Commission Implementing Regulation (EU) No 828/2014 (as retained in UK law), legislation.gov.uk. Accessed 4 October 2026.
  5. Prepacked for direct sale (PPDS) allergen labelling changes for restaurants, cafés and pubs, Food Standards Agency. Accessed 4 October 2026.
  6. Coeliac disease: treatment, NHS. Accessed 4 October 2026.
  7. How to read food labels, Coeliac UK. Accessed 4 October 2026.