Food information

Article 21 requires a distinguishing typeset. It does not say bold

Direct answer. EU law does not literally require bold. Regulation (EU) No 1169/2011, Article 21(1)(b), requires the Annex II allergen name to be “emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour.” Bold is one common way to do that. The quotes on this page are from the English original in the Official Journal. The consolidated text 02011R1169 — EN — 01.04.2025 — 004.001 prints the same Article 21 wording, with no amendment marker inside Article 21. EUR-Lex says that consolidation is a documentation tool and has no legal effect. This page is not legal advice.

EU Food Info Guard (Shopify App Store · Write a review): “Review allergen, ingredient, nutrition, net quantity, origin, operator, and storage gaps before food product display.”

Related: FibreLedger Textile Labels — EU fibre composition uses Annex I names.

Free check first: EU food label particulars checklist runs in your browser and sends nothing.

Checklist before you emphasise an ingredient

Use the Annex II name, with a clear reference, inside the ingredient list. That is Article 21(1)(a).
Emphasise that name by a typeset that distinguishes it. Font, style, or background colour are the examples in Article 21(1)(b). Bold is a style. It is not the only example the article gives.
Use the word “contains” only in the case the article states: there is no list of ingredients.
The 14 Annex II entries are on the EU 14 allergens list. This page does not repeat them.
Distance selling is Article 14(1), one line below, then nutrition and net quantity before purchase.

Article 21(1), as printed

Article 21(1) opens: “Without prejudice to the rules adopted under Article 44(2), the particulars referred to in point (c) of Article 9(1) shall meet the following requirements:”

(a) they shall be indicated in the list of ingredients in accordance with the rules laid down in Article 18(1), with a clear reference to the name of the substance or product as listed in Annex II; and

(b) the name of the substance or product as listed in Annex II shall be emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour.

The three subparagraphs that follow, still in Article 21(1):

In the absence of a list of ingredients, the indication of the particulars referred to in point (c) of Article 9(1) shall comprise the word ‘contains’ followed by the name of the substance or product as listed in Annex II.

Where several ingredients or processing aids of a food originate from a single substance or product listed in Annex II, the labelling shall make it clear for each ingredient or processing aid concerned.

The indication of the particulars referred to in point (c) of Article 9(1) shall not be required in cases where the name of the food clearly refers to the substance or product concerned.

A line such as “for allergens see ingredients in bold” is not a sentence in Article 21. The article requires the Annex II name itself to be emphasised in the list. The word “contains” is required in the case the first of those three subparagraphs states, which is the absence of a list of ingredients. Precautionary “may contain” wording is not Article 21. It is discussed on precautionary allergen labelling.

Distance selling, in one line

Article 14(1) opens: “Without prejudice to the information requirements laid down in Article 9, in the case of prepacked foods offered for sale by means of distance communication:” What must be available before purchase, and what may wait, is nutrition and net quantity before purchase.

The emphasis has to be in the HTML the customer reads

Article 21(1)(b) is about the typeset of the ingredient list. On a product page, that list is HTML. A heavier style can be marked with <strong> or <b> in a rich-text ingredients field. Those tags are one way to set a style. The article also gives font and background colour as examples, so a tag name is not itself the legal test. How a theme block shows the allergen field is allergen theme-block sync. An allergen named in ingredients but missing from the declared list is ingredient text versus the declared list.

On legislation.gov.uk, the retained text of Article 21(1)(b) is the same emphasis sentence: the Annex II name “shall be emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour.”

What this page is not

Not legal advice, and not a finding that a given ingredient list is lawful.
Not the list of 14 allergens. That page is Annex II.
Not “may contain” wording. That page is precautionary allergen labelling.
Not the full set of particulars before purchase. Start at allergen information before purchase.

EU food label particulars checklist
EU 14 allergens list
Nutrition and net quantity before purchase
Allergen theme-block sync
Ingredient text versus the declared list
Precautionary allergen labelling
Allergen information before purchase
EU Food Info Guard and FoodLabelKit
Best before and use by
Regulation (EU) No 1169/2011 — English Official Journal
EU Food Info Guard — live App Store listing
Shopify apps hub
Tools

Not legal advice. Confirm Article 21 of Regulation (EU) No 1169/2011, and Annex II, on EUR-Lex before you treat a typeset as sufficient. The app reviews gaps in the food information you enter. It does not decide that a label is lawful.