For direct farm sales, the useful rule is straightforward: if a food contains a regulated allergen that remains present in the finished product, the customer must be able to find that out before buying. The way the information is presented depends first on whether the food is prepacked, sold without packaging, packed at the buyer’s request or prepacked for immediate sale.

This matters less for plain fresh fruit and vegetables than for foods made from several ingredients: bread, biscuits, pâtés, cheese, pesto, preserves with added ingredients, prepared dishes or baskets containing several products. A clear description in a Seeed listing can help prepare the exchange, but it does not replace the label or the information that must remain available at the sale or pickup.

Start by classifying the product

Prepacked food

A food is prepacked when it was placed in packaging before being offered for sale and its contents cannot be changed without opening or altering that packaging. For most such products, the ingredients list is part of the mandatory information. Ingredients or processing aids that cause allergies or intolerances must be emphasised, for example through bold type, a different font or a background that clearly distinguishes them. Where an ingredients list is not required, the EU regulation provides for the word “contains” followed by the name of the allergen concerned.

Non-prepacked food or food packed for immediate sale

In France, food offered without packaging, packed at the customer’s request or prepacked for immediate sale must carry information that leaves no uncertainty about which food it refers to. France’s consumer authority, the DGCCRF, says that a notice or sign placed by the product must include its sales name and, where relevant, the presence of allergens.

An improvised spoken answer is therefore not a dependable system for a market stall, farm shop or pickup point. A written, current product sheet clearly linked to each recipe avoids relying on the memory of whoever happens to be serving.

Check the 14 regulated groups

Annex II to EU Regulation No 1169/2011 lists 14 categories that must be declared when used in manufacturing or preparation and still present in the finished food, even in an altered form:

  • cereals containing gluten, including wheat, rye, barley, oats, spelt and kamut;
  • crustaceans, eggs, fish and molluscs;
  • peanuts, soybeans and milk, including lactose;
  • the nuts named in the Annex, including almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia nuts;
  • celery, mustard, sesame seeds and lupin;
  • sulphur dioxide and sulphites above the regulatory threshold of 10 mg/kg or 10 mg/litre.

The Annex also contains precise exceptions for certain derivatives. Check the current legal text or seek advice from the relevant authority instead of assuming an exemption from an ingredient’s trade name.

Build an allergen record you can actually use

A small farm does not need an elaborate system, but it does need one reliable written source. For every processed product, create a sheet containing:

  1. the exact recipe, including every ingredient and processing aid used;
  2. supplier labels or specifications for compound ingredients such as chocolate, stock, spice blends or ready-made pastry;
  3. the allergens intentionally present, written with their regulated names;
  4. a recipe version and date, so any ingredient change triggers a fresh review;
  5. the matching customer-facing material: label, counter notice, market sheet or information shown before a distance order.

The record must follow what is really made, not a theoretical recipe. If a supplier changes an ingredient, a flour is substituted or a new product shares equipment, review the information before the next sale.

Do not confuse an ingredient with accidental presence

An allergen deliberately used in a recipe must be declared as such. Precautionary wording such as “may contain” addresses a different situation: a residual risk of unintended presence, for example despite separation and cleaning measures. The European Commission stresses that this wording is not a substitute for good manufacturing practice and should be based on a genuine risk assessment.

Adding “may contain all allergens” to every food is not a solution. First map how ingredients and utensils move through the workspace, separate activities where possible, plan production order, clean equipment and keep supplier information. If uncertainty remains, have the situation assessed rather than inventing a blanket warning.

Provide the information before an online order

For distance selling, allergen information cannot wait until pickup. The European Commission explains that mandatory information for prepacked food must be available before the purchase is concluded, apart from the durability or use-by date, which may be supplied at delivery. Allergen information for non-prepacked food sold at a distance must likewise be accessible before purchase and remain available when the food is handed over.

If you publish an offer among the products available nearby, avoid vague descriptions such as “homemade recipe” for a compound food. Explain at least how the buyer can obtain the complete information before confirming. At pickup, match each sheet to the right item, just as you would when organising local farm orders. The Seeed marketplace rules complement, but do not replace, the requirements that apply to your business and products.

A five-question final check

  • Does the product offered exactly match the documented recipe and batch?
  • Are deliberately used allergens named instead of hidden behind a general phrase?
  • Does the information clearly identify each product on sale?
  • Is it accessible before purchase when the order is placed remotely?
  • Can the person handing over the food find the current sheet without guessing?

If an ingredient or cross-contact risk is uncertain, pause sale of the affected batch while checking. For a complex product or workspace, contact the relevant French departmental authority, chamber of agriculture or a qualified food-safety adviser.

Sources

Photo: “Preserves, jams and pickled food at St. Jacobs Farmers Market”, Allie_Caulfield, via Wikimedia Commons, licensed CC BY 2.0. Resized by Wikimedia with no other alteration.