Allergen 2 of 14 · Gl
Cereals containing gluten: name the cereal, not the gluten
The allergen is not “gluten”: it is four cereals (wheat, rye, barley and oats) and anything made from them. On a label you name the cereal; on the matrix the column covers all four.
Checked against the official guidance on 18 September 2026
What the law covers
Annex II lists “cereals containing gluten, namely: wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof”. Spelt and khorasan (sold as Kamut) are wheat.
Exempt from declaration (Annex II):
- Wheat-based glucose syrups, including dextrose
- Wheat-based maltodextrins
- Glucose syrups based on barley
- Cereals used for making alcoholic distillates, including ethyl alcohol of agricultural origin (so whisky, gin and vodka are not declared)
Where it hides in a UK kitchen
| Where | Why |
|---|---|
| Soy sauce | Brewed with roasted wheat. Tamari is often wheat-free, not always. |
| Malt vinegar | Brewed from barley: chips with malt vinegar, pickled onions, piccalilli and brown sauce all carry barley. |
| Beer and beer batter | Barley, sometimes wheat. The batter carries it into the fish and into the fryer oil. |
| Sausages and burgers | Most British sausages and many butcher's burgers are bound with rusk, which is wheat. |
| Oats and oat milk | Oats are one of the four cereals. The flapjack, the crumble topping and the oat flat white all go in the column. |
| Stock, gravy, roux | Many stock cubes and gravy granules contain wheat; a roux is flour and butter. |
| Couscous, bulgur, semolina, seitan | All wheat, even though none of them says so. |
In the free matrix builder, typing any of these ticks gluten automatically: Wheat flour, Spelt, Rye, Barley, Oats, Couscous, Bulgur wheat, Semolina, Seitan, Bread, Burger bun, Brioche, Pitta bread, Naan, Chapati, Crumpet… These prompt a label check instead, because it depends on the recipe or the brand: Tamari, Hoisin sauce, Oyster sauce, Worcestershire sauce, Miso, Stock, Gravy, Piccalilli, Pickles, Vinegar, Taramasalata, Frangipane.
Cross-contact to think about
- The fryer: battered fish, scampi and onion rings leave batter in the oil the chips are cooked in.
- Flour in the air of a bakery or a pizza kitchen settles on everything around the bench.
- Toasters, bread knives and boards shared between normal and gluten-free bread.
Where your risk assessment finds a risk you cannot control, mark the dish “may contain” on the matrix. Don't use it as a blanket statement: when “may contain” is justified.
On a PPDS label
NOT ENOUGH
Flour, gluten, oats
CLEAR
Wheat flour, oats
The law lists the cereals by name and the FSA's guidance is to name the cereal: “gluten” on its own does not tell a customer which cereal is in the food.
Make a PPDS label with allergens emphasised automatically →
Mistakes we see on matrices
- Writing “contains gluten” instead of naming wheat, barley, rye or oats.
- Leaving the oat milk option out of the matrix.
- Calling chips gluten-free when they share oil with battered food.
Not on the list
Rice, maize (corn), buckwheat, quinoa, millet and teff are not cereals containing gluten. They can still pick up wheat through cross-contact, and “gluten-free” is a separate claim with its own legal limit.
Gluten: questions from kitchens
Is oats an allergen if the oats are gluten-free?
Oats are named in the list, so they are declared as a cereal containing gluten. A “gluten-free” claim on oats is a separate question with its own rules.
Do I need to declare whisky?
No. Cereals used to make alcoholic distillates are exempt, so whisky, gin and vodka are not declared. Beer, which is brewed rather than distilled, is.
Official sources
- Regulation (EU) No 1169/2011, Annex II — substances or products causing allergies or intolerances — legislation.gov.uk (version applying in Great Britain).
- Allergen guidance for food businesses — Food Standards Agency (GOV.UK), updated 17 July 2026.
- Food allergen labelling and information requirements: technical guidance — Food Standards Agency (GOV.UK), published 23 August 2023, revised March 2025.
- Regulation (EU) No 1169/2011, Article 21 — labelling of allergens — legislation.gov.uk.
All sources opened and checked on 18 September 2026. This page is general information, not legal advice.