Allergen 12 of 14 · So
Soya: the sauce, the flour and the lecithin
Soya travels in small amounts through a lot of products: soy sauce, soya flour in bread, soya lecithin in chocolate. Fully refined soya oil, on the other hand, is exempt.
Checked against the official guidance on 18 September 2026
What the law covers
Annex II lists “soybeans and products thereof”.
Exempt from declaration (Annex II):
- Fully refined soybean oil and fat
- Natural mixed tocopherols (E306), natural D-alpha tocopherol and its acetate and succinate, from soybean sources
- Vegetable oils derived phytosterols and phytosterol esters from soybean sources
- Plant stanol ester produced from vegetable oil sterols from soybean sources
Where it hides in a UK kitchen
| Where | Why |
|---|---|
| Soy sauce, teriyaki, hoisin, miso | All soya-based; soy sauce and teriyaki also carry wheat. |
| Bread | Many UK loaves contain soya flour. Check the bag or the bakery's specification. |
| Chocolate | Soya lecithin (E322) is the usual emulsifier. |
| Tofu, tempeh, edamame, TVP | Soya by definition, including in meat-free burgers and mince. |
In the free matrix builder, typing any of these ticks soya automatically: Soy sauce, Tamari, Teriyaki sauce, Hoisin sauce, Miso, Soya, Soya latte. These prompt a label check instead, because it depends on the recipe or the brand: Bread, Burger bun, Croissant, Gluten-free bread, Cake, Biscuit, Oyster sauce, Satay sauce, Chocolate, Milk chocolate, Hazelnut spread, Soya lecithin.
Cross-contact to think about
- Woks and stir-fry stations where soy sauce is used for everything.
- Shared fryer oil is not a soya risk if it is fully refined soya oil (exempt).
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
Lecithin
CLEAR
Emulsifier (soya lecithin)
Say where the lecithin comes from: sunflower lecithin is not an allergen, soya lecithin is.
Make a PPDS label with allergens emphasised automatically →
Mistakes we see on matrices
- Missing soya flour in bought-in bread.
- Declaring soya for the fryer because the oil is soya oil (fully refined soya oil is exempt).
- Forgetting the wheat that comes with soy sauce.
Soya: questions from kitchens
Is soya oil an allergen?
Fully refined soybean oil is exempt, so it is not declared. Cold-pressed or unrefined soya oil is not covered by the exemption.
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.