Introduction: Why Allergen Labeling Matters More Than Ever in the GCC
Food allergies are a growing public health concern worldwide, and the GCC is no exception. While population-level prevalence data for the Gulf region is still being developed, clinical evidence and hospital admission records indicate that food allergy rates are rising — particularly among children. The UAE's diverse expatriate population, representing over 200 nationalities, adds complexity: dietary patterns, allergy profiles, and consumer expectations vary significantly across demographic groups.
For food businesses, allergen labeling is both a legal obligation and a safety imperative. Inaccurate or incomplete allergen disclosure can result in severe allergic reactions, hospitalizations, and fatalities. It also exposes businesses to regulatory penalties, product recalls, and reputational damage. This guide provides a comprehensive overview of allergen labeling requirements across the GCC, with practical guidance on how food businesses can build robust allergen management systems.
GSO 9/2013: The Foundation of GCC Allergen Labeling
The primary regulatory framework for allergen labeling in the GCC is GSO 9/2013 — the Gulf Standardization Organization's standard for the labeling of prepackaged foodstuffs. This standard, adopted by all six GCC member states, requires that foods containing any of the following 14 allergenic substances (or products derived from them) must declare their presence on the label:
- Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut, and their hybridized strains)
- Crustaceans and crustacean products
- Eggs and egg products
- Fish and fish products
- Peanuts and peanut products
- Soybeans and soybean products
- Milk and milk products (including lactose)
- Tree nuts (almonds, cashews, walnuts, pecans, Brazil nuts, pistachios, macadamia nuts, hazelnuts)
- Celery and celery products
- Mustard and mustard products
- Sesame seeds and sesame seed products
- Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre expressed as SO2
- Lupin and lupin products
- Molluscs and mollusc products
The declaration must appear in the ingredient list, with the allergenic substance clearly identifiable. Many businesses use bold text, uppercase letters, or a separate "Contains" statement to highlight allergens — practices that, while not universally mandated by GSO 9/2013, are considered best practice and are required in some country-specific guidelines.
Compound Ingredients: The Hidden Allergen Risk
One of the most common sources of allergen labeling errors is compound ingredients — ingredients that are themselves made up of multiple components. For example, a chocolate chip cookie used as an ingredient in an ice cream product contains flour (wheat), butter (milk), eggs, and chocolate (which may contain soy lecithin and milk). If the ice cream label lists "chocolate chip cookie" as an ingredient without breaking it down, critical allergen information is hidden from the consumer.
GSO 9/2013 addresses this by requiring that compound ingredients making up more than 5% of the final product must have their sub-ingredients listed, including any allergenic substances. Even for compound ingredients below the 5% threshold, allergenic sub-ingredients must still be declared. This means that a seasoning blend making up just 2% of a product must still have its allergenic components identified on the label if it contains, say, celery or mustard.
For food businesses, managing compound ingredients requires detailed knowledge of every component in the supply chain. Manufacturers must obtain and verify ingredient specifications from all suppliers, and they must update their labeling whenever a supplier changes a formulation. This is an area where manual systems frequently break down — a supplier substitutes one emulsifier for another, introducing soy, and the downstream manufacturer's label becomes inaccurate without anyone realizing it.
Country-Specific Requirements Across the GCC
Saudi Arabia
The SFDA enforces GSO 9/2013 and has issued additional guidance on allergen labeling for food service establishments. Restaurants and caterers above a certain size are expected to provide allergen information to customers upon request, and the SFDA has indicated that mandatory allergen disclosure in food service menus may be forthcoming. The authority also requires that allergen declarations appear in both Arabic and English on all prepackaged food sold in the Kingdom.
United Arab Emirates
The UAE follows GSO 9/2013 through its municipal food safety authorities — the Abu Dhabi Agriculture and Food Safety Authority (ADAFSA), Dubai Municipality, and the respective authorities in Sharjah, Ajman, and other emirates. Dubai Municipality has been particularly active in enforcing allergen labeling requirements during market surveillance inspections. The UAE also requires bilingual (Arabic/English) labeling for all food products.
Kuwait
Kuwait's Public Authority for Food and Nutrition enforces GSO 9/2013 alongside its own national regulations. Kuwait has been particularly focused on allergen management in school and hospital food service settings, requiring caterers to provide detailed allergen information for all meals served in institutional environments.
Qatar
Qatar's Ministry of Public Health oversees food labeling requirements, including allergen disclosure. The country follows GSO 9/2013 and has additional requirements related to food imports, including the need for allergen declarations to be present on the original packaging (not just on sticker labels applied at the point of import).
Bahrain and Oman
Both countries adopt GSO 9/2013 as their baseline for allergen labeling. Bahrain's National Health Regulatory Authority and Oman's Ministry of Agriculture, Fisheries and Water Resources enforce these standards through import inspections and market surveillance. Both countries require Arabic language allergen declarations on all prepackaged food products.
Precautionary Allergen Labeling: "May Contain" Statements
Precautionary allergen labeling (PAL) — commonly expressed as "May contain traces of..." or "Produced in a facility that also processes..." — is used to communicate the risk of unintended allergen presence due to cross-contamination during manufacturing. Unlike mandatory allergen declarations, PAL is not required by GSO 9/2013. However, when used, it must be truthful and based on a documented risk assessment.
The challenge with PAL is that it has been overused. When manufacturers apply "May contain" statements to every product as a blanket precaution — regardless of actual cross-contamination risk — the labels lose their informational value. Consumers with food allergies who see "May contain" on nearly every product may either ignore the warnings entirely or find their food choices unnecessarily restricted.
Best practice in the GCC — consistent with guidance from international bodies such as the Codex Alimentarius Commission — is to use PAL only when a genuine cross-contamination risk exists that cannot be eliminated through good manufacturing practices. This requires a formal risk assessment that considers the production environment, equipment cleaning procedures, scheduling of allergen-containing products, and the severity of the potential allergic reaction.
Allergen Traceability: From Supplier to Label
Effective allergen management depends on traceability — the ability to track allergenic ingredients from their source, through the manufacturing process, to the final product label. Traceability systems must capture which suppliers provide which ingredients, the allergen status of each ingredient (confirmed by the supplier's specification sheet), which recipes use which ingredients, and which finished products contain which allergens.
When a supplier changes a formulation or when a manufacturer substitutes one ingredient for another, the traceability system must flag the change and trigger a review of all affected product labels. Without this capability, allergen labeling errors are almost inevitable over time.
RecipeBuilder addresses this challenge by maintaining a linked database where each ingredient's allergen profile is stored alongside the recipes that use it. When an ingredient is modified or substituted, the system automatically identifies all affected recipes and flags them for label review. This approach replaces manual cross-referencing — which is error-prone and time-consuming — with automated alerts that ensure no allergen change goes unnoticed.
Allergen Management in Food Service: Beyond Packaged Food
Allergen labeling requirements in the GCC are increasingly extending beyond prepackaged food to food service operations. Restaurants, catering companies, hotels, and institutional food providers face growing expectations — both regulatory and consumer-driven — to communicate allergen information clearly and accurately.
For food service businesses, allergen management presents unique challenges. Menus change frequently, dishes are prepared from scratch using dozens of ingredients, cross-contamination risks exist in shared kitchen environments, and front-of-house staff must be able to answer customer queries about allergens accurately and confidently.
Best practice for food service allergen management includes maintaining an allergen matrix for the full menu (updated whenever recipes or ingredients change), training all staff — both kitchen and front-of-house — on allergen risks and communication protocols, implementing physical controls in the kitchen to prevent cross-contamination (such as dedicated utensils, color-coded cutting boards, and separate preparation areas), and establishing a clear process for handling customer allergen queries, including a protocol for when a customer reports an allergic reaction.
Common Allergen Labeling Mistakes and How to Avoid Them
Regulatory enforcement data from across the GCC reveals several recurring allergen labeling errors. Undeclared allergens in compound ingredients remain the most common violation. Missing allergen declarations due to recipe changes that were not reflected on the label are also frequent. Incorrect translation of allergen information between English and Arabic labels creates confusion. Overuse of precautionary "May contain" statements that are not supported by documented risk assessments is another common finding. Additionally, failure to declare allergens from processing aids — such as sulphites used in dried fruit or casein used as a fining agent in wine — leads to violations.
Avoiding these mistakes requires a systematic approach: centralized ingredient data, automated allergen tracking, regular label audits, and staff training. Businesses that treat allergen management as an ongoing process — rather than a one-time labeling exercise — are far less likely to encounter these common pitfalls.
Building an Allergen Management System: A Practical Framework
A robust allergen management system for a GCC food business should include the following components. First, establish a supplier qualification process that requires all ingredient suppliers to provide allergen declarations and to notify the business of any formulation changes. Second, build and maintain a centralized ingredient database that records the allergen status of every ingredient used in production.
Third, link the ingredient database to your recipe and product database so that each product's allergen profile is automatically calculated from its ingredients. Fourth, implement a change management process that triggers a label review whenever an ingredient, recipe, or supplier changes. Fifth, conduct regular label audits — comparing the allergen declarations on physical labels against the current recipe and ingredient data — at least quarterly.
Sixth, train all relevant staff on allergen awareness, labeling requirements, and the company's allergen management procedures. Seventh, establish a recall procedure for the event that an undeclared allergen is identified in a product already in the market. Having these systems in place before an incident occurs is infinitely preferable to scrambling to respond after one.
Conclusion: Allergen Labeling as a Non-Negotiable Business Function
Allergen labeling is not a secondary consideration or an afterthought to be addressed during the label design phase. It is a core business function that spans procurement, production, quality assurance, and customer communication. In the GCC, where regulatory enforcement is tightening and consumer awareness is growing, food businesses that invest in systematic allergen management will protect their customers, their brands, and their market access. Those that do not will eventually face the consequences — whether through regulatory action, product recalls, or the far more serious outcome of a preventable allergic reaction.