Marking, allergens and traceability in dairy production
EU rules, allergen labeling, and traceability from cow to refrigerator counter
Milk is not just a raw material — it is also one of the substances that EU legislation requires be highlighted as an allergen on the packaging. For you as a dairy worker, knowledge of labeling and traceability rules is therefore not law for law's sake, but part of the daily responsibility for ensuring that products are both legal and safe.
§Food Information Regulations
The overall rules for labelling food in the EU including allergens are found in the food information regulation EU Regulation 1169/2011. Milk and milk products including lactose are listed among the allergens mentioned in the regulation's Annex II and must be highlighted in the ingredient list — for example in bold — when they are included in a product.
| Requirement | What it means for the dairy product |
|---|---|
| Ingredient list | All ingredients are listed in descending order of quantity |
| Allergen highlighting | Milk/lactose must be clearly highlighted, e.g. in bold |
| Minimum durability / last date of use | Specified depending on the product's shelf-life characteristics |
| Batch-/lotnummer | Make the production batch traceable |
| Producent/afsender | Name and address of the responsible company |
§Allergen information also applies to loose goods
The requirement for allergen information does not only apply to pre-packaged goods. For unpackaged food, or food packaged at the point of sale, information about the allergenic ingredients from Annex II that are still present in the food must be made available — either in writing, orally on request or via other relevant methods, for example electronically.
§Traceability: one step back, one step forward
Traceability is about a food company being able to document at any time where a raw material comes from and where the finished product went – the principle is often called 'one step back, one step forward'. At a dairy, it means you must be able to follow a given milk delivery all the way from the tank truck, through production, and forward to which customers received products from that specific batch.
- 01Each batch of milk/product receives a unique batch or lot number
- 02The number follows the product through all production steps in the documentation
- 03In case of a possible error, production can be traced back to the precise raw materials and forward to the customers who received the goods
- 04Traceability makes it possible to conduct a targeted recall rather than discard the entire production
§Why it is a daily task
Marking and traceability requirements are not something that only activates when something goes wrong. They must be an integrated part of everyday life — from correct batch marking at packing to accurate recording of which raw materials go into which production. It is part of the responsibility you take on as a dairy worker every time you pass a product forward in the chain.