Soya on the menu: what counts, where it appears and how to label it

What it covers and what it excludes

Point 6 of Annex II of Regulation (EU) 1169/2011, which still applies in the UK, covers “Soybeans and products thereof”, with four exceptions:

• fully refined soybean oil and fat;
• natural mixed tocopherols (E306) and other natural forms of vitamin E from soybean sources;
• phytosterols and phytosterol esters derived from soybean oils;
• plant stanol esters produced from soybean oil sterols.

In a kitchen, the only exception you will meet often is the first one: fully refined soya oil does not have to be declared, which is why its label does not emphasise it. Everything else counts: the bean, flour, protein, soya milk, tofu, sauce and lecithin.

Where it appears

Asian cooking

• Soy sauce, teriyaki and many hoisin, black bean and stir-fry sauces.
• Miso, in soups, glazes and dressings.
• Tofu, tempeh, edamame and natto.
• Gyoza and dumplings, in the filling or the dipping sauce.
• Poke bowls, ramen, yakisoba and stir-fries.

Vegan and vegetarian cooking

• Burgers, meatballs and mince made with textured soya protein.
• Plant-based sausages and deli slices.
• Soya yoghurts, cooking creams and desserts.
• Vegan mayonnaise, which is often emulsified with soya milk.

Coffee and cafe

• Soya milk for coffee, and the smoothies and iced coffees made with it.

Everyday bought-in products

• Sliced bread, burger buns and packaged pastries, with soya flour or soya lecithin.
• Chocolate, coatings and ice cream, where soya lecithin is common.
• Margarines and spreads.
• Some sausages, burgers, meatballs and cooked meats with soya protein.
• Ready-made sauces, dressings and stocks.

The last group is the trickiest: you do not associate them with soya, and recipes change without warning. Check the label every time you change brand.

How to read the label on a bought-in product

On packaged food, soya is emphasised in the ingredients list, in bold, another colour or capitals. Look for:

• soya, soy, soya flour, soya protein, soya milk;
• soya lecithin or E322 (soya);
• tofu, miso, edamame, tempeh, shoyu or tamari.

Lecithin can also come from sunflower or other sources; only soya lecithin carries the allergen, and the label says so. If a product says “may contain soya”, carry it across as a possible trace on the dish where you use it.

Cross-contamination

• The wok and pans used for stir-frying with soy sauce.
• The coffee machine’s steam wand, if you heat soya milk and cow’s milk with the same wand without purging and wiping it.
• Squeeze bottles and sauce spoons shared on the pass.
• The fryer, if you fry tofu, tempura or coated products containing soya.

If you cannot separate a process, mark traces on the affected dish.

Common mix-ups

• Beansprouts. Almost always mung beans. They are not soya, but do not assume: the label decides.
• Soya oil. Fully refined, it is not declared. Cold-pressed or unrefined, it is.
• Soy sauce. In most cases it carries two allergens: soya and gluten. Some wheat-free brands say so on the label.
• Plant milk. Soya milk is not milk, but it does carry the soya allergen. If you offer it as a dairy alternative, say so.

In the US

Soybeans are one of the FDA’s nine major food allergens, and “soy”, “soya” and “soybean” are all accepted names on US labels. As in the UK, highly refined soybean oil is exempt from allergen labelling, though the label still names it as “soybean oil”.

How to mark it on your menu

Soya is number 6 in Annex II. Mark it on dishes where it is an ingredient and also where it arrives through bread, a sauce or a bought-in product. On an Asian menu almost every dish will end up with the mark: that is fine, and far better than leaving it off.

With so many industrial products involved, the practical approach is one record per dish listing the brands you use, transferred to the allergen matrix for your premises. In MenuDesign, once soya is marked on a dish, the app shows it as an icon, number or name and includes it in the key and the matrix. You can start in the editor with a photo of your current menu.