Sulphites: when to declare them and where they appear

What the law says

Point 12 of Annex II of Regulation (EU) 1169/2011, still in force in the UK, covers “sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO₂”, calculated for products as ready to eat or as made up according to the manufacturer’s instructions.

Three key points:

• There is a threshold. Below 10 mg/kg or 10 mg/l you do not have to declare them. No other allergen on the list has a limit like this.
• Total SO₂ counts, whether it comes from an additive or forms naturally, as it does when wine ferments.
• It is measured in the product as eaten, not in one isolated ingredient.

Sulphites are used as preservatives and antioxidants. On labels they appear as “sulphites”, “sulphur dioxide” or E numbers E220 to E228 (for example sodium metabisulphite, E223, or potassium metabisulphite, E224), and they must be emphasised.

Where they appear

Drinks

• Red, white, rosé and fortified wines; Champagne, prosecco and other sparkling wines.
• Vermouth, sangria, spritzes and cocktails made with wine or vermouth.
• Cider, perry and some beers.
• Some fruit squashes and cordials.

Store cupboard

• Vinegar, especially wine vinegar and sherry vinegar.
• Pickles, pickled onions, gherkins and other preserved vegetables.
• Reductions and sauces made with wine, port or Madeira.
• Mustards, especially Dijon-style ones.
• Dried fruit, such as dried apricots and some raisins and sultanas.
• Some bottled lemon and lime juice, and some dried or frozen potato products.

Fish and shellfish

• Prawns, langoustines and other crustaceans, fresh or frozen, to which sulphites are added to stop black spots.
• Some frozen squid and octopus.

Meat

• Sausages and burgers with at least 4% vegetable or cereal content, where sulphite preservatives are permitted. Many British sausages use them, and the label says so.

The threshold in practice

You are not going to measure the SO₂ in a dish. The sensible way to work is this:

1. Packaged products. If the label emphasises “sulphites” or says “contains sulphites”, the product is over the threshold.
2. Drinks you serve as they come. Carry across to your menu what the label of each wine, beer or cider says.
3. Dishes you make. If an ingredient declares sulphites and there is a meaningful amount of it (a wine reduction, pickles, a vinaigrette, prawns), mark the dish. If you are unsure and have no data, declare it.

Do not assume cooking gets rid of them. Unless you have an analysis or a specification sheet that says so, keep the mark.

The wine list and the bar

Drinks are food too, and the allergen rules apply just as much to what you serve over the bar. A few tips:

• If every wine on your list contains sulphites, a clear note on the wine list may be enough. Check it really is true for each one, natural wines included.
• If a wine also declares egg or milk because of fining agents, mark it on that wine.
• “No added sulphites” does not mean “no sulphites”: fermentation produces them naturally. Look for “contains sulphites” on the label.
• Review your cocktails and mixed drinks: vermouth, sangria, spritzes, kir or anything else made with wine.

“Second-hand” sulphites

This allergen very often arrives inside other products. Two common cases:

• Shellfish. Grilled prawns can contain sulphites even though you added nothing. We explain this on the crustaceans page.
• Sauces and dressings. The vinegar in the vinaigrette or the mustard in a sauce can bring sulphites into the dish. For this case, see the mustard page.

Common mistakes

With sulphites, the problem is rarely contact between dishes. It is usually an ingredient nobody checked. The most frequent mistakes:

• Marking them only on the wine list and forgetting dishes with vinegar, pickles or wine.
• Not reading the label on frozen prawns, sausages or pickles.
• Assuming an organic or natural wine has none. It can still be above the threshold.
• Putting them on every dish “just in case”. It leaves people who must avoid them with no options and gives them no useful information.

In the US

Sulfites (the US spelling) are not one of the FDA’s nine major food allergens, but US packaged food must still declare them at 10 ppm or more, and wine labels say “Contains sulfites” from the same level, under TTB rules. The FDA has also banned sulfites on fresh fruit and vegetables meant to be served raw since 1986.

How to mark them on your menu

Sulphites are number 12 in Annex II. Many icon sets show them as a wine glass or the formula SO₂. Mark them on dishes and on drinks, and make sure your staff know they are not just about wine.

In MenuDesign you mark the allergen on each dish or drink and choose how it shows: icon, number or name. If your wine list is a separate document, you can create it in the editor too with the same key, so dishes and drinks use the same symbols.