Food Allergen Law UK: A Complete Guide for Food Businesses

Managing allergens correctly is not optional for food businesses in the UK. It is a legal obligation, a moral responsibility, and a core component of good food safety practice.

With an estimated 2 million people in the UK living with a food allergy, and around 600,000 diagnosed with coeliac disease, the stakes could not be higher.

Failing to comply with food allergen law in the UK can result in serious harm to customers, significant financial penalties, and lasting reputational damage.

At FooddSure, we work with food businesses across London, Surrey, Kent, and Buckinghamshire to help them understand and implement allergen compliance as part of a robust food safety management system.

Whether you operate a restaurant, a takeaway, a catering company, or a food manufacturing business, this guide walks you through everything you need to know about food allergen laws in the UK.

What Are the 14 Major Allergens Under UK Law?

UK food allergen law requires food businesses to identify and communicate the presence of 14 specific allergens, either as ingredients or as potential cross-contamination risks. These allergens are listed under the UK Food Information Regulations and are recognised as the most common causes of serious allergic reactions.

The 14 major allergens are:

Celery
Cereals containing gluten (including wheat, rye, barley, oats, spelt, and kamut)
Crustaceans (such as prawns, crabs, and lobster)
Eggs
Fish
Lupin
Milk
Molluscs (such as oysters, mussels, and squid)
Mustard
Peanuts
Sesame
Soybeans
Sulphur dioxide and sulphites (at concentrations above 10mg/kg or 10mg/litre)
Tree nuts (including almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts, and Queensland nuts)

Each of these must be declared whenever they are used as an ingredient. The declaration must be clearly distinguishable from the rest of the ingredient list, typically through the use of bold text, capital letters, italics, or a different colour.

The Legal Framework: Which Laws Apply?

Food allergen law in the UK is governed by a framework that has evolved significantly over the past decade. Understanding which legislation applies to your business is the first step toward compliance.

The Food Information Regulations 2014 (FIR)

The Food Information Regulations 2014 implemented the EU Food Information for Consumers (FIC) Regulation in Great Britain. Post-Brexit, Great Britain retained this legislation as retained EU law. The FIR establishes the obligation for food businesses to declare the 14 major allergens in the ingredient list of prepacked food, clearly emphasised from the rest of the ingredients.

Natasha's Law (October 2021)

Natasha's Law, which came into force on 1 October 2021, represented one of the most significant changes to allergen labelling in a generation. Named after Natasha Ednan-Laperouse, a teenager who died in 2016 after suffering a reaction to a baguette that did not carry a full allergen label, the law extended full ingredient and allergen labelling requirements to prepacked for direct sale (PPDS) foods.

PPDS food is food that is packaged at the same premises from which it is sold, before the customer selects it. This includes items like sandwiches, salads, sushi, and baked goods packaged in advance by a bakery or cafe. Prior to October 2021, many of these products only required a label with the food name and a note that allergen information was available on request.

Under the current law, the full ingredient list with allergens emphasised must appear on the packaging itself.

Allergen Labelling for Non-Prepacked Food

Food sold loose or non-prepacked, such as food served at a restaurant table, a market stall, or a school canteen, is also subject to allergen information requirements. In these settings, allergen information does not need to appear in writing, although written menus or allergy matrices are strongly recommended.

It must, however, be available to the customer before they order, either in writing or verbally from a trained member of staff.

If a food business relies on verbal communication to convey allergen information, it must ensure staff are properly trained and capable of answering allergen queries accurately. This is an area where many businesses remain exposed to compliance risk.

Precautionary Allergen Labelling: May Contain Warnings

"May contain" warnings, known formally as precautionary allergen labelling (PAL), are used when there is a risk of unintentional allergen presence due to cross-contamination during production or handling. These statements are voluntary under current UK law, but they carry significant weight.

The Food Standards Agency (FSA) has been working to introduce a more standardised approach to PAL following years of inconsistency across the industry.

A "may contain" statement must only be used where a genuine, assessed risk exists. It should not be used as a blanket disclaimer where there is no real risk, as this undermines the trust of consumers with allergies who rely on these statements to make safe choices.

At FooddSure, we advise clients to document their allergen cross-contamination risk assessments and use PAL statements only where the risk has been formally identified and verified. This supports both compliance and consumer confidence.

Responsibilities of Food Business Operators

Under UK food allergen law, food business operators (FBOs) carry clear legal responsibilities. These include:

  • Maintaining an accurate and up-to-date record of all ingredients used in each dish or product, including sub-ingredients within compound ingredients
  • Ensuring allergen information is accurately communicated to customers before purchase or consumption
  • Implementing allergen management procedures within the kitchen or production environment, including segregation of allergenic ingredients, dedicated equipment, and cleaning protocols
  • Training all staff who handle, prepare, or serve food on allergen awareness and the businesses allergen procedures
  • Reviewing allergen information whenever recipes, ingredients, or suppliers change
  • Making written allergen information available to customers on request, even where verbal communication is the primary method

Local authorities and the Food Standards Agency have powers to inspect premises and enforce these requirements. Non-compliance can result in improvement notices, prohibition orders, or prosecution. In the most serious cases involving allergen-related fatalities, criminal liability has been established.

How to Build an Allergen Management System

A well-structured allergen management system is the practical mechanism through which food businesses deliver compliance. At FooddSure, we help clients design and implement systems that are proportionate to their size and operations but comprehensive enough to meet legal requirements and protect their customers.

1

Allergen Audit

The starting point is a thorough audit of every ingredient used across your menu or product range. This includes reviewing supplier ingredient declarations and specifications, checking for hidden allergens in sauces, stocks, and blended seasonings, and identifying any ingredients that have changed without the allergen profile being updated.

2

Risk Assessment for Cross-Contamination

A written risk assessment should identify every point in your operation where allergen cross-contamination could occur, from goods-in to service. This assessment informs your allergen controls, including decisions about dedicated equipment, preparation schedules, and cleaning procedures.

3

Documentation and Allergen Matrix

An allergen matrix is a chart that maps every dish or product against each of the 14 allergens, showing which are present as ingredients and which present a cross-contamination risk. The matrix must be accurate, current, and accessible to staff. It also forms the basis of any written allergen information provided to customers.

4

Staff Training

Every member of staff, not just chefs, needs to understand allergens and their role in keeping customers safe. This includes front-of-house staff who field allergen queries, delivery drivers, and anyone involved in labelling or packaging. FooddSure offers accredited Level 2 and Level 3 food safety training that includes allergen awareness as a core component.

5

Ongoing Review

Allergen management is not a one-time exercise. It must be reviewed whenever a recipe changes, a new supplier is introduced, or a new product is added to the menu. We recommend building a scheduled review into your food safety management system, with clear records of each review undertaken.

Common Allergen Compliance Mistakes

Through our consultancy and audit work, the FooddSure team regularly identifies the same types of allergen compliance failures across food businesses of all sizes. These include:

  • Outdated allergen matrices that no longer reflect the current menu
  • Reliance on verbal allergen communication without written backup records or staff training records
  • Failure to check sub-ingredients in compound products such as pre-made stocks, marinades, and sauces purchased from suppliers
  • Inadequate segregation of allergenic ingredients in storage and preparation
  • Unlabelled PPDS products or labels that do not meet the requirements introduced by Natasha's Law
  • Missing allergen information on digital menus and online ordering platforms

Each of these failures represents a potential risk to customers and a point of legal exposure for the business. Our allergen audits and consultancy services are designed to identify these gaps before they result in enforcement action or, more seriously, consumer harm.

Allergen Information on Digital Platforms and Takeaway Apps

Allergen law applies equally to food sold through online platforms, including delivery apps and business websites. If a customer orders through an app, they must have access to accurate allergen information before they place their order. This means your allergen matrix or dish-level declarations must be kept current on every platform through which you sell, not just in your physical premises.

The rise of online food ordering has created a significant compliance gap for some businesses, particularly smaller operators who may update their digital menus less frequently than their physical ones. At FooddSure, we include digital channel allergen communication as part of our consultancy assessments.

How FooddSure Supports Allergen Compliance

FooddSure is a specialist food safety consultancy supporting businesses across London, Surrey, Kent, and Buckinghamshire. We are accredited by the Chartered Institute of Environmental Health (CIEH) and registered with the ICO, which underlines our commitment to professional standards and client confidentiality.

Our allergen compliance services include:

  • Full allergen audits of your premises, menu, labelling, and documentation
  • Development of allergen matrices and management procedures
  • Staff training at Level 2 and Level 3, covering allergen awareness as standard
  • HACCP development that integrates allergen controls within your broader food safety management system
  • Pre-inspection support to ensure your allergen procedures are ready for EHO review

We work with restaurants, takeaways, catering businesses, food manufacturers, cafes, and school food providers. Whatever the size or nature of your operation, we can help you build allergen compliance into your everyday practice, not just your paperwork.

FAQs: Food Allergen Law UK

Is allergen information legally required for food sold at markets and pop-up events?
Yes. Allergen information is required for all food businesses, including market stalls, pop-up events, and mobile catering units. If you sell non-prepacked food, you must be able to provide allergen information to customers on request, either in writing or verbally from a trained member of staff.
What is the difference between PPDS food and prepacked food?
Prepacked food is packaged before it is offered for sale and intended to be supplied without further packaging, such as supermarket ready meals. PPDS food is packaged at the same premises from which it is sold, such as a cafe sandwich or bakery product packaged before the customer selects it. PPDS food must carry a full ingredient label with allergens emphasised, under Natasha's Law.
Do online menus need to include allergen information?
Yes. If you sell food through a website, app, or third-party delivery platform, allergen information must be available to the customer before they place their order. This is a legal requirement under the Food Information Regulations 2014.
What allergen training do my staff need?
All staff involved in the preparation, handling, or service of food should receive allergen awareness training. Level 2 food safety training, which FooddSure delivers as an accredited CIEH provider, covers allergen identification, communication, and cross-contamination prevention as core subjects.
What happens if my business is found to be non-compliant with allergen laws?
Local authority enforcement officers can issue improvement notices, which require you to correct identified failures within a specified period. In more serious cases, prohibition orders can prevent you from trading. Where allergen non-compliance has caused harm to a consumer, criminal prosecution and significant fines are possible. Keeping your allergen management system current and documented is the most effective way to manage this risk.