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Phoenix Journal · Kitchens

Allergen Law: What Caterers Must Disclose

Serving food to the public means a legal duty to disclose allergens accurately, every time. Here is what UK caterers must declare, and how the rules changed in 2025.

ALLRGALLERGEN LAW
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Allergen compliance

If you serve food to the public, allergen information is not a courtesy - it is the law, and in 2025 the bar was raised again.

Every caterer, cafe, takeaway and staff canteen has a legal duty to tell customers what is in the food they are eating. Get it right and you protect people who genuinely cannot afford a mistake. Get it wrong and the consequences run from an unlimited fine to a court appearance - and, in the worst cases, to real harm. Here is what you must disclose, and how the ground has shifted.

What the law actually asks of you

Three duties sit at the heart of allergen compliance under the Food Information Regulations 2014 (which retain the requirements of EU Regulation 1169/2011). Get these right and you are on solid ground.

The 14 allergens you must declare

UK law names 14 allergens. If any of them is used as an ingredient, you must be able to say so - accurately, every time, for every dish.

  • Celery, mustard & lupin
  • Cereals containing gluten - wheat, rye, barley & oats
  • Crustaceans & molluscs - prawns, crab, mussels & oysters
  • Eggs, milk & fish
  • Peanuts, tree nuts, sesame & soya (soybeans)
  • Sulphur dioxide (SO₂) & sulphites, where present above 10 mg/kg or 10 mg/litre

What you must disclose, and to whom

Consumers may react to other ingredients too, but the law requires you to declare these 14 - not just the ones you judge to be the most severe.

  • Whether each item contains any of the 14 allergens as an ingredient, given clearly and without ambiguity
  • Prepacked for direct sale (PPDS) items - sandwiches, salads, cakes made and wrapped on site - carrying a full ingredients list with allergens emphasised, under Natasha's Law since 1 October 2021
  • For online, click-and-collect and delivery orders, the information on the product page or no more than one click away, and again with the food when it arrives
  • Staff trained to answer confidently, because the customer in front of you may not read a label at all

Where written information now belongs

The FSA published updated best practice guidance for the out-of-home sector in March 2025. It treats written and spoken information as two halves of the same duty.

  • Allergen detail available in writing - a menu, an allergen matrix, a folder or a clearly sited display board
  • A conversation with a trained member of staff to underpin it, ideally opened early and confirmed again when the dish is served
  • Clear signposting where the detail is not on the main menu, so a customer knows exactly where to look
  • An "ask staff" sign on its own - still lawful for now, but no longer considered best practice

Why a clean kitchen is part of the answer

Disclosure is only half the picture. Telling a customer a dish is free from peanuts means nothing if peanut traces have travelled to it across a shared board, a blade or an unwashed surface. The law that governs what you say sits alongside the food hygiene law that governs what actually reaches the plate - and enforcement officers look at both together.

This is where precautionary labelling comes in. Phrases such as "may contain" or "not suitable for someone with a peanut allergy" are voluntary, and the FSA is explicit that they are not a substitute for good hygiene. Advisory wording only means something if it reflects a real, unavoidable risk. Slapping "may contain everything" on every menu to cover your back is treated as misleading, and it robs allergic diners of any useful choice. The honest answer is to control cross-contamination at source, then reserve advisory wording for genuine cases.

Controlling it at source is a cleaning and systems question. Separate equipment and colour-coded tools, thorough cleaning down between tasks, and a kitchen where fabric, extraction and hard-to-reach surfaces are not quietly harbouring residue all reduce the chance of an allergen ending up somewhere you promised it would not be. A periodic deep clean that reaches behind and beneath equipment, and through the canopy and ductwork, removes the built-up grease and debris where cross-contact and pests both thrive. It is the same discipline that keeps your fire risk down, working for your allergen controls too.

The paperwork side matters just as much when service is busy. An accurate allergen matrix, kept current as recipes and suppliers change, is what lets a member of staff give a straight answer in seconds rather than guessing. If you want the practical detail on building systems that hold up on a real service, our guide to allergen management that works in a real kitchen is a good next read, and for the pressure of the pass itself there is managing allergen orders at speed without mistakes. Both come back to the same truth - a calm, well-ordered, genuinely clean kitchen is far easier to keep compliant than a chaotic one.

The stakes are not abstract. Failing to provide correct allergen information is a criminal offence. On conviction it can carry an unlimited fine set by the magistrates, and where a case reaches the Crown Court it can bring an unlimited fine and up to two years' imprisonment. Prosecutions have risen sharply, and they follow harm - a diner who was assured a dish was safe when it was not. Treat allergen control as a whole-kitchen responsibility, from the menu wording your front-of-house team relies on right back to the surfaces your food is prepared on, and you close the gaps before they open.

Want your allergen controls backed by a genuinely clean kitchen? Start with our commercial kitchen deep cleaning.

Questions

Frequently asked questions

What are the 14 allergens caterers must declare?

They are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, tree nuts, sesame, soybeans (soya), and sulphur dioxide and sulphites. If any of these is used as an ingredient, you must be able to tell customers clearly and accurately. Reacting to something outside the 14 is possible, but only these are required to be declared by law.

Does Natasha's Law apply to my catering business?

Natasha's Law applies to prepacked for direct sale (PPDS) food - items you make and package on the same premises before a customer orders, such as sandwiches, salads and cakes on a chiller. These must carry a full ingredients list with the 14 allergens emphasised. Food cooked to order and served without prior packaging is not PPDS, but you still have a full legal duty to provide accurate allergen information for it.

What changed with the FSA's 2025 allergen guidance?

In March 2025 the FSA updated its best practice guidance for the out-of-home sector. It now expects allergen information to be available in writing - on a menu, matrix or display board - and underpinned by a conversation with trained staff. A lone 'ask staff' sign remains lawful for now but is no longer considered best practice, and for online orders the information should sit on the product page or no more than one click away.

What are the penalties for getting allergen information wrong?

Failing to provide correct allergen information is a criminal offence. On conviction in the magistrates' court it can bring an unlimited fine, and a case that reaches the Crown Court can carry an unlimited fine and up to two years' imprisonment. Prosecutions have risen sharply in recent years, and they typically follow real harm to a customer who was given wrong or missing information.

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