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Allergen Labelling & Law

Food Information Regulations 2014: Allergen Requirements Explained

Food Information Regulations 2014: Allergen Rules for Food Businesses

The Food Information Regulations 2014 (FIR 2014) are the foundation of UK allergen law. They implement EU Regulation 1169/2011, known as the Food Information to Consumers Regulation, into UK domestic law. The regulations require food businesses to provide allergen information for all food sold or provided to consumers, whether prepacked, loose, or served in a restaurant. The 14 declarable allergens are defined in Annex II of EU 1169/2011. These regulations existed before Natasha's Law and continue to apply alongside it. Where Natasha's Law specifically addresses PPDS labelling, FIR 2014 covers the broader obligation to declare allergens in all food categories. Understanding FIR 2014 is essential because it sets the baseline that every other allergen regulation builds on.

Key takeaways

FIR 2014 requires declaration of 14 specific allergens in all food categories
Allergens must be emphasised within ingredients lists for prepacked and PPDS food
Loose food allergen information can be verbal, but written records must exist to support it
Bold text is the industry standard for emphasising allergens, applied consistently
Maintaining an allergen matrix and supplier specs is the best way to demonstrate due diligence

The Core Obligation: Declare the 14 Allergens

FIR 2014 requires food businesses to declare the presence of 14 specific allergens whenever they are used as ingredients or processing aids in food. The 14 allergens are: celery, cereals containing gluten (wheat, rye, barley, oats), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts), peanuts, sesame, soybeans, and sulphur dioxide/sulphites at concentrations above 10mg/kg or 10mg/litre. This obligation applies regardless of the quantity used. Even trace amounts used as processing aids must be declared if they are deliberately added. The only exception is where the allergen has been so highly processed that scientific evidence demonstrates it no longer triggers a reaction, and specific exemptions are listed in the legislation (for example, certain refined oils). These exemptions are narrow and rarely relevant to typical food businesses.

How Allergen Information Must Be Provided by Food Category

The format for allergen information depends on how the food is sold. For prepacked food (manufactured and packaged before being placed for sale), allergens must appear emphasised within a full ingredients list on the packaging. For PPDS food (covered by Natasha's Law), the same rule applies. For loose food, which includes food served in restaurants, cafes, takeaways, and canteens, the regulations allow more flexibility. Allergen information for loose food can be provided in writing (menus, chalkboards, table talkers, information packs) or verbally, provided there is a clear sign directing customers to ask and staff are trained to give accurate answers. If you choose the verbal route, you must have documented allergen information available to back up what staff say. Relying on memory alone is not compliant. Many EHOs now expect written allergen information even for loose food, and it is considered best practice across the industry.

Emphasising Allergens: Legal Formatting Requirements

For prepacked and PPDS food, allergens must be "emphasised" within the ingredients list by a means that clearly distinguishes them. The legislation does not mandate bold specifically, but bold has become the industry standard because it is the clearest and most consistent method. Other acceptable methods include italics, underlining, capitalisation, or a contrasting background colour. Whichever method you choose, it must be applied consistently across all your products. Mixing methods on different labels creates confusion and may be challenged by enforcement officers. The allergen must be emphasised using the specific name listed in the regulations: "milk" not "dairy", "celery" not "celeriac" (unless celeriac is the specific form used, in which case "celery" must still appear). Each occurrence of an allergen in the ingredients list must be emphasised. If milk powder and butter both appear as ingredients, both "milk" references must be in bold.
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Record-Keeping and Due Diligence

FIR 2014 does not prescribe a specific record-keeping format, but enforcement under the Food Safety Act 1990 means you need evidence of due diligence. In practice, this means maintaining allergen information files for every product or menu item, keeping supplier specifications and ingredient data sheets, training records showing staff understand allergen requirements, and documented procedures for handling allergen queries. When an EHO inspects your business, they will ask to see your allergen records, check that your declared allergens match actual ingredients, and may question staff to test their knowledge. A well-maintained allergen matrix (cross-referencing every menu item against the 14 allergens) is the most efficient way to demonstrate compliance. Digital systems that link recipes to ingredient data and auto-generate allergen declarations are increasingly common and reduce the risk of human error.

What to do next

Map your obligations by food category

Classify every product as prepacked, PPDS, or loose, and apply the correct allergen information requirements for each category.

Build an allergen matrix for your full menu

Create a grid cross-referencing every menu item against the 14 allergens. Update it whenever recipes or suppliers change.

Collect and file supplier allergen data

Request ingredient specifications from every supplier and store them in a central file. Check them on every delivery for changes.

Common mistakes to avoid

Mistake
Using "dairy" instead of "milk" when declaring allergens
Instead
The regulations list "milk" as the declarable allergen. Use the exact terms from the legislation to avoid confusion and potential enforcement issues.
Mistake
Relying solely on verbal allergen communication without documentation
Instead
Even if you provide allergen information verbally for loose food, you must have documented records (allergen matrix, recipe files) to support the information given.

Frequently asked questions

Do the Food Information Regulations apply to takeaway food?

Yes. Takeaway food is classified as either loose food or PPDS depending on how it is packaged. Allergen information must be provided regardless. For loose takeaway food, the regulations allow verbal communication backed by written records.

Are sulphites always declarable?

Sulphites must be declared when present at concentrations above 10mg/kg or 10mg/litre in the finished product. Below this threshold, declaration is not required. Wine and dried fruit are common sources.

What happens if my supplier does not provide allergen information?

You are legally responsible for the allergen information you provide to customers, regardless of what your supplier tells you. If a supplier cannot or will not provide full allergen data, find a different supplier or have the product independently analysed.

Do I need to list allergens for staff meals?

The regulations apply to food sold or provided to consumers. Food provided to staff (e.g. in a staff canteen) is covered if it is provided as part of a business activity. Best practice is to provide allergen information for all food served to anyone.

Is banana one of the 14 allergens?

No. Banana is not one of the 14 declarable allergens under UK food law. The 14 allergens are: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, peanuts, sesame, soya, and sulphur dioxide/sulphites. While some people are allergic to bananas, it is not a regulated allergen and does not need to be highlighted on labels or menus. You should still inform customers if asked.

Why are these 14 allergens regulated?

The 14 allergens were selected because they account for the vast majority of serious allergic reactions in the EU and UK population. The list is based on scientific evidence reviewed by the European Food Safety Authority. It was established under EU Regulation 1169/2011 (Food Information to Consumers) and retained in UK law after Brexit. The list is periodically reviewed but has not changed since its introduction.

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