Allergen Labelling & Law

Allergen Information for Loose Foods: What the Law Requires

Allergen Information for Loose Foods: Legal Requirements & Best Practice

Loose food is any food that is not prepacked or PPDS when it reaches the customer. This covers the vast majority of food served in restaurants, cafes, pubs, canteens, and takeaways. Under the Food Information Regulations 2014, you must provide allergen information for loose food, but you have more flexibility in how you deliver it compared to packaged food. You can use written methods (menus, chalkboards, information folders) or a combination of written signage directing customers to ask staff, with trained staff providing accurate verbal information. However, "flexible" does not mean "optional." Many food businesses treat loose food allergen requirements as an afterthought, and this is one of the most common findings during EHO inspections.

Key takeaways

Loose food allergen information can be written or verbal, but written documentation must always exist
Staff providing verbal allergen information must be trained and able to answer accurately on the spot
Allergen symbols on menus with a key are considered best practice for restaurants
EHOs test staff knowledge during inspections, not just paperwork

Written vs Verbal: What the Law Actually Says

The regulations allow two compliant approaches for loose food. The first is written allergen information provided at the point of choice, typically on a menu, chalkboard, or information sheet that the customer can read before ordering. The second is a verbal approach, where you display a clear sign directing customers to ask a member of staff, and that staff member provides accurate allergen information from documented sources. In both cases, the underlying documentation must exist. If you choose the verbal route, you must have a written record (typically an allergen matrix or recipe file) that staff can refer to. EHOs will test this by asking staff about allergens in specific dishes. If staff cannot answer or give incorrect information, the system fails regardless of what paperwork exists in the office. Many businesses now use a combined approach: allergen symbols or codes on the menu, backed by a detailed allergen matrix available on request, with staff trained to discuss specifics.

Best Practice Formats for Loose Food Allergen Information

The most effective format depends on your business type. For restaurants and cafes with printed menus, adding allergen symbols (numbered 1-14 or using standard icons) next to each dish is widely considered best practice. Include a key at the bottom of the menu explaining each symbol. For businesses with changing menus (daily specials, seasonal changes), a separate allergen matrix printed on a single sheet or laminated card is easier to update than reprinting menus. Chalkboard-based businesses should maintain a printed allergen sheet available on request, because chalkboards cannot convey 14 allergens per dish legibly. Digital menus and QR codes are increasingly popular and have the advantage of being updateable in real time. Whatever format you choose, it must be available at the point where the customer makes their choice, not after they have ordered. Allergen information on a website alone is not sufficient if the customer orders in person without consulting the website.

Staff Training and the "Ask the Staff" Model

If your allergen system depends on staff providing verbal information, those staff members are a critical control point in your compliance. Every front-of-house team member must know the 14 allergens, understand which dishes contain which allergens, know what to do when they are unsure (the answer is always to check, never to guess), and understand the seriousness of getting it wrong. Training should happen during induction and be refreshed at least annually, or whenever the menu changes significantly. Keep training records with dates, content covered, and signatures. During an EHO inspection, officers will typically ask a front-of-house staff member an allergen question about a random dish. If that person cannot answer accurately, it counts against your food hygiene rating. The most common failure is not lack of documentation but lack of staff knowledge at the moment of truth.
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What EHOs Look for During Inspections

During a food hygiene inspection, the allergen assessment typically covers several areas. First, the officer checks whether allergen information is available at the point of choice. If you rely on the "ask staff" model, they check for signage directing customers to do so. Second, they review your allergen documentation: the matrix, recipe files, and supplier specifications. They check whether these are current and match the actual menu. Third, they question staff. This is where many businesses fail. A well-documented system is useless if the people serving food cannot explain it. Fourth, they check the kitchen: are allergen-free dishes prepared separately? Are colour-coded utensils used? Is there a clear system for communicating allergen orders from front of house to kitchen? Allergen management now forms a significant part of the food hygiene rating score. Consistent failures can drop your rating by one or two points.

What to do next

Add allergen codes to your menu

Assign numbers 1-14 to each allergen and add the relevant codes next to every dish. Print a key explaining the codes at the bottom of the menu.

Create a detailed allergen matrix for staff reference

Build a grid listing every dish against all 14 allergens. Laminate it and keep copies in the kitchen and at the service counter.

Test staff knowledge monthly

Pick a random dish each month and ask front-of-house staff which allergens it contains. Record results and retrain anyone who cannot answer correctly.

Common mistakes to avoid

Mistake
Displaying allergen information only on the website, not in the premises
Instead
Allergen information must be available at the point of choice. If customers order in person, the information must be accessible in the premises, not just online.
Mistake
Putting up an "ask staff" sign without actually training staff
Instead
The sign creates an obligation. If a customer asks and the staff member cannot answer, you have failed to provide the required information. Train before you sign.

Frequently asked questions

Do I need allergen information on a buffet?

Yes. Buffet food is loose food and allergen information must be available at the point where customers select their food. Place allergen labels or codes next to each dish, or provide a printed allergen matrix at the start of the buffet line.

Can I just say "all dishes may contain allergens"?

No. A blanket statement does not provide the specific allergen information the law requires. You must be able to tell the customer which specific allergens are present in each dish.

What about daily specials not on the printed menu?

Daily specials need allergen information too. Use a separate printed sheet, a chalkboard with allergen codes, or ensure staff can provide accurate verbal information backed by documented recipes.

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