How-To Guide

How to Set Up Allergen Management Procedures for Your Food Business

Complete guide to implementing allergen management procedures in UK food businesses. Covers the 14 declarable allergens, Natasha's Law requirements, menu mapping, staff training, and verification systems.

Estimated time: 4 hours

Allergen management is one of the most scrutinised areas of food safety in the UK. The Food Information Regulations 2014 require every food business to provide accurate allergen information to customers, and since October 2021, Natasha's Law (the Food Information (Amendment) (England) Regulations 2019) extended this to require full ingredient labelling on all prepacked for direct sale (PPDS) food. Non-compliance carries unlimited fines and, in the event of a serious allergic reaction, potential manslaughter charges.

The UK recognises 14 declarable allergens: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, peanuts, sesame, soybeans, and sulphur dioxide (above 10mg/kg). Every food business must have documented procedures for identifying these allergens in their dishes, communicating them to customers, and preventing cross-contamination during preparation and service.

This guide takes you through setting up a comprehensive allergen management system, from mapping every ingredient in your menu through to training staff and verifying your procedures work in practice.

5 steps to complete

1

Identify the 14 declarable allergens and understand legal requirements

Start by ensuring you and your team can name all 14 allergens that must be declared under UK law: 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 (where above 10mg/kg or 10mg/litre). Understand the difference between loose food (verbal allergen information acceptable, but written record must exist) and prepacked for direct sale food (full ingredient labelling with allergens emphasised, per Natasha's Law).

2

Map every menu item against the 14 allergens

Create an allergen matrix that lists every dish, drink, sauce, dressing, and accompaniment on your menu, cross-referenced against all 14 allergens. For each item, check every ingredient, including cooking oils, marinades, stocks, garnishes, and bought-in components. Contact suppliers for allergen specifications of all bought-in products and keep these on file. Be rigorous: breadcrumbs contain gluten, Worcestershire sauce contains fish, many desserts contain egg and milk, and soy is present in more products than most operators realise. Update the matrix whenever your menu changes.

3

Create communication procedures for front-of-house

Establish clear procedures for how allergen information is communicated to customers. For loose food, you must either display written allergen information (on menus, chalk boards, or table notices) or direct customers to ask a member of staff, provided that staff member has access to written allergen records. For PPDS food, each item must carry a label listing all ingredients with the 14 allergens emphasised (bold, underline, or contrast). Train front-of-house staff on how to handle allergen enquiries, including the exact phrases to use and the escalation process when they are unsure.

4

Train all staff on allergen awareness and procedures

Every member of staff who handles, prepares, or serves food must receive allergen training. Training should cover: what allergens are and why they are dangerous, the 14 declarable allergens and common foods that contain them, how to read and use the allergen matrix, cross-contamination prevention during preparation (separate utensils, dedicated prep areas, cleaning between allergen and non-allergen dishes), how to handle customer allergen enquiries, and what to do in an emergency (recognising anaphylaxis, calling 999, locating and administering an auto-injector if the customer carries one). Record all training with dates and signatures.

5

Set up verification and review processes

Implement regular checks to verify your allergen procedures work in practice. This includes: spot-checking that front-of-house staff can accurately identify allergens in menu items; verifying that kitchen practices match documented procedures (separate utensils, proper cleaning between allergen tasks); reviewing allergen matrices whenever menus, recipes, or suppliers change; checking that supplier allergen specifications are current (request updated certificates at least annually); and conducting a full allergen procedure review at least every six months or after any allergen-related incident.

Tips for success

Keep a master allergen matrix in a laminated folder accessible to all staff, plus a digital copy that can be updated instantly when menus change. Paddl can generate this automatically from your ingredient data.
Use a "when in doubt, leave it out" policy for allergen queries. If any member of staff is unsure whether a dish contains a specific allergen, the answer to the customer should always be that it may contain that allergen until verified.
Ask customers about allergies proactively when taking orders rather than relying on them to volunteer the information. A simple "Does anyone at the table have any food allergies we should know about?" can prevent incidents.
Colour-code utensils, chopping boards, or containers used for allergen-free preparation to reduce the risk of cross-contamination. Purple is commonly used for allergen-free items in the UK.
Review your allergen matrix immediately when any supplier changes the formulation of a product, even if the change seems minor. Reformulations frequently introduce new allergens.

Common mistakes to avoid

Relying solely on verbal allergen information without a written record
The Food Information Regulations 2014 require that allergen information is available in writing, even if your primary method is verbal communication via staff. You must have a documented allergen matrix or equivalent that staff can reference. A verbal-only system fails the moment a knowledgeable staff member is absent.
Failing to account for cross-contamination during preparation
Knowing which ingredients contain allergens is only half the battle. Cross-contamination from shared utensils, oil, grill surfaces, or even airborne flour can introduce allergens into a dish labelled as allergen-free. Implement separate preparation areas or thorough cleaning protocols between allergen and non-allergen preparation.
Not updating the allergen matrix when menus or suppliers change
An outdated allergen matrix is potentially more dangerous than no matrix at all, because staff trust it to be accurate. Build allergen matrix updates into your menu change process as a mandatory step, not an afterthought.
Assuming all staff understand allergens based on general food safety training
Allergen management requires specific, dedicated training that goes beyond general food hygiene. Staff need to understand the life-threatening nature of allergic reactions, the specific procedures in your business, and exactly how to respond to allergen emergencies.

Frequently asked questions

What are the penalties for failing to manage allergens properly?

Failing to comply with allergen regulations can result in unlimited fines, an improvement notice, a prohibition order, or prosecution. If a customer suffers a serious allergic reaction due to incorrect allergen information, the consequences can include corporate manslaughter charges. In the Pret a Manger case involving Natasha Ednan-Laperouse, the company was fined and the resulting public inquiry led directly to Natasha's Law. Local authorities take allergen non-compliance extremely seriously.

Do I need to label food sold loose (not prepacked)?

Food sold loose does not require individual labels, but you must provide allergen information either in writing (on menus, labels, or signage) or verbally, provided there is a clear sign directing customers to ask and your staff have access to a written allergen record. Many businesses find it simplest to include allergen information directly on menus or to have a separate allergen menu available on request.

How does Natasha's Law affect my business?

Natasha's Law requires that all food prepacked for direct sale (PPDS) must carry a label listing the full ingredients with the 14 declarable allergens emphasised. This applies to items like sandwiches, salads, and cakes made on-site and wrapped or packaged before the customer selects them. If your business produces any PPDS food, every item must have a compliant label. Non-PPDS food (made to order or sold loose) is not covered by this specific requirement but is still covered by the Food Information Regulations 2014.

Can I use a "may contain" warning instead of listing specific allergens?

"May contain" warnings (also called precautionary allergen labelling) should only be used when there is a genuine, unavoidable risk of cross-contamination despite all reasonable precautions being taken. They must not be used as a blanket disclaimer to avoid proper allergen management. The FSA has published guidance on responsible use of precautionary labelling. Overuse erodes customer trust and reduces the choices available to allergy sufferers. Always try to eliminate cross-contamination before resorting to a "may contain" statement.

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