Legal Requirements for Food Allergen Labelling
All UK food businesses are required to follow the information rules for food allergens set out in the Food Information Regulations 2014 and the EU Food Information for Consumers Regulation (EU FIC). Find out more about these legal requirements, the UK Food Information Amendment, also known as ‘Natasha’s Law‘ (effective from 1 October 2021) requiring all UK food businesses to provide a full ingredients list with clear allergen labelling on ‘pre-packed for direct sale’ (PPDS) food and the requirement for large food businesses (with more than 250 employees) in England to display the calorie information of non-prepacked food and soft drink items (effective 6 April 2022).
The Food Standards Agency provides advice, technical guidance and free online allergy training to help businesses meet their legal requirements.
A key recommendation is that information on food allergens should be recorded – for example, in the form of product specification sheets, ingredients labels and recipes or explanations of the dishes. That’s where Menu Guide comes in.
Although allergen information may also be provided verbally to customers. The FSA advises that this needs to be backed up by the information being in writing to ensure it is accurate and consistent. Your customers also have a responsibility to tell you about their allergy or intolerance.
In short: you must make sure that the 14 regulated food allergens are declared, that your staff are trained about allergens and you manage allergens properly.
FSA guidance states that information on allergenic ingredients must be listed clearly in an obvious place, such as a menu, board or information pack. If it is not provided upfront, you need to signpost to where it could be obtained. Menu Guide provides a simple solution to this requirement.
The 14 Food Allergens
With additional information and guidance provided by the Food Standards Agency (FSA).
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Including celery stalks, leaves, seeds and celeriac. You can find celery in celery salt, salads, some meat products, soups and stock cubes.
Including wheat (such as spelt and Khorasan wheat/Kamut), rye, barley and oats. Often found in foods containing flour, such as some types of baking powder, batter, breadcrumbs, bread, cakes, couscous, meat products, pasta, pastry,sauces, soups and fried foods which are dusted with flour.
Please see the important information below if you are marking menu items as ‘gluten-free’.
Such as prawns, scampi, crabs and lobsters. Shrimp paste, often used in Thai and south-east Asian curries or salads, is an ingredient to look out for.
Often found in cakes, some meat products, mayonnaise, mousses, pasta, quiche, sauces and pastries or foods brushed or glazed with egg.
May be found in fish sauces, pizzas, relishes, salad dressings, stock cubes and Worcestershire sauce.
A flower that is also found in flour. Lupin flour and seeds may be used in some types of bread, pastries and pasta.
A common ingredient in butter, cheese, cream, milk powders and yoghurt. It can also be found in foods brushed or glazed with milk, and in powdered soups and sauces.
These include mussels, oysters, land snails, squid and whelks, but can also be commonly found in oyster sauce or as an ingredient in fish stews.
Including liquid mustard, mustard powder and mustard seeds. This ingredient can also be found in breads, curries, marinades, meat products, salad dressings, sauces and soups.
Sometimes called groundnuts because they are a legume that grows underground, peanuts are often used in biscuits, cakes, curries, desserts, sauces (such as satay), as well as groundnut oil and peanut flour.
These can often be found in bread (like burger buns), breadsticks, houmous, sesame oil and tahini. They are sometimes toasted and used in salads.
Found in bean curd, edamame beans, miso paste, textured soya protein, soya flour or tofu, soya is a staple ingredient in oriental food. It may also be in desserts, ice cream, meat products, sauces and vegetarian products.
Sometimes known as sulphites, this is an ingredient often used in dried fruit such as raisins, dried apricots and prunes. You may also find it in meat products, soft drinks, vegetables as well as in wine and beer. People with asthma have a higher risk of developing a reaction to sulphur dioxide.
*At a concentration of more that ten parts per million
Nuts that grow on trees including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts. Nuts may be found in breads, biscuits, crackers, desserts, nut powders (often used in Asian curries), stir-fried dishes, ice cream, marzipan (almond paste), nut oils and sauces.
Gluten-free and very low gluten options
About 1% of people in the UK are intolerant to gluten – this condition is also known as coeliac disease. People with coeliac disease need to avoid foods that contain gluten to prevent potentially serious health effects. This means labelling claims about gluten in foods are very important. Foods that contain gluten include wheat, rye and barley (see above). European legislation has set levels of gluten for foods that claim to be either ‘gluten-free’ or ‘very low gluten’. These levels are:
- ‘gluten-free’ – 20 parts or less of gluten per million.
- ‘very low gluten’ – 100 parts or less of gluten per million. However, only foods with cereal ingredients that have been specially processed to remove the gluten may make a ‘very low gluten’ claim.
These regulations apply to all foods and businesses can only use the phrase ‘gluten-free’ if they can demonstrate that, when tested, their product is 20 parts or less of gluten per million. They will also be required to demonstrate that any products claiming to be ‘very low gluten’ also comply with the legislation.
If your menu items have no deliberate gluten-containing ingredients, but are at risk of gluten cross-contamination, you must not label menu items as ‘gluten-free’ or ‘very low gluten’. If steps have been taken to control gluten cross-contamination, you may indicate which menu items do not have gluten-containing ingredients. This allows people with coeliac disease to make choices about the food they eat based on their individual levels of sensitivity.
The Food and Drink Federation provides specific information and guidance on allergen-free claims.
[Source: Food Standards Agency]
About Food Allergies & Intolerances
In the UK, it is estimated that 1-2% of adults and 5-8% of children have a food allergy, which equates to around 2 million people in total. This figure does not include those with food intolerances. This means the number of people with a food allergy and/or food intolerance is considerably higher.
An allergic reaction can be produced by a tiny amount of a food ingredient that a person is sensitive to (for example a teaspoon of milk powder, a fragment of peanut or just one or two sesame seeds). Symptoms of an allergic reaction can range from mild symptoms such as itching around the mouth and rashes; and can progress to more severe symptoms such as vomiting, diarrhoea, wheezing and anaphylaxis (shock). Around ten people in the UK die from allergic reactions to food every year.
As there is usually no cure for a food allergy, the only way to manage the condition is to avoid food that makes the person ill by being provided allergen ingredients information. Therefore, it is very important that food businesses provide clear and accurate information about allergenic ingredients in their products.
[Source: Food Standards Agency]
The FSA guidance states that information on allergenic ingredients must be either
- written up front (for example on a menu or menu board) without the customer having to ask for (food allergens) information
- sign-posted to where written information can be found or obtained
- sign-posted to say that oral information can be obtained from a member of staff