UK & EU Allergen Labelling: What Restaurants Actually Need
What PREA and FIC require of non-prepacked food, how the 14 allergens differ from the US nine, and the practical record-keeping for an inspector.
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UK and EU rules on allergens in restaurants are more prescriptive than the US equivalents, and considerably less understood by operators. The core requirement is simple — inform the guest, in writing, of the 14 allergens present in a dish — but the operational consequences are real.
The legal position
Three instruments matter:
- Regulation (EU) No 1169/2011 (FICA) — the general food information framework, Article 21 covering allergens.
- Food Safety and Hygiene (England) Regulations 2013 (and equivalents) — which incorporate allergen duties for non-prepacked food.
- PPDS ( Natasha's Law) — from 1 October 2021, requires written allergen information for non-prepacked food in England, not just verbal notification.
The US and EU lists are not the same
The EU's FIC list is the 14. The US list is now also 14, but the two are different sets. This matters if you operate across regions or serve an international clientele:
| Allergen | In EU 14 | In US 14 |
|---|---|---|
| Milk, egg, fish, crustacean, tree nuts, peanut, wheat, soy, celery, mustard, sesame, molluscs, lupin, sulphites | Yes | Yes |
| **Lupin** | Yes | Yes |
| **Mustard** | Yes | Yes |
| **Celery** | Yes | Yes |
| **Molluscs** | Yes | Yes |
| **Sulphur dioxide / sulphites** | Yes | Yes |
The practical version: the US list is the 9 plus lupin, mustard, molluscs and sulphites. The EU list adds celery and sesame to reach 14. Both end up at 14, but a chef trained on one list will omit celery or sesame when operating under the other.
What PPDS actually changed
Before October 2021, allergen information for non-prepacked food could be given verbally. Natasha's Law required it in writing, available before the order is placed.
In practice this means:
- Allergen information must exist in written form and be available before the guest orders — not produced after a query.
- It must be easy for the guest to understand. A dense table of abbreviations is technically available and practically useless.
- It must be accurate and kept current. Serving out-of-date written information is a compliance failure in its own right, separate from the allergen itself.
A printed menu with a clear per-dish allergen indication satisfies this well. A verbal answer from a knowledgeable manager does not, however well-intentioned.
Prepacked vs non-prepacked
The distinction determines which rules apply:
| Category | Rules | Example |
|---|---|---|
| Prepacked for direct sale | Full ingredient list + emphasised allergens | A packaged retail sandwich sold as-is |
| Non-prepacked (loose) | Written allergen information, 14 allergens | Everything made in your kitchen |
| Loose ingredients sold separately | Advisory labelling on the ingredient itself | A bag of flour beside your pizza |
Restaurants are almost entirely in the second category. The third catches you when you sell flour, pasta or breadsticks by weight alongside a dish.
Records an inspector will ask for
- The written allergen information currently in use, dated.
- Evidence that staff were trained — attendance, and ideally assessment.
- The process document for handling an allergen query.
- Any incident reports and the remedial action taken.
- Supplier specifications for high-risk ingredients (stock, sauces, oils, breading).
Common findings
In inspection experience the recurring issues are unglamorous:
- Written information present but describing the old menu.
- Staff able to recite the 14 allergens but unable to say which dishes contain them.
- A 'may contain' statement applied so broadly across a menu that it communicates nothing.
- No record at all of who prepared the written information or when.
- Photographic or social media content promoting a dish whose recipe has since changed.
Making compliance sustainable
Almost every finding above traces back to the same root: the written information is maintained by hand, so it drifts. Generating it from the menu and re-generating on every menu revision removes the largest single category of finding — and takes the daily operational load off the person who has to run service.
What compliance still requires is judgement and a record: controls in place, staff assessed, incidents logged. Software handles accuracy and currency. It does not replace the process.