The fourteen
UK law names fourteen allergens that must be declared. They are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites, and tree nuts.
The underlying law is assimilated EU Regulation 1169/2011 together with the Food Information Regulations 2014. What changes between settings is not the list but how the information has to reach the customer.
In the dining room: verbal is allowed, silence is not
For non-prepacked food — anything made and served loose rather than sold in a package — allergen information may be provided by any means, including verbally by a member of staff.
The condition attached to that is the part restaurants forget. If the information is going to be given verbally, there must be a clearly visible sign telling the customer that it is available and where to ask. No particular wording is required by law; the FSA’s guidance offers the example "We have a menu with allergen information, please speak to staff who will be happy to provide it."
The FSA also advises that verbal information should be backed by the same information in writing, so what staff say is accurate and consistent between shifts. That is best practice rather than a legal minimum, and this guide flags the difference rather than blurring it — but a kitchen with no written allergen matrix is one new starter away from a bad answer.
Online, the rule changes
Taking orders through a website or by telephone is distance selling, and it is where the web obligation sits. Written allergen information must be available to the customer at two separate points.
- Before the order is placed — so it has to be on the site, reachable before the basket is confirmed, not supplied afterwards.
- Again when the food is delivered — a sticker on the packaging, an enclosed menu, or the equivalent.
The FSA’s best-practice guidance adds a specific web instruction: the information should be no more than one click away. Where it cannot be provided online, the customer must still be able to get it easily, for example by telephone to a member of staff.
Read that against a typical restaurant website and the problem is obvious. A menu as a downloadable PDF is not one click away in any meaningful sense, and a menu living inside a third-party ordering widget is frequently not readable at all until the customer has started a basket.
Prepacked for direct sale
There is a third category worth naming because cafés and delis fall into it without noticing. Prepacked for direct sale — PPDS — is food packaged on the premises before a customer orders it: the sandwiches in the chiller, the boxed salads on the counter.
PPDS items require a label carrying the name of the food and a full ingredients list with the allergens emphasised within it. This is a stricter requirement than the loose food served at a table, and it catches businesses that think of themselves as restaurants but sell a grab-and-go range alongside.
If your website pictures a counter full of pre-packed items, that range is under the labelling rules rather than the verbal ones, and the site should not imply otherwise.
What this means for how the site is built
Almost every allergen failure we see on a restaurant website is a build decision rather than a kitchen one.
- The menu as a PDF. It is not one click away, it is painful on a phone, search engines read it poorly so you never appear for the dish you are known for, and it goes stale because updating it means finding the file.
- The menu trapped inside an ordering widget. If the allergen information only exists after the customer starts a basket, it is not available before the order in any useful sense — and nothing in it is indexed.
- Allergen data as a separate afterthought page. It is better than nothing and worse than putting it on the dish, where the person deciding is actually looking.
- A photograph of a menu. Invisible to search engines, invisible to screen readers, and unusable by exactly the customers who most need to read carefully.
- No signposting at all, on a site that takes bookings but not orders — the dining room rule still expects the customer to be told where to ask.
The version that works is unglamorous: each dish as real text on a real page, with its allergens on it, updatable in a minute by whoever changes the menu. That satisfies the distance selling requirement, it is readable on a phone, and it ranks for every dish you serve — which a PDF never will.
The commercial side of doing it properly
There is a real market being underserved here. The FSA’s own research into distance selling found that of adults with a food hypersensitivity who had ordered this way, 47% received written allergen information and 54% were asked about an allergy before ordering. Roughly half the time, the customer most motivated to choose carefully is not being given what they need.
A household where one person cannot eat freely chooses the restaurant that makes it easy, and keeps choosing it. Publishing allergens properly on the dish is one of the few compliance jobs that is also a direct commercial advantage over the restaurant next door.
And the search side is open. Real menu pages are how a restaurant actually competes for those.
