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Kitchen deep cleaning - food law
Allergen law places a clear duty on caterers: to disclose, accurately, whether the food they serve contains any of the 14 major allergens - because customers with allergies rely on that information to eat safely. The duty applies however the food is sold, though the way it is disclosed differs. Here is what caterers must disclose under allergen law, and why getting it right is a serious responsibility.
The short answer
Allergen law requires caterers to disclose whether the food they serve contains any of the 14 major allergens (celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya and sulphur dioxide), so that customers with allergies can make safe choices. This is a legal duty, and it rests on the reality that for someone with a serious allergy, accurate allergen information can be a matter of life and death - so the law requires the information to be provided accurately and made available to the customer before they buy. The duty applies to all the food a caterer serves, but the way the disclosure is made depends on how the food is sold. For food packaged on-site before ordering (prepacked for direct sale, or PPDS), the information must be on a label: a full ingredients list with the allergens emphasised. For food sold loose or made to order (a dish cooked to order, food served at a counter), the information does not have to be on a label but must still be provided and accurate - through the menu, a sign or allergen guide, or verbally by staff. So the form of disclosure varies with the type of sale, but in every case the duty is the same: the allergen information must be accurate and available to the customer before they buy. Underlying the disclosure is the requirement to actually know what allergens are in each dish - a caterer cannot disclose accurately without knowing accurately, which means maintaining reliable records of the ingredients in each item. And the disclosure has to be taken seriously and got right, because inaccurate or missing allergen information can cause a serious, even fatal, allergic reaction, and is a breach of food law with legal consequences. So what caterers must disclose is clear: whether each dish contains any of the 14 allergens, accurately, available before the customer buys, in the form appropriate to how the food is sold - a duty grounded in the real harm that wrong allergen information can cause.
Key points
The duty
At its core, allergen law places a clear duty on caterers: to disclose whether the food they serve contains any of the 14 major allergens, accurately, so that customers with allergies can decide whether it is safe for them to eat. The 14 allergens are the ones the law singles out as most associated with serious allergic reactions - celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide - and for each dish a caterer serves, the caterer must be able to tell a customer, accurately, which of these it contains. This is the fundamental duty: not to hide, guess at, or misstate the allergens, but to disclose them accurately, because an allergic customer relies on that disclosure to avoid a food that could harm them.
The duty rests on the seriousness of the stakes. For someone with a serious allergy, eating a food containing their allergen can cause a severe reaction, including anaphylaxis, which can be fatal - so the allergen information a caterer provides is not a nicety but potentially a matter of life and death for the allergic customer. The law exists because people have died from allergens they were not told about. So the duty to disclose accurately is grounded in real, serious harm, which is why it is a legal obligation and why accuracy is central to it: an inaccurate disclosure - saying a dish is free of an allergen it actually contains - is not a minor error but a potentially dangerous misinformation. So the heart of what caterers must do is disclose the 14 allergens accurately for the food they serve, taking the accuracy seriously because a customer's safety depends on it. Everything else about the disclosure - how it is provided, when it must be available - follows from this basic duty to give accurate allergen information for each dish.
How it is disclosed
While the duty to disclose accurately is the same for all food, the way the disclosure is made depends on how the food is sold - because different types of sale suit different forms of information. For food that is packaged on the premises before the customer orders it (prepacked for direct sale, PPDS), the information must be on a label: the food must carry a full ingredients list with the 14 allergens emphasised within it, so the customer picking up the pre-packaged item can see the allergens without being able to ask. So PPDS food carries its allergen disclosure on a written label. This is the form for food the customer takes ready-packaged, where there may be no staff interaction at the point of choice.
For food that is sold loose or made to order - a dish cooked to order, food served from a counter - the allergen information does not have to be on a label, but it must still be provided and be accurate, and can be given in other ways: on the menu (listing allergens against dishes), on a sign or allergen guide the customer can consult, or verbally by staff when asked. The key requirements are that the information is accurate and genuinely available to the customer who needs it before they buy. So for made-to-order and loose food, the disclosure can be verbal or on a menu, provided it is accurate and available. Many caterers use a combination - an allergen matrix that staff consult, plus a note on the menu inviting customers to ask about allergens - so that anyone with an allergy can get correct information. So the form of disclosure fits the type of sale: a written label for PPDS, and menu, signage or verbal information for loose and made-to-order food. But whatever the form, the underlying duty is the same - accurate allergen information, available to the customer before they buy - so the form is a matter of how the duty is met, not whether it applies.
Available before buying, and accurate
Two things are essential about the disclosure however it is made: it must be available to the customer before they buy, and it must be accurate. Available before buying matters because the whole point is to let the customer make a safe choice - which they can only do if they have the information before they commit to and eat the food. So the allergen information has to be accessible at the point of choice: on the label of a PPDS item the customer picks up, on the menu or sign they consult, or from staff they can ask before ordering. Information that is only available after the customer has bought or eaten the food is useless for the decision it is meant to inform. So the disclosure has to be genuinely available to the customer at the point where they are deciding what to eat, which is before they buy.
Accurate matters because inaccurate allergen information is worse than none - it can actively mislead an allergic customer into eating something dangerous. If a caterer tells a customer a dish is free of their allergen when it actually contains it, the customer may eat it in reliance on the assurance and suffer a serious reaction. So the disclosure must be accurate: based on what is genuinely in each dish, not guessed or assumed. This is why accuracy depends on the caterer actually knowing what allergens are in each dish - which requires maintaining reliable records (an allergen matrix) of the ingredients in each item, kept current as recipes and suppliers change. A caterer cannot disclose accurately without knowing accurately, so the accurate knowledge underlies the accurate disclosure. So the disclosure must be both available before buying (so the customer can use it to choose) and accurate (so it does not mislead them) - and the accuracy rests on the caterer knowing, reliably, what is in each dish. These two requirements, availability and accuracy, are what make the disclosure genuinely serve its purpose of keeping allergic customers safe.
Why it must be got right
The duty to disclose allergens accurately has to be taken seriously and got right, because the consequences of getting it wrong are severe - both for the customer and, in law, for the caterer. For the customer, inaccurate or missing allergen information can cause a serious, even fatal, allergic reaction: an allergic person who is not told, or is wrongly told, about an allergen may eat it and suffer anaphylaxis, which can kill. So a failure in allergen disclosure is not a minor administrative lapse but a potential cause of serious injury or death - which is why the law is strict about it, and why Natasha's Law strengthened the labelling requirements after a death from an undisclosed allergen. The disclosure is a genuine safety matter, with a person's life potentially depending on it.
For the caterer, failing the duty is a breach of food law, with legal consequences, quite apart from the moral weight of causing harm to a customer. So there are strong reasons - the customer's safety and the caterer's legal obligation - to get the disclosure right. Getting it right means the whole discipline: knowing accurately what allergens are in each dish (an accurate, current matrix), providing the information in the right form for how each food is sold (label for PPDS, menu, signage or verbal for loose and made-to-order), making it available to the customer before they buy, and training staff to give accurate allergen information and take allergy questions seriously. Each part matters, and a failure in any - an out-of-date matrix, a wrong verbal answer, a missing PPDS label - can undermine the whole disclosure and expose an allergic customer to harm. So what caterers must disclose is clear, and the responsibility to do it accurately is serious: the allergen information they provide can be the difference between a customer eating safely and suffering a dangerous reaction. That is why the duty is treated as a genuine responsibility, not a formality - because for allergic customers, its accuracy can be a matter of life and death.
The takeaway
Allergen law requires caterers to disclose whether the food they serve contains any of the 14 major allergens, accurately, so allergic customers can make safe choices. The duty applies to all the food a caterer serves, and the form of the disclosure fits how the food is sold: a written label (full ingredients with allergens emphasised) for food packaged on-site before ordering (PPDS), and menu, signage or verbal information for food sold loose or made to order. But whatever the form, two things are essential - the information must be available to the customer before they buy (so they can use it to choose), and it must be accurate (so it does not mislead them). And the accuracy rests on the caterer actually knowing what is in each dish, which means maintaining reliable, current records of the ingredients.
The duty has to be got right because the consequences of failing it are severe. For the customer, inaccurate or missing allergen information can cause a serious, even fatal, allergic reaction - the law exists because people have died from allergens they were not told about. For the caterer, it is a breach of food law with legal consequences. So getting it right means the whole discipline: knowing accurately what allergens are in each dish, providing the information in the right form, making it available before the customer buys, and training staff to answer accurately. Each part matters, and a failure in any can expose an allergic customer to harm. So what caterers must disclose is clear - the 14 allergens, accurately, available before buying, in the form appropriate to the sale - and it is a serious responsibility, because its accuracy can be a matter of life and death for allergic customers.
Questions
Whether the food they serve contains any of the 14 major allergens - celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide - accurately, so allergic customers can make safe choices. For each dish, the caterer must be able to tell a customer, accurately, which of these it contains. The duty applies to all the food served, though the way the information is provided varies with how the food is sold. Underlying it is the requirement to actually know what allergens are in each dish, because a caterer cannot disclose accurately without knowing accurately. So the disclosure is: the 14 allergens, per dish, accurately - grounded in the reality that for an allergic customer, this information can be a matter of safety, even life and death.
All food the caterer serves - the duty is the same, though the form of disclosure differs. For food packaged on-site before ordering (PPDS), the allergen information must be on a label (a full ingredients list with allergens emphasised). For food sold loose or made to order, the information does not have to be on a label but must still be provided and accurate - on a menu, a sign or allergen guide, or verbally by staff. So the duty to disclose accurately covers everything the caterer serves; what changes with the type of sale is how the disclosure is made, not whether it applies. A caterer cannot decline to disclose allergens for made-to-order food because it has no label; they must provide the information another way. So the duty is universal across the food served, with the form fitting the sale.
Yes, for food sold loose or made to order - such information does not have to be on a label and can be given verbally by staff, provided it is accurate and available to the customer before they buy. Many caterers use a combination: an allergen matrix that staff consult to give accurate answers, plus a note on the menu inviting customers to ask about allergens. What matters is that the verbal information is accurate (based on what is genuinely in each dish, not guessed) and that staff can reliably provide it - which is why staff training and an accurate matrix are important. Verbal disclosure is not allowed as a substitute for the required label on PPDS (packaged-in-advance) food, which must carry a written ingredients list. But for loose and made-to-order food, accurate verbal information is a valid form of disclosure.
Because the whole purpose of the disclosure is to let the allergic customer make a safe choice - which they can only do if they have the information before they commit to and eat the food. Allergen information that is only available after buying or eating is useless for the decision it is meant to inform. So the information must be accessible at the point of choice: on the label of a PPDS item the customer picks up, on the menu or sign they consult, or from staff they can ask before ordering. This is a core requirement of the disclosure: it must be genuinely available to the customer at the point where they are deciding what to eat. A caterer who only reveals allergen information after the sale has not met the duty, because the customer could not use it to make the safe choice the disclosure exists to enable.
It can cause serious, even fatal, harm to an allergic customer, and it is a breach of food law. If a caterer fails to disclose an allergen, or wrongly tells a customer a dish is free of one it contains, the allergic customer may eat it and suffer a severe reaction, including anaphylaxis, which can be fatal. So a failure in allergen disclosure is not a minor administrative error but a potential cause of serious injury or death - which is why the law is strict and why Natasha's Law strengthened the requirements after a death from an undisclosed allergen. For the caterer, it is also a breach of food law with legal consequences. So there are strong reasons - the customer's safety and the caterer's legal obligation - to get the disclosure right, which is why it has to be taken seriously as a genuine responsibility rather than a formality.
By actually knowing what allergens are in each dish, which means maintaining reliable, current records - an allergen matrix listing which of the 14 allergens each item contains, based on the real ingredients and recipes, kept up to date as recipes and suppliers change. Accurate disclosure depends on accurate knowledge: a caterer cannot tell a customer accurately what a dish contains without knowing accurately, so the matrix (or equivalent record) is the foundation. From there, the information has to be provided in the right form (label, menu or verbal), and staff trained to use the records to give accurate answers and take allergy questions seriously. So the accuracy of the disclosure rests on the accuracy of the underlying ingredient knowledge, maintained and kept current - which is why keeping the allergen records accurate and up to date is central to meeting the duty.
Accurate allergen disclosure works alongside cross-contamination control, so the food matches what is disclosed - our kitchen deep cleaning keeps surfaces and equipment clean. Ask us about a deep clean.
