Allergen Legislation and Legal Responsibilities
The legal framework
UK allergen law derives from the Food Information Regulations (implementing FIC/FIR) and the Food Safety Act, enforced by local authorities. Prepacked foods must carry a full ingredients list with the 14 allergens emphasised (bold, capitals, contrasting background). Non-prepacked foods (loose, deli, restaurant meals) must provide allergen information in writing or orally, with a clear written signpost to how to obtain it. From October 2021, Natasha's Law requires prepacked for direct sale (PPDS) foods to carry a full ingredients list with allergens emphasised.
Responsibilities
Food business operators must provide accurate, consistent and verifiable allergen information, ensure staff are trained, keep records, and avoid misleading claims. 'Free-from' and 'suitable for' claims are stricter than 'no added'. 'May contain' is voluntary precautionary labelling and should only be used after a genuine risk assessment. Gluten-free claims are controlled (20 mg/kg or less for gluten-free; 100 mg/kg for very low gluten oats).
Traps
- PPDS is defined by being packed on the same premises where sold (e.g. sandwich made and wrapped in a café), not by being wrapped.
- Oral allergen information is permitted for non-prepacked food, but a written signpost is still required.
- Allergen information must be free of charge.
- The operator, not the customer, bears responsibility for accuracy.
Worked example
A bakery wraps a cheese sandwich on site and sells it from the same shop. It is PPDS, so it needs a label listing ingredients with milk and gluten (wheat) emphasised, even if the customer could ask staff.