Allergen Information on a Canteen Counter

A canteen counter must be able to tell a customer, in writing or by a member of staff with clear signposting to that answer, whether a dish contains any of the fourteen allergens the law names. The food on a canteen counter is not packaged, so it does not need a label. It still needs an answer, and the answer has to be accurate, current and easy to get to.

What counts as the fourteen allergens?

The list sits in Annex II of the retained Regulation (EU) No 1169/2011, enforced by the Food Information Regulations 2014 in England, the Food Information (Wales) Regulations 2014 and the Food Information Regulations (Northern Ireland) 2014. It names cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia), celery, mustard, sesame seeds, sulphur dioxide and sulphites above 10mg/kg or 10mg/litre, lupin, and molluscs. A canteen does not get to decide which of these matter. It has to be able to answer for all fourteen, on every dish it serves, every day it serves it.

Does a canteen counter need a printed allergen label?

No, and this is the point that trips up a kitchen that has read about "Natasha's Law" without reading the rest of it. The amendment that carries Natasha Ednan-Laperouse's name, in force since 1 October 2021 (in Wales through the Food Information (Wales) (Amendment) (No. 2) Regulations 2020), covers food that is pre-packed for direct sale, sandwiches made ahead and wrapped on a shelf, a pasty in a cellophane sleeve. That food must carry a full ingredients label with the allergens emboldened. Food served loose across a counter, ladled, plated, handed over at the till, is a different category in the regulations: non-prepacked food. It does not need a label. It needs allergen information available to the person asking for it, in a form the Food Standards Agency can call clear.

How is a canteen allowed to give that information?

The Food Standards Agency's technical guidance gives businesses serving non-prepacked food flexibility to provide the information by any means. Written information, on a menu, a chalkboard, a laminated sheet kept at the till, or a folder a member of staff can hand over. A conversation, where a member of staff who actually knows the dish answers the question directly. Or both: the guidance's best practice is to make the information easily available in writing and have staff support it with a conversation, because a spoken answer from someone who was not in the kitchen that morning is only as good as what they were told.

A sign that says "ask a member of staff about allergens" is legal only if a member of staff can actually answer, accurately, for every dish on the counter that day. A counter that changes its menu daily, which most canteens do, needs that written note checked and updated daily, not printed once in September and left on the wall through December.

What does this mean for a counter that serves twelve dishes a day, not twelve menu items printed once a year?

It means the allergen note has to travel with the dish, not with the printed menu. A kitchen that cooks from a changing crate, the same seasonal habit this ledger has recorded on a canteen menu before, cannot rely on a fixed allergen sheet from last month. Each day's board needs its own short note: today's soup contains celery and milk; today's pie contains gluten and egg. The regulations do not demand a laboratory test. They demand that whoever assembled the dish actually knows, and wrote it down, what went into it.

Where should the information sit, physically, on the counter?

The FSA guidance is specific on this: a business that gives the information orally must use clear signposting to direct the customer to where it can be found. A canteen that keeps its allergen chart or recipe sheets behind the till, out of sight, has to say so on the board a customer reads first. The guidance names a chart, a recipe book or ingredient information sheets as the way to keep a spoken answer accurate, which is the practical argument for doing both rather than treating the sign as the whole answer.

What does a canteen get wrong most often?

Two things, in this ledger's experience of counters. The first is treating a verbal answer as sufficient without anything written to back it up, so a new or rushed member of staff gives a wrong answer with nothing to correct it against. The second is leaving a seasonal dish off the allergen note because it only runs for a fortnight. The regulations draw no distinction between a dish served for a year and a dish served for a fortnight. If it is on the counter, it is covered.

A canteen that gets this right treats the allergen note the way it treats the till roll: written fresh, checked against what actually went into the pot, and kept where the first question gets asked, at the counter, not in a drawer.