BHA Allergen Toolkit

BHA Allergen Toolkit

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New Allergen Regulations introduced by the EU say that from December 13th 2014 all UK food service providers will be obliged to accurately track, record and communicate to the public 14 of the most common foods to cause allergic reactions.

To support you, we’ve created a Guidance Toolkit and events designed to assist you in understanding and implementing the new Allergen Regulations and ultimately saving you money and time.  It is available for FREE to all BHA members.

Please log in to access this content and enjoy the full benefits of the members-only toolkit HERE.

    • BHA Food Allergen Checklist
    • Access to online BHA Forum
    • Template letter to food suppliers
    • Template letter to drink suppliers
    • Allergen Questions & Answers
    • BHA Food Allergen Report
    • more to follow...

Have a taste of our allergen toolkit...


Why do we need to get focused on allergens?

The law will soon change on labelling and communicating allergens in food. Previous regulation focused on ensuring “pre-packed” food was clearly labelled to show any potential food allergens.  From 13 December, all food businesses, including food service operators, will be responsible for clearly informing their customers about the presence of any of 14 food allergens in the food they serve. It means that everyone from the suppliers to the chefs to the waiting staff will need to understand what food ingredients could cause allergies and how to inform their customers about them.

Who needs to take notice of the new laws?

It’s relevant for all food businesses that have direct interaction with their customers, such as hotels serving food, restaurants, caterers, sandwich shops and bakers.

What are the allergenic ingredients?

There are 14 allergens that must be labelled or indicated as being present in foods and these are:

      • Cereals containing gluten such as wheat, rye, barley, oats, spelt or khorasan
      • Crustaceans for example prawns, crabs, lobster, crayfish
      • Eggs
      • Fish
      • Peanuts
      • Soybeans
      • Milk (including lactose)
      • Nuts such as almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia (or Queensland) nuts
      • Celery (including celeriac)
      • Mustard
      • Sesame seeds
      • Sulphur dioxide (>10mg/kg or 10mg/L)
      • Lupin
      • Molluscs for example clams, mussels, whelks, oysters, snails and squid

When are the changes to the law taking place?

As of 13 December 2014, all food sellers must be able and willing to answer any consumer queries regarding allergens in foods you serve.

If food is “pre-packed” there is no change in the law and any allergenic ingredients need to continue to be emphasised in the labelling.

What is new?

Where food is offered for sale to the final consumer or to “mass caterers” without packaging, or where foods are packed on the sales premises at the consumer’s request or pre-packed for direct sale, information about allergenic ingredients must be provided. Food includes drink, so allergenic ingredients in alcoholic and non-alcoholic drinks must also be given to customers on request.

Allergen information must be provided for non-pre-packed foods (such as plated dishes) in written or oral formats with clear signposting to where consumers can obtain this information, when it is not provided up front in a written format. Waiting staff will need to explain which ingredients in which dishes may be allergenic.

BHA Allergen Toolkit

Please login in order to access this content and enjoy the full benefits of the members only toolkit HERE.

      • BHA Food Allergen Checklist
      • Access to online BHA Forum 
      • Template letter to food suppliers
      • Template letter to drink suppliers
      • Allergen Questions & Answers
      • BHA Food Allergen Report
      • more to follow...

Communicating allergen information to customers

Information on specific allergenic ingredients must be either written up front (for example on a menu or menu board) without the customer having to ask for information OR, if written information is not provided, there must be a statement in a prominent place in the establishment along the lines:

“Before Ordering, Speak to Our Staff if you have a Food Allergy or Intolerance.”

Information on which, if any, allergens are in a menu dish can be provided orally, but this must be consistent and verifiable (i.e. a business must have processes in place to capture information from recipes or ingredients lists from products bought in, and make this available to staff).

It is important that customers with food allergies or intolerances are able to make informed choices when choosing products.

All staff serving customers should be made aware of the potential risks to customers' health if they advise them incorrectly. A process must be in place to ensure that allergen information can be easily obtained and is accurate and consistent.

Customers are strongly advised to speak to staff regarding their allergy requirements. It may be a good idea to have a single point of contact for questions, rather than all waiting staff.

Some legal definitions

Mass caterer / Catering establishment

A restaurant, canteen, club, public house, school, hospital or similar establishment (including a vehicle or a fixed or mobile stall) where, in the course of a business, food is prepared for delivery to the ultimate consumer and is ready for consumption without further preparation.

'Pre-packed food'

'Pre-packed' foods are foods, which have been put into packaging before sale (to the final consumer or to mass caterers), where there is no opportunity for direct communication between producer and customer, and the contents cannot be altered without opening or changing the packaging. For example, most pre-packed foods sold in supermarkets will fall under this definition, such as tinned food, ready-made meals or frozen food products.

'Pre-packed for direct sale'

Generally means those foods that have been packed on the same premises as they are being sold. In these situations, it is thought that the customer would be able to speak to the person who made/packed the foods to ask about ingredients and so these foods do not generally have to be labelled with ingredients by law. Foods which could fall under this category are meat pies made on site, and sandwiches made and sold pre-packed or not pre-packed from the premises in which they were made.

'Non-pre-packed' (Loose foods)

Foods which are non-pre-packed can be often described as foods sold loose. In a retail environment this would apply to any foods which are sold loose from a delicatessen counter (for example, cold meats, cheeses, quiches, pies and dips), fresh pizza, fish, salad bars, and bread sold in bakery shops etc. In a catering environment this would apply to foods ready for consumption such as meals served in a restaurant, café or purchased from a takeaway.

The BHA perspective

“The British Hospitality Association is a consistent advocate of local supply chains across the hospitality and tourism industry.  These new allergen regulations means that knowing your suppliers and the ingredients used is vital.

“Our view and approach has always been to encourage food service businesses to purchase food from smaller local businesses.  This is demonstrated by our involvement with SALSA (Safe and Local Supplier Approval Scheme) which provides assurance of food safety in small businesses and is supported by BHA members .

“However, we recognise that these new regulations will put a significant burden on hospitality suppliers and the front line service providers and we estimate the cost of implementing them could be in the region of £200 million per year.”

Facts & Stats

      • According to the NHS 1-2% of adults have a food allergy
      • According to the NHS 5-8% of children have a food allergy
      • However, when questioned, 20% of people think they have an allergy (source: NHS)
      • It is estimated that in the region of one million people will need to be trained up on the new regulations, and training will need to be kept up to date every time there is a menu or supplier change
      • There are 14 allergenic foods as part of the regulations
      • There are c. 8 billion meals served each year in the UK
      • The BHA estimates that the cost to the industry could be up to £200 million per year
      • Some countries are making it mandatory to put allergen details on the menu. In the UK the focus is on training and awareness
      • The FSA estimates it will take a hospitality professional approximately three hours to become proficient in the new regulations
      • Regulations come into force on 13 December 2014 just in time for Christmas dinner menus
      • The requirements cover hotels, restaurants, caterers, pubs, festival caterers, burger vans, street food sellers, bakers, sandwich makers etc.
      • In the UK the focus is on providing information to the consumer orally rather than having large amounts of information on the menu



*This information toolkit is provided by the British Hospitality Association in cooperation with Bond Dickinson LLP. It is intended to assist in interpreting the Food Information Regulations 2014 and European Directives 2003/89/EC and 2006/142/EC. The content is provided for general information only and must not be used for giving legal or other professional advice. Whilst every care has been taken to ensure the accuracy of content, the authors accept no responsibility for loss or consequential loss occasioned to any person acting or refraining from action as a result of any statement in it.