Allergen labelling: legal requirements and digital display

Allergen Labelling for Restaurants: Legal Requirements and Digital Display

Every year, around 10 people in the UK die from food allergy reactions. Approximately 2 million people in the UK have a diagnosed food allergy — and a further 6 million experience food intolerances. In the EU, between 11 and 26 million people are estimated to suffer from food allergy. In the United States, more than a quarter of adults and children have at least one allergy.

These guests are sitting at your tables tonight.

The question of allergen labelling in restaurants is not primarily a legal question — it is a safety question that also has legal consequences. Getting it wrong has cost restaurant owners unlimited fines, criminal convictions, and in the most tragic cases, contributed to deaths that proper labelling would have prevented. Getting it right is not complicated when you have the right system, and a digital menu is one of the most effective tools available for staying compliant in real time.

This guide covers the legal landscape by geography, what specifically is required of your restaurant, and how to implement allergen information on your digital menu in a way that protects your guests and your business.

The scale of the problem: why allergen compliance matters

The regulatory framework around allergen information in restaurants did not emerge from bureaucratic enthusiasm. It emerged from a series of preventable deaths.

In the UK, Natasha Ednan-Laperouse died in 2016 after eating a pre-packaged Pret a Manger baguette that contained sesame she was allergic to — sesame that wasn't listed on the packaging. Natasha's Law, which came into force in October 2021, directly resulted from her case. Owen Carey died in 2017 after eating a Byron burger that contained undisclosed buttermilk — he had a dairy allergy and had specifically asked about allergens. Owen's Law followed in 2024.

The FSA estimates that approximately 1 in 100 catering menus contains an undeclared allergen risk at any given time. That is not a fringe problem — it is a systemic one, and the regulatory environment is tightening in direct response.

For restaurant owners, the consequences of non-compliance have become severe and very public. In May 2025, an Uxbridge restaurant was fined nearly £44,000 after a customer with a nut allergy suffered a severe reaction. In October 2025, a London restaurant owner was fined £45,000 for failing to safely store and prepare gluten-free meals. In the UK, under the Food Safety Act 1990, failure to comply with allergen regulations is a criminal offence carrying a maximum penalty of an unlimited fine and/or 2 years' imprisonment.

The 14 major allergens: what every restaurant must track

In the EU and UK, 14 substances must be declared whenever they are present as ingredients in food served to customers. These are defined in EU Regulation 1169/2011 (retained in UK law post-Brexit) and enforced through national food information regulations:

These 14 allergens must be declared for every dish on your menu where they are present — not just the obvious ones. A mustard vinaigrette in a salad dressing, sulphites in a house wine served with food, sesame oil in a marinade — all require declaration.

Legal requirements by geography

European Union — EU Regulation 1169/2011 (in force since December 2014)

EU Regulation 1169/2011 on the provision of food information to consumers was a landmark change because it extended mandatory allergen information for the first time to non-prepacked food, including in restaurants and cafes — previous legislation had only covered prepacked foods. The regulation requires:

• Allergen information for all 14 substances in every dish where present

• Information that is easily accessible to the consumer before purchase

• Written allergen information presented in a legible and clearly visible form

• Allergens emphasised in any ingredients list (by font, style, or background colour)

• The same requirements apply equally to online menus and distance selling

The regulation does not prescribe a specific format — it can be a menu, a chalkboard, a separate allergen information sheet, or a digital menu — but the information must be accessible before the customer orders, not only when they ask.

The EU does not allow restaurants to comply by only providing allergen information upon specific customer request. The information must be proactively available.

United Kingdom — Natasha's Law, Owen's Law, and FSA March 2025 Update

The UK operates under retained EU Regulation 1169/2011 (now assimilated UK law) alongside two significant extensions:

Natasha's Law (October 2021) — Requires all prepacked for direct sale (PPDS) food to display a full ingredients list with the 14 major allergens clearly emphasised. This applies to food items packaged on-site before a customer requests them — sandwiches, salads, pastries wrapped in advance.

Owen's Law (2024) — Requires food businesses in England to communicate allergen information verbally to customers with allergies. This builds on the written information requirement by adding an active communication obligation for staff.

FSA Best Practice Update (March 2025) — The FSA updated its guidance to push restaurants more firmly toward written allergen information on menus, moving away from the "ask a member of staff" approach that many venues still rely on. While this guidance is technically best practice rather than law, environmental health officers increasingly use it as their benchmark during inspections — making written allergen information the practical standard for UK restaurants regardless of the technical legal minimum.

Under current UK law, allergen information can be provided either in writing or verbally. However, the FSA's 2025 best practice guidance strongly recommends that written allergen information should always be available for non-prepacked food.

United States — No federal restaurant requirement, but growing state legislation

As of 2025, there are no US federal or state regulations on allergen disclosures for restaurant menus specifically. The FDA's FALCPA (Food Allergen Labelling and Consumer Protection Act 2004) covers packaged foods only — not restaurant-prepared meals. In 2023, sesame was added as the ninth major allergen for FDA-regulated packaged foods, but this did not extend to restaurant menus.

The absence of federal regulation does not mean the legal landscape is empty:

• California is actively advancing SB 68 (as of April 2025), which would require restaurants to disclose major allergens on menus — supported by Allergy & Asthma Foundation of America

• New York City's food allergy rules require restaurants to inform patrons about eight major allergens upon request and prohibit misrepresentation

• Massachusetts has a restaurant food allergy law requiring training and a "Food Allergy" notice on menus when staff have been trained

• Multiple states have voluntary or mandatory training requirements for food handlers

US restaurants serving guests from the EU or UK — particularly in tourism markets — should consider aligning with EU standards as a risk management baseline, regardless of local legal minimums.

The nine major US allergens recognised by the FDA: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame (added 2023).

Three compliance approaches and which one works best

The third approach — allergen information on the menu at the item level — is the most legally defensible and the most practically useful. It is also the most difficult to maintain with a printed menu, because every recipe change requires a reprint. This is exactly where a digital menu creates a structural compliance advantage.

How a digital menu solves the allergen compliance problem

A printed menu's allergen information is accurate at the time it is printed. It may be inaccurate by the time a guest reads it, if:

• A supplier changed an ingredient formulation

• A new dish was added mid-season without a reprint

• A recipe modification was made operationally that wasn't captured on the menu

• Seasonal substitutions changed the allergen profile of an existing dish

Every one of these failure modes is eliminated by a digital menu updated in real time. When you change a recipe, you update the allergen information simultaneously — and every guest who scans from that moment sees accurate information.

The FSA estimates that approximately 1 in 100 catering menus contains an undeclared allergen risk at any given time. For a restaurant updating its menu quarterly through a print cycle, that risk window is three months wide. For a restaurant with a live digital menu, the risk window is the time between a recipe change and a dashboard update — which should be measured in minutes, not months.

How to implement allergen information on your PixPlat digital menu:

Option 1 — Allergen badge icons per item. PixPlat supports visual allergen badges at the item level — small icons (V for vegan, GF for gluten-free, common allergen symbols) visible in the item card without opening the full item description. This is the fastest browsing experience for guests who know what they're looking for.

Option 2 — Allergen text in item descriptions. List the allergens directly in the description: "Contains: gluten, eggs, milk." This is the most explicitly compliant format — unambiguous, readable, and searchable.

Option 3 — Full allergen section per item. For restaurants serving guests with serious allergies, a dedicated allergen field per item displays the full list of the 14 allergens present, in a standardised format. This is the most thorough option and the one closest to EU Regulation 1169/2011's spirit of proactive, accessible information.

For UK restaurants following FSA March 2025 best practice guidance, Option 2 or 3 is strongly recommended. For EU restaurants, written allergen information on the menu (Options 2 or 3) is the standard to meet.

What staff need to know — and how allergen information on the menu helps them

Written allergen information on a digital menu reduces the burden on staff, but it does not eliminate it. Owen's Law requires verbal communication to customers with allergies in England — the digital menu supports this but does not replace the human conversation.

Staff should be trained to:

1. Know which of the 14 allergens are present in every dish they serve

2. Know which dishes can be modified and which cannot (e.g., a dish where the allergen is fundamental to the preparation, not an add-on)

3. Know the cross-contamination risks in the kitchen — a dish that doesn't contain nuts but is prepared on the same surface as a nut-containing dish

4. Direct guests to the allergen information on the menu as the first reference point, then engage in the conversation from there

The digital menu handles step 4 automatically — the guest sees the information before they speak to a server. This does not mean staff can be uninformed. It means the first level of information delivery is handled by the menu, and staff conversations are about specific follow-up questions rather than providing the entire allergen profile from memory under service pressure.

Keeping allergen information current: the maintenance checklist

A compliant allergen display is only as useful as it is accurate. This operational checklist should be part of your regular menu management routine:

The FSA requires that allergen information is accurate, available, and easily accessible to the consumer at all times. There is no seasonal dispensation for inaccurate information. A menu that was allergen-accurate in January but was not updated after a recipe change in March is a compliance failure in March, even if the original menu was impeccable.

→ For how to update your menu in real time when ingredient changes happen, see Restaurant menu management: updating your menu in real time

→ For the complete digital menu guide, see The complete guide to digital menus for restaurants

Frequently asked questions

Are UK restaurants legally required to list allergens on their menus?
UK restaurants must provide allergen information for all 14 major allergens present in any food they serve, under the Food Information Regulations 2014. The information must be available before the customer orders. While the regulations don't mandate a specific format, the FSA's March 2025 best practice guidance strongly recommends written allergen information on menus or easily accessible documents, rather than relying solely on verbal communication. Environmental health officers increasingly use this guidance as their inspection benchmark, making written information the practical standard for compliance.

What is the difference between Natasha's Law and Owen's Law?
Natasha's Law (October 2021) covers prepacked for direct sale (PPDS) foods — items packaged on-site before a customer requests them, like pre-wrapped sandwiches or cakes. It requires a full ingredients list with allergens clearly emphasised. Owen's Law (2024) applies to restaurant service and requires food businesses to actively communicate allergen information verbally to customers with allergies — it is about the staff conversation, not just the label. Both apply to UK restaurants simultaneously, alongside the general allergen information requirements under assimilated EU Regulation 1169/2011.

Do US restaurants have to list allergens on their menus?
As of 2025, there is no federal US law requiring restaurants to list allergens on their menus. FDA allergen labelling requirements apply to packaged foods only. However, several states are actively pursuing restaurant allergen legislation — California's SB 68 was advancing through the legislature in April 2025. Some cities (New York City, for example) have local rules requiring restaurants to disclose allergens upon request and prohibiting misrepresentation. US restaurants with international guests or health-conscious audiences should consider proactive allergen labelling as a risk management practice even without a legal obligation.

How does a digital menu make allergen compliance easier to maintain?
A printed menu's allergen information is accurate at the time of printing and potentially inaccurate for the rest of its life. Every recipe change, ingredient substitution, or supplier change that affects allergen content requires a reprint to keep a printed menu compliant. A digital menu allows allergen information to be updated immediately whenever a recipe changes — the update is live on every guest's phone within seconds. This eliminates the compliance gap between operational reality and what guests see on the menu. The FSA estimates 1 in 100 catering menus contains an undeclared allergen risk; most of those risks arise from the lag between a change in the kitchen and a change in the menu document.