2024 marks 10 years since the introduction of the Allergen Laws. The changes in 2014 were introduced to reduce the risk of Allergy related incidents. Food Business Owners were required to review the recipes and must highlight any ingredients which fall under the named #top14allergens.

EU law defined the list as follows:

Celery, Cereals containing gluten, Crustaceans, eggs, fish, lupin, milk, mustard, molluscs, peanuts, sesame seeds, soya, sulphites, tree nuts.

This list was originally created as across the EU the allergens listed caused 90% of all reactions. Although we are no longer a member of the EU the Allergens Law legislation has been incorporated into UK Food Law. Food Businesses must inform the customer if the food product contains any of the #Top14 allergens.

It has become apparent that many people suffer with reactions from ingredients outside the #Top14 list. In fact, there are over 250 proteins in food which can cause an allergic reaction to a person. The reactions as with any allergen can vary from mild to severe and just because that ingredient does not appear on the #Top14 list does necessarily follow that the symptoms are less severe for that individual.

The law states that any allergen from the #Top14 must be highlighted, and the customer should be informed of the presence of any of these allergens. This can be on the menu, via a QR code or an App or simply by sharing the Allergen Matrix with the customer. The information must be accurate and should be checked regularly.

How do we inform customers of any food items outside the #Top14 mandatory list?

It is not possible to list all ingredients on an Allergen Matrix or highlight them on a menu-this is impractical. However, the Chef must know exactly which ingredients have been used in all dishes on the menu. If a standard recipe specification system is in place, this is straightforward. If the chefs have some leeway in preparing meals and can add their own recipes, this becomes a problem when managing the ingredients and allergens. Each chef should keep a written record of the ingredients in each recipe- a Chefs Allergen card can be used for this purpose.

A customer may ask for more information on the recipe as they might react to ingredients such as onions, mushrooms, tomatoes, or fruits such as apples, pears, or strawberries. It is important that such enquiries can be answered accurately because for that customer it may be a big problem.

Sometimes this type of question is not taken seriously as the chef can disregard it “It’s only onions, it can’t be much of a problem-it’s not one of the #Top14.” The chef is not able to judge and should take the query at face value and provide accurate information.

In many schools, the staff must manage a wide range of dietary requests (following medical confirmation of the allergens/reactions). School chefs are often asked to ensure that meals are free from strawberries, kiwi fruit, onions, pulses such as pea protein, lentils, and beans. There are a growing number of such requests. Some schools may decide that they are unable to manage such a wide variety of meals, and others take it in their stride and provide meals adapted for different diets. This depends on the policy of the caterer and in a school, this can be a difficult decision. In a restaurant setting, the chef must make an informed decision based on his knowledge and understanding of managing allergens and whether a recipe can be adapted safely to ensure certain ingredients are not used.

How far will this go?

It is evident that currently there is a problem with an increase in reactions to pea protein- this is often used as an ingredient in Vegan and Vegetarian foods and sometimes as a crispy coating for items such as chips. Questions have been raised as to whether the #Top14 list will change or not. At this stage, the FSA has not indicated any change to the list. Each Food Business Operator will need to decide how they can manage a wide range of dietary requests and whether the business is able to adapt safely or not.

If you had an allergy to an ingredient outside the #Top14, how would you manage?

Jacqui McPeake – Chief Allergen Advisor, Allergen Accreditation