Allergen information belongs in the same system that takes the order, because a printed allergen matrix goes out of date the moment a supplier changes. The Food Standards Agency’s best practice guidance, published in March 2025, expects written allergen information to be readily available for non-prepacked food and supported by a conversation with the customer. A sign saying “ask staff” still meets the legal minimum, but it is no longer what the regulator considers good practice.
For most operators the compliance question is not really about the fourteen allergens. It is about version control.
The FSA’s best practice guidance on allergen information for non-prepacked foods sets out that allergen information should be provided in the way consumers prefer, which is in writing and supported by a conversation. It applies in England, Wales and Northern Ireland, and the FSA has been clear that it is aimed at businesses of every size, from large chains to single-site independents.
Three points matter operationally:
The guidance is voluntary rather than a change to labelling law. The FSA has said it will review the guidance by September 2026, so the direction of travel is worth watching.
Because information about a dish lives in at least four places and they drift apart.
There is the recipe the chef cooks. There is the printed menu. There is the allergen folder behind the bar. There is whatever a member of staff remembers when a customer asks at 8pm on a Saturday. Change one ingredient, because a supplier substituted a product or a special came off, and you have to update all four. In practice one or two get missed.
The risk is not theoretical. The FSA’s move towards written information followed sustained campaigning by families affected by fatal allergic reactions in restaurants, including cases where a customer was given inaccurate verbal information about a dish.
It reduces the number of places the truth lives.
When allergen flags sit against the product record in your till system rather than in a separate document, the information travels with the item. Add a dish, and it carries its allergen data through to every place the dish appears.
At the point of order. Staff taking an order can see the allergen flags on the screen in front of them rather than fetching a folder. That supports the conversation the FSA guidance asks for, rather than replacing it.
On the kitchen ticket. An allergen note attached to an order line travels to the kitchen with the order. A verbal “table nine has a nut allergy” shouted across a pass does not survive a busy service.
On self-service and online ordering. Where the customer is ordering without a member of staff present, the written information is the only information. A self-service kiosk or QR ordering journey can prompt for allergen requirements before the basket is built rather than after payment.
Across sites. Update the product record centrally and every venue picks it up. For a group, this is the difference between one update and eight.
Distance selling is where the requirements are firmest and the process is loosest. The customer never speaks to anybody, so there is no conversation to underpin the written information.
If you take phone orders, the written information still has to be available to the customer before they order, which usually means your own website carrying an accurate, current allergen listing. If you sell through third-party delivery platforms, the listing on the platform is another copy of the same information that can drift out of date. Every additional channel is another place to update.
Our EPOS for fast food and takeaways page covers how order channels feed back into a single product database, which is the only realistic way to keep several menus in step.
Yes. The guidance covers any business supplying non-prepacked food, including food given away free of charge. A members club putting on a buffet is inside the scope.
It also catches the things that are easy to forget: specials boards, seasonal menus, function catering and the bar snacks nobody thinks of as a menu. Specials are the highest-risk category precisely because they change most often and are least likely to be documented. If a special is set up as a product on the till, it can carry allergen data. If it is rung through on a miscellaneous key, it cannot.
See our bars and restaurants and sports and members clubs pages for how this works in a licensed venue.
If your allergen matrix is a laminated sheet that was accurate the day it was printed, the process is the risk, not the paperwork.
Speak to CCR Systems about allergen data in your EPOS setup. We supply and support ICRTouch systems across pubs, restaurants, takeaways and clubs in the North West, and we can walk through how your product database would need to be structured.
