Fourteen allergens and one question from table nine

Saturday, half past eight. Table nine asks whether the Caesar salad has anything with nuts in it. The waiter does not know, so he goes to the pass. The pass does not know either, because the dressing was made on Thursday by somebody who is off today.

Someone says "I don't think so", and the plate goes out. Most of the time nothing happens. The rule exists for the time something does.

This is what the EU rule on allergens actually asks of a restaurant, read from the regulation itself, and what it takes to answer table nine in ten seconds instead of a shrug.

The rule, in one paragraph

The rule is Regulation (EU) No 1169/2011 on food information to consumers, and it has applied since 13 December 2014. It does not stop at supermarket packaging. It names "mass caterers" directly: any establishment where food is prepared ready to eat, from restaurants and canteens to schools, hospitals and food trucks.

For food that is not prepacked, which is everything that leaves your pass, Article 44 makes one piece of information compulsory whatever else you leave out: the allergens. Each member state may decide how you give that information. Whether you give it is not up for discussion.

The fourteen

Annex II of the regulation lists fourteen substances and products. Each one counts as an ingredient to declare, and so does anything made from it:

• Cereals containing gluten: wheat, rye, barley, oats, spelt, kamut
• Crustaceans
• Eggs
• Fish
• Peanuts
• Soybeans
• Milk, including lactose
• Tree nuts: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamias
• Celery
• Mustard
• Sesame seeds
• Sulphur dioxide and sulphites above 10 mg per kg or per litre
• Lupin
• Molluscs

A few entries carry narrow exceptions, such as fully refined soybean oil or wheat-based glucose syrups. They matter to a food manufacturer far more than to a kitchen. If you are ever in doubt, declare it.

Where kitchens actually get caught

Nobody forgets that a prawn is a crustacean. The trouble is what the regulation says in Article 9: the allergen has to be declared if it is still in the finished dish, "even if in an altered form". In practice that means the allergen hiding inside something else.

Take Acacia's Caesar salad, the example restaurant I use for worked cases. It looks like lettuce and cheese. Here is what it carries:

Three of the five sit in the dressing, which was made on Thursday by somebody who is off today. That is the whole problem in one bowl. The allergen is not on the plate where anybody can see it. It is one or two recipes down.

The second place kitchens get caught is the supplier. The bread you bought last month and the bread you bought this week may not have the same label. A brand change, a new recipe at the bakery, a substitute because the usual one was out of stock: each of those can change what is in your dish without anyone in your kitchen changing anything.

Saying it out loud is allowed. Waiting to be asked is not.

The European Commission published guidance on exactly this in 2017 (Commission Notice C(2017) 4864). Two of its points matter for every dining room.

First, in principle any means of communication is acceptable, including information given orally, as long as it can be verified. Second, the information cannot be available only when the guest asks for it. And where a country has no national rules on how to do it, the guidance says the general labelling rules apply instead: written, easy to see and clearly legible.

So the first thing to check is what your own country has decided. The regulation leaves that choice to each member state, the answers differ, and I will not pretend one answer fits everywhere. Check before you print the next menu.

Whatever your country decided, my rule for the dining room is the same: when the waiter says "no nuts", that answer comes from something written down, not from memory. Oral information only counts if it can be verified, and memory cannot.

An allergen record that survives a busy Saturday

• One recipe card per dish, including the sub-recipes. The dressing, the stock, the crumb and the marinade each get their own card with their own allergens, and the dish inherits them. It is the same card you need to cost the plate, so it is one job, not two.
• The supplier's label goes in the file. When a product or brand changes, the card changes the same day, before the first plate goes out.
• One allergen matrix for the whole menu. Dishes down the side, the fourteen across the top, a tick where it applies, a date and a name of who checked it.
• The matrix lives where the floor can reach it. Not in the office. The waiter at table nine should be able to answer without walking to the pass.
• A new starter learns it on day one. Where the matrix is, what to say, and what to do when the answer is not on it: ask, and never guess.

One honest limit. Everything above is about declaring what is in a dish. Keeping an allergen out of a dish, with separate boards, clean oil and a clean pan, is a different job and belongs to your food safety procedures. Both HACCP Code and The AI Ecosystem include a printable allergen matrix to start from.