Natasha's Law โ formally the Food Information (Amendment) (England) Regulations 2021, with equivalent provisions in Scotland โ came into force on 1 October 2021. More than three years on, allergen documentation gaps remain one of the most common issues uncovered during restaurant compliance audits. This article explains what's required, where restaurants most commonly fall short, and what genuine compliance looks like in practice.
Allergen-related incidents can be fatal. Natasha Ednan-Laperouse, for whom this legislation was named, died in 2016 after consuming a sandwich that contained undisclosed sesame. Non-compliance is not a technicality โ it is a genuine life-safety issue and a criminal offence under food safety law.
UK food law requires that information about the following 14 allergens must be provided whenever they are present in food served to customers:
The legislation's primary focus is on pre-packed for direct sale (PPDS) foods โ food that is packed on the premises where it is sold, before a customer orders it. This includes sandwiches made fresh in the morning and displayed for sale, salads prepared and wrapped in advance, cakes and pastries packaged on site, and similar products.
For PPDS foods, full ingredient labelling including allergen highlighting is now required on the packaging of each individual item.
Non-prepacked food โ i.e., dishes made to order in a restaurant โ is covered by existing allergen information regulations (EU 1169/2011 retained in UK law). Allergen information must still be provided, but can be communicated verbally, on menus, via a written statement, or through other means. The key requirement is that accurate, consistent information is available and accessible to every customer who asks.
Having audited restaurants across Scotland since Natasha's Law came into force, these are the gaps I find most consistently:
| Common Gap | Risk Level | How Often Found |
|---|---|---|
| Allergen matrix exists but hasn't been updated when the menu changed | High | Very common |
| Staff cannot accurately describe the allergen procedure when asked | High | Very common |
| PPDS items not labelled with full ingredients and allergen highlighting | High | Common |
| No cross-contamination control procedure documented | Medium | Very common |
| Allergen info held only by head chef โ unavailable when they're absent | Medium | Common |
| Supplier ingredient declarations not checked when supplier changes product | Medium | Common |
| Training records not held for all staff, including seasonal/agency workers | Medium | Very common |
A restaurant that is genuinely allergen-compliant โ not just technically compliant on paper โ will have all of the following in place:
A complete matrix (table) showing which of the 14 allergens are present in every dish on your menu. This must be updated every time the menu changes, a supplier changes a product's formulation, or a new ingredient is introduced. The person responsible for maintaining it must be identified.
Every pre-packed for direct sale item must carry a label with the full ingredient list, with allergens highlighted (typically in bold). This applies even if the item is only sold occasionally or seasonally.
This is separate from allergen information โ it covers how you prevent allergens from transferring from one dish to another through shared equipment, surfaces, oil or staff handling. A customer with a severe nut allergy needs to know not just that your pesto pasta contains pine nuts, but that there is a procedure to prevent nut traces entering their allergen-free dish.
Every member of staff who handles food or takes customer orders must be trained in allergen awareness. Training records must be signed and dated, and must be held for agency and seasonal workers as well as permanent staff.
There must be a documented process for how allergen requests from customers are handled โ from the front of house team taking the order through to the kitchen producing it. This should include who to escalate to for complex requests, and what to say when cross-contamination cannot be guaranteed.
Non-compliance with allergen labelling and information requirements can result in:
The practical challenge for most restaurants is not understanding the requirements โ it's building systems that make compliance routine for a busy kitchen team. The allergen matrix that's 100% accurate in January needs to still be 100% accurate in July after three menu changes, two new suppliers and a change of head chef.
ALPS Consultancy works with restaurants to build allergen management systems that are practical, documented, and maintainable โ not just compliant on the day of the audit. We also provide staff training and carry out regular allergen compliance reviews.
Book a free restaurant compliance assessment with ALPS Consultancy. We'll review your allergen management system and identify any gaps โ before an EHO or Trading Standards officer does.
Book an Exploratory Discussion โ