Restaurants

Natasha's Law โ€” Is Your Restaurant Fully Compliant?

๐Ÿ“… January 2025 โœ๏ธ Steuart Fotheringham, ALPS Consultancy โฑ 6 min read

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.

Why This Matters

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.

The 14 Notifiable Allergens

UK food law requires that information about the following 14 allergens must be provided whenever they are present in food served to customers:

๐ŸŒพ Cereals with gluten
๐Ÿฆ Crustaceans
๐Ÿฅš Eggs
๐ŸŸ Fish
๐Ÿฅœ Peanuts
๐Ÿซ˜ Soybeans
๐Ÿฅ› Milk
๐ŸŒฐ Tree nuts
๐ŸŒฟ Celery
๐ŸŸก Mustard
โšซ Sesame
๐Ÿซง Sulphur dioxide
๐Ÿฆช Molluscs
๐Ÿ’œ Lupin

What Does Natasha's Law Actually Require?

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.

What About Non-PPDS Food?

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.

The Most Common Compliance Gaps

Having audited restaurants across Scotland since Natasha's Law came into force, these are the gaps I find most consistently:

Common GapRisk LevelHow 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

What Does a Compliant Allergen System Look Like?

A restaurant that is genuinely allergen-compliant โ€” not just technically compliant on paper โ€” will have all of the following in place:

1. An Accurate, Current Allergen Matrix

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.

2. Labelling for All PPDS Items

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.

3. A Documented Cross-Contamination Control Procedure

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.

4. Staff Training and Records

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.

5. A Clear Customer Communication Process

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.

๐Ÿฝ๏ธ Restaurant Allergen Compliance โ€” Full Checklist

EHO and Trading Standards Enforcement

Non-compliance with allergen labelling and information requirements can result in:

Getting Compliant โ€” and Staying Compliant

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.

SF
Steuart Fotheringham Managing Director, ALPS Consultancy ยท NEBOSH ยท Food Safety Level 4 ยท Environmental Health Specialist

Is Your Allergen Documentation Watertight?

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.

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