Allergen rules for pizzerias and takeaways

Updated 14 September 202610 min readRomain Ferrand — pizzaiolo, 12 years in trucks and dining rooms

A pizzeria must be able to tell a customer which of the 14 regulated allergens is in any dish, before they order. For food sold over the counter you may do that verbally, as long as a visible sign says how to ask. For orders taken online or by phone you may not: the information has to be written, available before the order is placed, and again when the food is delivered.

The 14 allergens

The list is unchanged from Regulation (EU) No 1169/2011, which the UK retained after leaving the EU. It applies in England, Scotland, Wales and Northern Ireland.

AllergenAllergen
1Cereals containing gluten8Nuts
2Crustaceans9Celery
3Eggs10Mustard
4Fish11Sesame
5Peanuts12Sulphur dioxide and sulphites
6Soybeans13Lupin
7Milk14Molluscs

Retained Regulation (EU) No 1169/2011, Annex II.

Peanuts and nuts are two separate entries, and so are cereals and lupin. A pizzeria will usually declare gluten and milk on almost everything, fish on the tuna and anchovy pizzas, sulphites wherever there is wine or certain olives, and celery far more often than people expect — it hides in stock and in some ready-made sauces.

Counter sales: verbal is allowed, with a sign

Food you make to order and hand over unpackaged — which is nearly everything a pizzeria sells — counts as non-prepacked. You must supply allergen information for every item, but you may do it verbally, provided a notice in a clearly visible position tells customers how to ask.

The Food Standards Agency's own position is that written information supported by a conversation works best. In practice, verbal-only is also the arrangement that fails first: it depends on whoever happens to be on the counter at 9pm on a Friday knowing what is in the nduja.

Online and phone orders: written, twice

That second half catches people out. Information on your website covers the "before ordering" requirement; the delivery itself still has to carry something the customer can check against the food in front of them. A printed order slip listing the allergens per item is the usual answer.

What about Natasha's Law?

Natasha's Law — the PPDS rules in force since 1 October 2021 — requires a full ingredients list with allergens emphasised on food that is prepacked for direct sale: packaged on the premises before the customer selects it.

For most pizzerias it barely applies. A pizza made to order and boxed at the customer's request is explicitly not PPDS, and neither is anything packaged after the customer has chosen it. Where it does apply is the chiller cabinet: pre-boxed slices, a tub of dressed salad made this morning, a wrapped cannolo sitting by the till. Those need the full label.

A workable system

  1. Write the matrix once. Every dish down one side, the 14 allergens across the top. The FSA publishes a template.
  2. Record it per ingredient, not per pizza. When you change supplier for your dough flour or your gorgonzola, you want one line to update rather than eleven pizzas to re-check.
  3. Re-check on every supplier change. Recipes change without announcement. The label on the tin is the source of truth, not last year's matrix.
  4. Publish it where the order is taken. On the menu page, next to the dish — which also satisfies the distance-selling requirement without anyone remembering to do anything.
  5. Never write "may contain" as a substitute. Precautionary labelling is for genuine cross-contamination risk you have assessed and cannot remove. Used to cover everything, it tells a customer nothing and they will order elsewhere.

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Who enforces it, and what happens

Environmental health officers from your local authority, usually during a routine food hygiene inspection. Allergen management forms part of the food safety management assessment that feeds your hygiene rating, so a missing matrix costs you the sticker in the window as well as the improvement notice.

The pizzeria website guide

Sources