Summary of FSA Best Practice Guidance 2025 for Non-Prepacked Food

Date

Mar 31, 2025

Author

Alex

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The Food Standards Agency’s Best Practice Guidance on Allergen Information for Non-Prepacked Foods (March 2025) runs to dozens of pages. Below is taster of the essential information – substantial enough to act on, yet short enough to read between lunch and dinner service. Whenever you want to dive deeper, follow the links to the dedicated articles in this series.

Best practice is written information backed by conversation

The FSA now treats written and spoken information as two sides of the same coin. A printed menu, spreadsheet matrix or digital guide should be “easily available in writing and underpinned with a conversation”. A lone sign that says “ask staff” still keeps you inside the law (for now), but it is no longer deemed best practice. Staff are encouraged to open a dialogue about allergens early, answer confidently, and confirm again when the dish is served.

The 14 allergens

Nothing has changed in the list itself – celery through sulphites remain the regulated allergens – but the guidance reminds us that omitting any one of them can lead to fines, closure or court action. Where a group term is used (for example tree nuts or cereals containing gluten), the information should specify exactly which nut or grain, or minimally staff should be able to provide this information when asked.

New to the list? The 14-Allergen List: What Every Business Needs to Know walks you through each item and why it matters.

How to present written allergen information

The guidance boils key design principals down to four words: easy, clear, comprehensive, accurate. A full “Contains: milk, egg, mustard” line is the clearest, but many operators choose icons (which must be at least 0.6 cm square to stay legible) or a numbering system with a legend on the same page. Digital, filter-able menus earn special praise: they easily update in seconds and stay in sync across print, web, and QR codes, so out-of-date versions never linger in circulation.

A walk-through of each option – complete with layout examples and the benefits/drawbacks to each approach – can be found in How to Present Written Allergen Information.

Flow of information

The FSA includes a diagram that traces allergen information from the moment a guest is greeted to the moment the plate reaches the table. The big takeaway: every step depends on the one before it. Staff must ask, record, relay, cook safely, identify the dish clearly, and confirm at service. Miss any single link and the chain breaks.

We break the diagram into real-world actions in Effective Flow of Information: How to Talk about Allergens.

Takeaway and delivery – the “before & after” rule

Selling over the phone, from a website or via an app? Written allergen information has to be visible before the customer pays and again on delivery, typically via a label or slip in the bag. If you rely on a third-party platform, signpost allergen details clearly or supply the data directly. No website? You still have to tell callers where they can see written allergen info and ask about allergies before taking the order.

For guidance on distance selling read Takeaway Menus: Best Practice for Allergen Labels.

Voluntary info, "may contain" and “free from” claims

The FSA urges operators to keep track of all ingredients – not just the legal 14. If a diner asks, you should be able to check the recipe (or supplier spec) and give a clear answer in the same way you would for milk or peanuts.

Then there’s precautionary allergen labelling (PAL), commonly known as a “may contain” warning. Use this only when a written risk assessment shows cross-contact can’t be ruled out. Blanket PAL across half the menu isn’t best practice; it just shifts the risk back to the diner without offering real insight.

“Free-from” claims are stricter still. “Gluten-free” means <20 ppm gluten; whereas “peanut-free” or “dairy-free” is an absolute guarantee of zero. That means dedicated utensils, segregated storage, documented cleaning routines, and – if you outsource anything – supplier certificates to match. The guidance urges operators to think carefully before making such claims, because the legal expectation is total absence, not “low risk”.

Keep it live and traceable

Allergen data is only useful if it’s current. The FSA advises recipe logs, supplier-spec files, and regular audits – especially after menu changes or ingredient swaps. Digital menus with a single source of truth can replace the nightmare of chasing down every printed copy. (Stay tuned for a deep dive on audit trails)

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