Allergen records for small food producers: the 14 allergens and how to keep them straight
Most allergen problems in small food businesses are not about ignorance. They're about a recipe that changed, a substitute ingredient on a busy morning, or a label printed from last year's file.
13 October 2026, 7 min read
The 14 allergens
EU and UK law requires food businesses to declare the presence of these 14 allergens in any food they sell, whether prepacked or sold loose:
- Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut)
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk
- Nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamias)
- Celery
- Mustard
- Sesame
- Sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre
- Lupin
- Molluscs
For prepacked food the allergens must be emphasised in the ingredients list on the label. For food sold loose or made to order, the information must be available to the customer, in writing or verbally with a sign saying to ask.
Where it goes wrong
- Ingredient substitutions. The usual stock is gone, a different brand goes in, and that brand contains soya or sulphites the original didn't. Nobody updates the recipe.
- Recipe drift. The scone recipe gained an egg wash two years ago; the allergen card didn't.
- Hidden allergens. Worcestershire sauce has fish. Many stocks have celery. Dried fruit often has sulphites. Baking powder can contain wheat starch.
- Cross contact. Not a declaration issue as such, but a nut line sharing a table with a nut free line needs a procedure and often a "may contain" statement.
- Old files. Labels printed from a saved document that nobody has checked since.
A system that stays correct
The fix is to keep allergen information in one place, written down against each product, and to read it from there every time rather than remembering it.
- Record allergens on each ingredient as it arrives. If a delivery is a different brand, check its label. This is the moment substitutions get caught.
- Keep an allergen list for each product. Review it whenever a recipe or an ingredient changes.
- Produce labels and customer information from the recipe record, not from memory or an old file.
- Keep the link between the batch and the deliveries it used. If a question comes up later ("was there sesame in last Tuesday's batch?"), you can look at exactly which ingredients went in and read their labels.
- Check the whole list twice a year. Put it in the diary.
When a customer asks
Have the answer written down, and have it be the same answer every member of staff gives. A printed allergen matrix on the counter, generated from your recipes, is the simplest approach for a shop or market stall. For wholesale customers, send the matrix with each new product and whenever a recipe changes, and keep a copy of what you sent.
Questions on this topic
Do I have to list allergens if I only sell at a market?
Yes. Allergen information must be available for all food sold, including loose food at a market. You can give it in writing (a sign or card) or verbally, as long as there's a clear sign telling customers to ask.
What's the difference between 'contains' and 'may contain'?
'Contains' means the allergen is an ingredient and must be declared. 'May contain' is a voluntary warning about possible cross contact during production. Use it only after a genuine risk assessment, not as a blanket cover.
Are oats gluten free?
Not by default. Oats are listed under cereals containing gluten because they're usually contaminated with wheat during growing and milling. Only oats sold as certified gluten free can be treated as such.
Do I need to declare sulphites in dried fruit?
If the finished product contains sulphur dioxide or sulphites above 10 mg per kg or litre, yes. Dried fruit, some wines and some vinegars commonly push a product over that threshold, so check the ingredient's label.
Does SmartTrace record allergens?
Not at the moment. What it does record is exactly which deliveries went into every batch, so if a question comes up about a past batch you can see which ingredients and which supplier lots were used, and check their labels. Keep your allergen lists alongside.
More from the blog
Your supplier has just recalled a lot. Here's what to do in the next hour.
A step by step guide for small food producers when a supplier recalls an ingredient lot: find it, find what you made with it, find who got it, and tell the right people.
Preparing for an EHO inspection: what the traceability questions will be
What an Environmental Health Officer looks for in a small food producer's traceability records, the questions they actually ask, and how to have the answers ready.
Keep the records that answer these questions.
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