Allergen Management for Small Food Producers: A Practical Guide to Natasha's Law

Why allergen management can't be an afterthought

Natasha Ednan-Laperouse died in 2016 after eating a baguette from Pret A Manger that contained sesame - an allergen that wasn't declared on the label. She was 15 years old.

Her death led to Natasha's Law, which came into force in October 2021 and fundamentally changed how food businesses must handle allergen information. But beyond the legal requirements, allergen management is about protecting people's lives. An estimated 2 million people in the UK live with a diagnosed food allergy, and allergic reactions kill around 10 people in the UK each year.

For small food producers, getting allergen management right isn't just a compliance box to tick. It's one of the most important things you do.

The 14 UK declarable allergens

UK law requires you to declare the presence of these 14 allergens in your food products:

1. Celery - including celeriac
2. Cereals containing gluten - wheat, rye, barley, oats, spelt, kamut
3. Crustaceans - prawns, crab, lobster, crayfish
4. Eggs
5. Fish
6. Lupin
7. Milk - including lactose
8. Molluscs - mussels, oysters, squid, snails
9. Mustard
10. Tree nuts - almonds, hazelnuts, walnuts, cashews, pecans, brazils, pistachios, macadamias
11. Peanuts
12. Sesame
13. Soybeans
14. Sulphur dioxide and sulphites - at concentrations above 10mg/kg or 10mg/litre

These 14 allergens must be declared regardless of the quantity present. There's no minimum threshold - if it's in the product, it must be declared.

What Natasha's Law requires

Before Natasha's Law, food that was prepacked for direct sale (PPDS) didn't need a full ingredient list. A bakery wrapping sandwiches for its own display counter could sell them with no ingredients or allergen information on the label at all.

Natasha's Law changed this. Since October 2021:

Prepacked for direct sale (PPDS) food must carry:

• A full ingredient list
• All 14 allergens emphasised within that list (bold, italic, underlined, or capitalised)
• The name of the food
• The name and address of the business

PPDS includes:

• Sandwiches, wraps, and salads made and packed on the same premises where they're sold
• Baked goods wrapped for a display counter
• Meals packed in containers for customer selection
• Any food that is packaged before the customer chooses or orders it, at the same premises where it's sold

PPDS does not include:

• Food packed at a different premises (this is "prepacked" and was already covered by existing labelling rules)
• Food sold loose or unpackaged (allergen info must still be available, but a full ingredient list isn't required on a label)
• Food packed after the customer orders it

Building your allergen management system

Step 1: Know your ingredients

For every raw material you use, you need allergen information from the supplier. This should come in the form of a product specification or technical data sheet that lists:

• All allergens present in the product
• Any allergens that may be present due to cross-contamination during manufacturing ("may contain" declarations)
• The full ingredient list

Don't assume. A seasoning blend might contain milk powder. A bread flour might contain soy. A margarine might contain fish oil. Check every single ingredient, every time you change supplier, and every time a supplier changes their formulation.

Keep these specifications on file. Your SALSA auditor will ask to see them.

Step 2: Create allergen matrices

An allergen matrix is a grid that shows which allergens are present in which products. It's one of the most useful documents in your food safety system.

Create a table with:

• Your products listed down the left side
• The 14 allergens listed across the top
• Each cell marked to show whether the allergen is present (contained as an ingredient), may be present (risk of cross-contamination), or absent

This gives you and your team a single reference document for allergen information across your entire product range. It also makes it immediately obvious where cross-contamination risks exist - if Product A contains peanuts and Product B doesn't, but they're made on the same equipment, you have a cross-contamination risk to manage.

FoodSafe's allergen management feature tracks all 14 UK allergens across every product and recipe, generating allergen matrices automatically as you add products and ingredients.

Step 3: Control cross-contamination

Allergen cross-contamination is the biggest practical challenge for small producers. You're often working in a single kitchen with shared equipment, making products that contain different allergens.

Controls to implement:

1. Production scheduling - make allergen-free products first, before introducing allergens into the kitchen. Schedule nut-containing products at the end of the day.
2. Dedicated equipment - where possible, use separate utensils, chopping boards, and containers for allergen-containing ingredients. Colour-coding helps.
3. Cleaning between products - when switching between products with different allergen profiles, clean all surfaces and equipment thoroughly. Document the cleaning.
4. Storage separation - store allergen-containing ingredients separately from allergen-free ingredients. Use sealed containers. Store allergens on lower shelves so they can't contaminate items below.
5. Staff awareness - everyone handling food must understand the allergen controls and why they matter. This isn't optional knowledge.
6. Supplier controls - verify that your suppliers have their own allergen management procedures. Check "may contain" declarations on incoming ingredients.

Step 4: Label correctly

For prepacked products (including PPDS), your labels must include:

• A full ingredient list in descending order of weight
• All 14 declarable allergens emphasised wherever they appear in the ingredient list
• The emphasis must be clearly different from the rest of the text - bold is the most common approach

For example: "Ingredients: Wheat flour (wheat), sugar, butter (milk), eggs, vanilla extract, baking powder (raising agent: sodium bicarbonate)"

Common labelling mistakes to avoid:

• Listing allergens separately instead of within the ingredient list (this doesn't meet the legal requirement for prepacked food)
• Forgetting to emphasise allergens that appear as part of compound ingredients
• Using a font size or emphasis that isn't clearly distinguishable
• Not updating labels when recipes change

Step 5: Train your team

Every food handler must receive allergen awareness training. This should cover:

1. What the 14 declarable allergens are
2. Why allergen management matters (the health consequences of getting it wrong)
3. Your specific cross-contamination controls and why each one is important
4. How to respond if a customer asks about allergens
5. What to do if a suspected allergic reaction occurs
6. How to read and interpret ingredient labels and supplier specifications

Training should be documented and refreshed regularly. The SALSA auditor may quiz your staff on allergen awareness during the audit.

"May contain" statements

"May contain" (or "not suitable for" or "made in a factory that handles") statements are used when there's a genuine risk of allergen cross-contamination that can't be eliminated through your controls.

Important points:

• "May contain" is voluntary - there's no legal requirement to use it
• It should only be used after a proper risk assessment, not as a blanket disclaimer
• Using "may contain" for every allergen on every product makes it meaningless and is considered bad practice
• It doesn't replace the need for proper cross-contamination controls
• SALSA auditors will question excessive or unjustified "may contain" declarations

The right approach: implement controls to minimise cross-contamination, conduct a genuine risk assessment for each product, and only apply "may contain" where a real residual risk remains despite your controls.

What SALSA auditors check

During your SALSA audit, the allergen section will cover:

1. Supplier specifications - do you have allergen information for every raw material?
2. Allergen matrix - is it complete, accurate, and up to date?
3. Cross-contamination controls - what procedures are in place and are they being followed?
4. Labelling - are labels accurate, compliant, and reviewed when recipes change?
5. Staff knowledge - can your team demonstrate allergen awareness?
6. Complaint handling - do you have a procedure for allergen-related complaints?
7. Traceability - can you trace allergen-containing ingredients through your production process?

The auditor is looking for a system - not perfection, but a documented, implemented, and maintained approach to managing allergens across your operation.

Common allergen management mistakes

1. Relying on memory instead of documentation. You might know your recipe contains milk, but if it's not documented and your staff member doesn't know, you have a gap.
2. Not checking supplier specifications regularly. Suppliers change formulations. A product that was allergen-free last year might not be this year.
3. Inconsistent cross-contamination controls. Having procedures but not following them consistently is worse than having no procedures - it creates a false sense of security.
4. Not updating labels when recipes change. Every recipe change should trigger a label review.
5. Using "may contain" as a shortcut. It's not a substitute for proper risk assessment and control measures.

Getting it right

Allergen management isn't complicated, but it does require discipline. The core routine is:

1. Know what's in every ingredient (check supplier specs)
2. Know what's in every product (maintain your allergen matrix)
3. Control cross-contamination (implement and follow your procedures)
4. Declare accurately (label correctly)
5. Train your team (and keep training them)

Get these five things right, consistently, and you'll protect your customers, satisfy your auditor, and sleep better knowing you've done everything you can.

Food safety compliance, handled.