Lesson 1: Food allergy, intolerance and coeliac disease
This lesson is for awareness only, not for diagnosing anyone. It explains why every allergy question matters. The health information here follows the advice of Ireland's health service (HSE). It is one country's guidance, so also follow your own national health service's advice.
What is a food allergy?
A food allergy happens when the body's immune system reacts to a food. It wrongly treats a protein in the food as a threat. Symptoms can affect several parts of the body at the same time. Common symptoms include an itchy mouth, throat or ears, a raised itchy rash (hives), a swollen face and vomiting.
With IgE-mediated allergy, symptoms start a few seconds or minutes after eating. With non-IgE-mediated allergy, symptoms take longer, up to several hours. Almost any food can cause an allergic reaction, not only the 14 allergens in EU law.
Anaphylaxis
Anaphylaxis is a severe allergic reaction that can kill. It can develop within minutes or over up to two hours. Food is one possible trigger, along with medicines, latex and insect stings. Warning signs include:
- swelling of the throat and tongue
- difficulty breathing or breathing very fast
- feeling faint or dizzy, or a racing heart
- feeling sick, and sometimes a swollen, raised or itchy rash
Lesson 6 explains what to do. In short: call 112 and say you think it is anaphylaxis.
Food intolerance
A food intolerance is not the same as an allergy. The person has difficulty digesting a substance, and no allergic reaction takes place. Symptoms usually appear several hours after eating. An intolerance can make someone feel very unwell, but it is never life-threatening. Staff cannot tell which one a customer has, so treat every request with the same care.
Coeliac disease
Coeliac disease is not an allergy or an intolerance. It is an autoimmune condition: the immune system reacts to gluten and damages the small intestine. Gluten is found in wheat, barley and rye. There is no cure; the main treatment is a gluten-free diet. This is why EU law lists "cereals containing gluten" as one of the 14 allergens.
The European Food Safety Authority (EFSA) gives scientific advice on allergens. Its 2014 opinion covered food allergies, coeliac disease and reactions to sulphites, but not reactions that do not involve the immune system.
Who is responsible?
- Under Regulation (EC) No 852/2004 on food hygiene, the primary responsibility for food safety rests with the food business operator (the business).
- Under Regulation (EU) No 1169/2011 on food information, the business under whose name a food is sold is responsible for its food information. If that business is outside the EU, the importer is responsible.
- Regulation 1169/2011 has applied since 13 December 2014. It covers labels and any other way of giving information, including by staff speaking to customers.
- Every worker must follow their employer's training, recipes and procedures.
Lesson 2: The 14 allergens and where they hide
Annex II of Regulation (EU) No 1169/2011 lists 14 substances or products that cause allergies or intolerances. EU food businesses must give information about them, including products made from them.
| # | Allergen | Vad den omfattar | Main exceptions |
|---|---|---|---|
| 1 | Cereals containing gluten | Wheat (including spelt and khorasan wheat), rye, barley, oats, their hybrids and products made from them | Wheat- and barley-based glucose syrups, wheat-based maltodextrins, cereals used for alcoholic distillates |
| 2 | Crustaceans | And products made from them | None |
| 3 | Eggs | And products made from them | None |
| 4 | Fish | And products made from them | Fish gelatine as a carrier for vitamin or carotenoid preparations; fish gelatine or isinglass used to clarify beer and wine |
| 5 | Peanuts | And products made from them | None |
| 6 | Soybeans | And products made from them | Fully refined soybean oil and fat; some tocopherols, sterols and stanol esters from soy |
| 7 | Milk | And products made from it, including lactose | Whey used for alcoholic distillates; lactitol |
| 8 | Nuts (tree nuts) | Almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia (Queensland) nuts | Nuts used for alcoholic distillates |
| 9 | Celery | And products made from it | None |
| 10 | Mustard | And products made from it | None |
| 11 | Sesame seeds | And products made from them | None |
| 12 | Sulphur dioxide and sulphites | Above 10 mg/kg or 10 mg/litre (total SO2), in the food as eaten or made up by the maker's instructions | None |
| 13 | Lupin | And products made from it | None |
| 14 | Molluscs | And products made from them | None |
Points people often get wrong
- Name the cereal, not just "gluten". Wheat, rye, barley and oats must be named. Spelt, khorasan and durum are types of wheat.
- Peanuts and tree nuts are separate items on the list. The tree nuts are only the eight named nuts.
- Lactose counts as milk. Lactitol is an exception.
- Sulphites only need to be declared above 10 mg/kg or 10 mg/litre, worked out on the food as it is eaten or made up.
- The exceptions are narrow. Fully refined soybean oil is exempt, but soy flour, soy sauce and soya lecithin are not.
Where allergens hide
Allergens often hide in the small parts of a dish. Every ingredient made from an allergen counts. Ireland's food authority (FSAI), for example, points to these:
- Sauces and condiments. Allergen information must cover these minor parts too.
- Flavourings. A flavouring made from almonds contains a nut allergen.
- Cooking oil. The oil itself counts as an ingredient of food cooked in it.
- Vinegars and drinks. Barley malt vinegar comes from barley. Wine can contain sulphites.
- Dish names. A name does not always show every allergen. Fish cakes, for example, may contain several. The FSAI advises declaring all of them, even the one in the name.
A business must know which allergens it handles and be able to track where they are used. Get a product's allergen information before you use it, and check again whenever a supplier, brand or recipe changes.
Other foods can cause allergies too. If a customer is allergic to something not on the list, check the recipes in the same careful way.
Practical exercise: check the recipe cards for the 14 allergens
You are preparing the allergen records for a café. The recipe cards below include the ingredients listed on each supplier label. Find the allergens in each dish.
| Dish | Recipe card (with supplier label details) |
|---|---|
| A. Chicken Caesar salad | Cos lettuce; grilled chicken; croutons (wheat flour, rapeseed oil, salt); Caesar dressing (rapeseed oil, egg yolk, Parmesan cheese (milk), anchovy, mustard, lemon juice) |
| B. Vegetable soup | Carrot, onion, celery, potato; vegetable stock (salt, celery, onion powder); served with a bread roll (wheat flour, sesame seeds, yeast, water) |
| C. Thai prawn curry | Prawns; coconut milk; curry paste (chilli, garlic, lemongrass, fish sauce (anchovy, salt)); jasmine rice |
| D. Pasta pesto | Durum wheat pasta; pesto (basil, sunflower oil, cashew nuts, hard cheese (milk), garlic); side salad with balsamic dressing (vinegar, grape must, sulphites, olive oil) |
Which of the 14 allergens are in dish A?
Visa svar
Cereals containing gluten (wheat, in the croutons), eggs, milk, fish (anchovy) and mustard. Four are in the dressing alone.
Which allergens are in dish B, and which one is easy to miss?
Visa svar
Celery, cereals containing gluten (wheat) and sesame seeds. Celery is also in the stock, and sesame is easy to miss because it is in the roll.
Which allergens are in dish C?
Visa svar
Crustaceans (prawns) and fish (the fish sauce in the curry paste). Coconut is not one of the 14 allergens.
Which allergens are in dish D?
Visa svar
Cereals containing gluten (durum wheat), nuts (cashews), milk (cheese) and sulphites (in the dressing; declare them when the level is above 10 mg/kg or 10 mg/litre).
The supplier changes the pesto to one made with almonds and pine nuts. What must you do?
Visa svar
Get the new product's allergen information first and update the recipe card and menu. Almonds are a listed tree nut, so dish D still contains nuts.
Lesson 3: Allergen labelling on prepacked food
Prepacked food is food put into its packaging before it is offered for sale, so that the food cannot be changed without opening or changing the pack. Food packed on the sales premises at the customer's request, or prepacked there for direct sale, is treated as non-prepacked (Lesson 4).
Allergens in the ingredients list
Allergens are a mandatory particular on prepacked food (Article 9(1)(c)). This covers any Annex II ingredient or processing aid still in the finished food, even in a changed form, including additives, flavourings and parts of compound ingredients. Article 21 says:
- The allergen must be named in the ingredients list, with a clear reference to its Annex II name.
- It must be emphasised so it stands out from the other ingredients, for example by font, style or background colour.
- Only the allergen word needs emphasis: in "milk powder", emphasise milk.
- Allergens inside a compound ingredient must be emphasised too, for example "chocolate (sugar, cocoa butter, milk powder, soya lecithin)".
- Gluten added as such must name its cereal, for example "gluten (wheat)".
If several ingredients come from one allergen, this must be clear for each. The Commission's guidance allows one linked note such as "From wheat".
Food with no ingredients list
Some foods do not need an ingredients list, for example drinks with more than 1.2% alcohol, such as beer (Article 16(4)). Then the allergen is shown with the word "contains" and the allergen name, for example "contains barley". No statement is needed when the food's name clearly refers to the allergen, such as "cheese" or "cream" for milk. If the food does have an ingredients list, the allergen must still be emphasised in it: "Cheese (milk, salt, rennet)".
The Commission's guidance also says that allergen information cannot be repeated voluntarily outside the ingredients list, for example in an extra "Contains:" box. The emphasised list is the declaration.
Clear and readable
- Food information must be accurate, clear and easy to understand, and must not mislead.
- Mandatory information must use a font with an x-height of at least 1.2 mm. On packs whose largest surface is less than 80 cm², the minimum is 0.9 mm.
- The business under whose name the food is sold is responsible for the label.
"May contain" labels
A precautionary statement such as "may contain nuts" is about unintended presence (cross-contact). It is voluntary. Commission guidance says it should be based on a proper risk assessment and should never replace good allergen control. It is not an allergen declaration: allergens that are ingredients must always be declared.
Practical exercise: check a biscuit label
Here is the ingredients list from a packet of biscuits. Emphasised words are shown in CAPITALS. Check it against the rules in this lesson.
| Part of the label | Text |
|---|---|
| Name | Oat and hazelnut biscuits |
| Ingredients | WHEAT flour, OAT flakes, sugar, butter (MILK), HAZELNUTS (8%), chocolate (sugar, cocoa butter, milk powder, soya lecithin), glucose syrup (wheat), raising agent, salt |
| Box below the list | Allergy advice: contains wheat, oats, milk, hazelnuts |
| Pack size | Largest surface 9 cm by 8 cm |
Which allergens are emphasised correctly?
Visa svar
Wheat, oats, milk (in the butter) and hazelnuts.
What is missing from the emphasis?
Visa svar
In the chocolate, "milk" and "soya" must be emphasised, because allergens inside compound ingredients must stand out too.
Does the glucose syrup (wheat) need emphasis?
Visa svar
No. Wheat-based glucose syrups are an exception in Annex II, so this is not an allergen declaration.
Is the "Allergy advice" box allowed?
Visa svar
No. The Commission's guidance says allergen information should not be repeated voluntarily outside the ingredients list.
What is the minimum x-height for the mandatory text on this pack?
Visa svar
0.9 mm. The largest surface is 9 × 8 = 72 cm², which is less than 80 cm².
Lesson 4: Allergen information for non-prepacked food
Non-prepacked food includes food sold without packaging (a meal in a restaurant, a pastry from the counter), food packed on the premises at the customer's request, and food prepacked on the premises for direct sale. It also covers food supplied to mass caterers. EU law defines a mass caterer as any establishment, including a vehicle or a fixed or mobile stall, such as restaurants, canteens, schools, hospitals and catering businesses.
The EU rule
- For non-prepacked food, allergen information is mandatory in every EU country (Article 44). It is the only food information that EU law requires for this food; other details are needed only where national rules require them.
- Mandatory food information must be available and easily accessible.
- Each Member State may adopt national measures on how the allergen information is made available and how it is presented.
The Commission's guidance says that under national rules any means can be used in principle, including verbal information. Without national measures, information cannot be given only when a customer asks.
National rules: an example
Rules differ between countries, so check your own national food authority. In Ireland, for example, the national rules (S.I. No. 489 of 2014, updated by S.I. No. 656 of 2024) say:
- Allergen information must be in writing, easy to find and available before the food is sold.
- It must relate to each item, for example "Spaghetti bolognaise: contains milk, celery, wheat".
- It can be beside each item or in one or more clearly visible central places, on paper or on a screen.
- It must be updated each time a dish, such as a special, changes.
- Allergens in a made-to-order drink that is not on the menu must be told to the customer before the sale.
- For deliveries, information is given before ordering and again when the food is delivered.
- Staff can also explain allergens verbally, for example to people with a vision impairment.
Keeping the information right
Keep a recipe card for each dish, including the allergens in every bought-in product, and update it and the menu whenever a recipe, product or supplier changes. A "may contain" or "made in a kitchen that uses nuts" notice is not a declaration and does not replace it.
Practical exercise: check a café's allergen menu
Compare the allergen information on this café's menu board with its recipe records. Today's soup is a special that changed this morning.
| Dish | Menu board says | Recipe records say |
|---|---|---|
| Toasted cheese sandwich | Contains: wheat, milk | Bread (wheat, sesame seeds), cheese (milk), butter (milk) |
| Soup of the day: tomato | Contains: celery | Today's soup is lentil and coconut: lentils, coconut milk, onion, vegetable stock (celery), cumin |
| Fruit salad | No allergens | Melon, grapes, orange, mint |
| Brownie | Ask staff | Wheat flour, eggs, butter (milk), walnuts, chocolate (soya lecithin) |
What is wrong with the sandwich entry?
Visa svar
Sesame seeds are missing. The bread contains sesame, so the entry should read: contains wheat, sesame, milk.
What should happen with the soup entry?
Visa svar
Update it, because the special changed. The lentil soup contains celery (in the stock); lentils and coconut are not among the 14.
Is "No allergens" correct for the fruit salad?
Visa svar
Yes, based on the records: none of its ingredients is one of the 14 allergens. Check again if the recipe changes.
Why is "Ask staff" not enough for the brownie, and what should it say?
Visa svar
Information on request only is not enough unless national rules allow it (Ireland requires writing). It should say: contains wheat, eggs, milk, nuts (walnuts), soya.
Lesson 5: Avoiding cross-contact in the kitchen
Cross-contact means an allergen gets into a food that is not meant to contain it. EU texts call this "cross-contamination". It can happen through shared equipment, boards and knives, surfaces, cooking oil, storage containers, hands and gloves. The customer cannot see it, so the kitchen must prevent it.
What the law says
Since 2021, the EU food hygiene rules (Regulation 852/2004, as changed by Regulation 2021/382) say that equipment, vehicles and containers used for food containing an allergen must not be used for food that does not contain it, unless they have been cleaned and checked, at least for any visible traces of that allergen.
The Commission's guidance says allergens must be part of the business's food safety management system (its HACCP-based procedures).
Good practice from the Commission's guidance
- Storage: store allergen ingredients correctly and label raw materials that contain allergens.
- Separate where you can: use separate equipment, containers and storage for allergen ingredients where possible.
- Plan the order of work: where separation is not possible, make allergen-containing products last, for example at the end of the day.
- Clean well: where you cannot check for visible traces, pay extra attention to how often and how thoroughly you clean.
- Suppliers: if a supplier says an allergen might be present by accident, they should say how much so the risk can be assessed.
- "May contain" labels should be based on a risk assessment and never replace these steps.
Practical points
- Boards and knives are equipment too: use separate ones, or clean and check them between uses.
- Shared frying oil carries allergens from one food to the next. Ireland's food authority (FSAI) gives the example of chips fried in oil also used for fish: the chips can carry fish. Tell an allergic customer this.
- Picking an allergen off a plate does not make it safe. The UK Food Standards Agency, for example, says not to just remove the allergen and serve the food, but to start again with fresh ingredients.
- Wash your hands thoroughly before preparing an allergy order, as UK Food Standards Agency guidance advises.
- Never swap ingredients without updating the records.
Training and food safety culture
Food handlers must be supervised and instructed or trained in food hygiene in line with their work. Businesses must also have a food safety culture: committed managers, staff who know the hazards, open communication and enough resources. The Commission's guidance says staff awareness of allergen management should be ensured, for example through specific training for workers. The Irish food authority, for example, says staff training should cover how to identify and handle the 14 allergens and how to respond to customers' concerns. Your employer's own training covers the equipment and procedures in your kitchen.
Practical exercise: spot the cross-contact risks
A customer with a peanut allergy orders a stir-fry with no peanuts. Read what happens in the kitchen and answer the questions.
| Steg | What the cook does |
|---|---|
| 1 | Uses the wok just used for a peanut satay stir-fry, after wiping it with a cloth |
| 2 | Takes noodles from an open tub stored under a tub of crushed peanuts |
| 3 | Chops vegetables on a board with some peanut pieces still on it |
| 4 | Serves the dish and removes two peanuts seen on top |
What is wrong with step 1?
Visa svar
Equipment used for an allergen must be cleaned and checked before use for food without it. A quick wipe is not enough.
What is the risk in step 2, and how can storage be improved?
Visa svar
Peanuts can fall into the open noodle tub. Keep allergens in closed, clearly labelled containers, stored apart from other foods where possible.
What should the cook do instead of step 3?
Visa svar
Use a clean board and knife, or wash and check the board for any visible traces first.
Is removing the peanuts in step 4 enough?
Visa svar
No. Removing an allergen does not make the dish safe. Start again with fresh ingredients and clean, checked equipment, and tell the manager.
Lesson 6: Allergy questions and emergencies
When a customer asks about allergens
- Listen and take it seriously. Ask which foods they must avoid. Do not judge whether it is an allergy, an intolerance or coeliac disease.
- Check, do not guess. Use the written allergen information, the recipe card and the product labels. Ask the chef or manager if you are not sure.
- Be honest. If you cannot be sure a dish is free from the allergen (for example because of shared oil or equipment), say so. Let the customer decide, and offer options that are safer.
- Pass it on clearly. Mark the allergy on the order and tell the kitchen, following your workplace procedure. EU hygiene rules call for open and clear communication between all staff.
- Check before serving. Make sure the right dish goes to the right person.
Some customers need information in a different way, for example people with a vision impairment. Read the information to them or explain it. If the allergy is not one of the 14, check the recipes for that food in the same way.
In an emergency: call 112
112 is the European emergency number. It works everywhere in the EU, free of charge, from fixed phones and mobile phones. Many countries also keep national numbers, but 112 always works. If the caller does not know the address, the operator can find the location and pass it on.
If someone shows signs of anaphylaxis, such as a swollen throat or tongue or difficulty breathing, follow these steps. They are based on the advice of Ireland's health service (HSE), one country's guidance; also follow your workplace first-aid training:
- If the person has an adrenaline auto-injector, help them use it. The instructions are on the side of the device.
- Call 112 (or ask a colleague to call at the same time) and say you think the person is having anaphylaxis.
- Lie them down. If they find it hard to breathe, they can sit up slowly or raise their shoulders.
- Do not let them stand up or walk, even if they seem to feel better.
- If the symptoms get worse or do not improve within 5 minutes, use a second auto-injector if there is one.
- Follow the operator's instructions and get your workplace first-aider and manager.
Afterwards, tell your manager, follow your employer's incident procedure and note what the person ate.
Practical exercise: handle the customer
Read each situation and decide what you would say or do. Then compare with the model answers.
| # | Situation |
|---|---|
| 1 | A customer asks: "Is the chocolate cake nut-free? I have a severe hazelnut allergy." You do not know the recipe. |
| 2 | The recipe shows no nuts, but the cake is made on the same trays as a hazelnut tart. |
| 3 | Ten minutes after eating, a customer says their tongue is swelling and they are struggling to breathe. They have an auto-injector in their bag. |
| 4 | After the injection the customer says, "I feel better now, I'll just walk to the toilet." |
Situation 1: what do you do?
Visa svar
Do not guess. Say you will check the allergen information and recipe card, or ask the chef or manager.
Situation 2: what do you tell the customer?
Visa svar
Tell them honestly that hazelnuts are not an ingredient, but shared trays mean traces cannot be ruled out. Let them decide, and suggest a safer choice if there is one.
Situation 3: what are your first actions?
Visa svar
Help the customer use their auto-injector, and call 112 (or get someone to call at the same time), saying you think it is anaphylaxis. Lie them down, or let them sit up slowly if breathing is hard.
Situation 4: what do you say?
Visa svar
Ask them not to stand or walk, even though they feel better. Keep them lying or sitting until the ambulance arrives. Use a second auto-injector if symptoms get worse or do not improve within 5 minutes.
Källor
- Regulation (EU) No 1169/2011 on the provision of food information to consumers (consolidated text, EUR-Lex)
- Commission Notice 2017/C 428/01 on the provision of information on substances or products causing allergies or intolerances (EUR-Lex)
- European Commission: Mandatory food information
- Regulation (EC) No 852/2004 on the hygiene of foodstuffs (consolidated text, EUR-Lex)
- Regulation (EU) 2021/382 amending the food hygiene annexes (allergen management and food safety culture, EUR-Lex)
- Commission Notice 2022/C 355/01 on food safety management systems, including allergen management (EUR-Lex)
- EFSA: Scientific Opinion on the evaluation of allergenic foods and food ingredients for labelling purposes (2014)
- EFSA: Allergens in food: scientific advice updated (news, 2014)
- European Commission: 112, the European emergency number
- Food Safety Authority of Ireland: Allergen information for non-prepacked food
- Food Safety Authority of Ireland: Allergen information for non-prepacked food (leaflet, PDF)
- Food Safety Authority of Ireland: List of 14 allergens
- Food Safety Authority of Ireland: Food allergens (consumer advice)
- HSE (Ireland): Food allergy
- HSE (Ireland): Anaphylaxis
- HSE (Ireland): Coeliac disease
- UK Food Standards Agency: Cross-contamination and food allergies (Safer food, better business sheet, PDF)