Owen’s Law Is Coming: 7 Allergen Training Upgrades Every UK Kitchen Needs Before It’s Mandatory

Owen’s Law is not yet UK law.

It is a campaign calling for restaurants, cafés, pubs, takeaways and caterers to provide written allergen and ingredient information at the point of ordering.

The Food Standards Agency (FSA) published voluntary best practice guidance in March 2025. The guidance recommends that food businesses make written allergen information available to customers and support it with a clear conversation.

The government is evaluating how widely the guidance has been adopted. Results are expected in 2026 and will help determine whether mandatory legislation is needed.

That means now is the right time to prepare.

Kitchens that already use accurate menus, trained staff and strong allergen controls will be better positioned if Owen’s Law becomes mandatory.

They will also be better positioned to meet current legal duties.

OWEN’S LAW: WHAT BUSINESSES NEED TO KNOW

For non-prepacked food, businesses must provide accurate allergen information for any of the 14 regulated allergens.

This applies to food served in:

• Restaurants
• Cafés
• Pubs and bars
• Takeaways
• Hotels
• Schools and colleges
• Care settings
• Event catering
• Workplace canteens
• Mobile food businesses

At present, non-prepacked allergen information can be provided in writing or verbally, provided there is clear signposting telling customers how to obtain it.

The FSA now recommends a stronger approach:

1. Provide allergen information in writing.
2. Make it available before the customer orders.
3. Train staff to answer questions accurately.
4. Use a conversation to confirm the customer’s requirements.

This is the practical direction many food businesses are already taking.

Read the current GOV.UK allergen guidance for food businesses.

NATASHA’S LAW IS ALREADY MANDATORY

Owen’s Law is proposed legislation.

Natasha’s Law is already in force.

Natasha’s Law applies to prepacked for direct sale (PPDS) food. This includes food packed on the same premises before it is offered for sale, such as:

• Prepacked sandwiches
• Boxed salads
• Packaged cakes
• Wrapped burgers prepared in advance
• Prepacked pies
• Food placed in packaging and displayed for customers

PPDS food must have:

• The name of the food
• A full ingredients list
• Allergens emphasised in the ingredients list

Allergens can be emphasised using bold text, capital letters, contrasting colour or underlining.

The key point is simple:

If your kitchen sells PPDS food, the labelling requirement already applies.

If your kitchen serves made-to-order meals, allergen information must still be provided, but written information is currently best practice rather than a specific legal requirement for every menu.

INFOGRAPHIC: 7 ALLERGEN TRAINING UPGRADES TO MAKE NOW

1. PUT WRITTEN ALLERGEN INFORMATION IN PLACE

Do not rely on memory.

Create a written allergen record for every dish, drink, sauce, garnish and ingredient used by the business.

This may be held in:

• An allergen matrix
• A recipe file
• Product specification sheets
• Supplier information
• A digital menu system
• A kitchen management folder

The information must be current and accurate.

Review the record whenever:

• A recipe changes
• A supplier changes
• A product is replaced
• A seasonal menu is introduced
• A new garnish or sauce is added
• A preparation method changes

A written system gives staff a reliable source to check before answering a customer.

It also provides evidence that allergen management is being taken seriously.

2. TRAIN STAFF ON ALL 14 ALLERGENS

Every team member who prepares, handles, serves or sells food needs appropriate allergen awareness.

The 14 regulated allergens are:

• Celery
• Cereals containing gluten
• Crustaceans
• Eggs
• Fish
• Lupin
• Milk
• Molluscs
• Mustard
• Peanuts
• Sesame
• Soya
• Sulphur dioxide and sulphites above the legal threshold
• Tree nuts

Staff should understand that allergens can appear in less obvious ingredients.

Examples include:

• Soya in sauces
• Milk in butter, cream or cheese
• Sesame in burger buns
• Mustard in dressings
• Wheat in stock cubes
• Nuts in pesto
• Sulphites in some drinks and preserved ingredients
• Fish in sauces and stock products

Staff should also understand the difference between:

• Food allergies
• Food intolerances
• Coeliac disease
• Anaphylaxis
• Cross-contact and cross-contamination

Book Food Allergen Awareness training at Zems Academy to build this knowledge across your team.

3. USE CLEAR SIGNPOSTING

If customers need to ask staff for allergen information, make this clear.

Use a visible statement on:

• Menus
• Counter displays
• Till points
• Ordering screens
• Websites
• Delivery menus
• Food packaging
• Buffet displays

A suitable message could be:

Please speak to a member of staff if you have a food allergy, intolerance or coeliac disease. We will provide information about the ingredients in your meal.

The message should be easy to see and easy to understand.

Do not hide it in small print at the bottom of a menu.

For online and telephone orders, allergen information must be available before the purchase is completed and again when the food is delivered.

4. CONTROL CROSS-CONTAMINATION

An ingredient does not need to be part of the recipe to create a risk.

Allergens can transfer through:

• Shared utensils
• Chopping boards
• Frying oil
• Work surfaces
• Gloves
• Cloths
• Storage containers
• Hands
• Slicers and mixers
• Inadequate cleaning

Controls should include:

• Washing hands between tasks
• Cleaning and sanitising surfaces
• Using clean utensils
• Separating allergen-containing ingredients
• Storing ingredients in closed, labelled containers
• Keeping original packaging or accurate labels
• Using separate equipment where necessary
• Checking shared frying oil
• Preparing allergen-sensitive orders in a controlled area

If the business cannot control the risk, staff must not promise that a dish is allergen-free.

Avoid making “free-from” claims unless the business has strict controls that support the claim.

5. REVIEW MENU LABELLING

Menu labelling should help customers make an informed choice quickly.

You can use written descriptions, allergen names, numbers or symbols.

If symbols are used, explain them clearly with words.

Do not rely on a symbol system that customers cannot understand.

Good menu labelling should be:

• Clear
• Consistent
• Easy to read
• Accurate
• Updated when recipes change
• Available before the order is placed

For example:

Chicken burger : contains wheat, milk, egg and mustard.

You can also use a separate allergen matrix. This may be useful for larger menus, buffets and catering operations.

The FSA provides allergen icons and posters for food businesses.

6. IMPROVE THE ACCURACY OF VERBAL INFORMATION

A customer may ask:

“Does this contain milk?”

The answer must come from a verified source.

Staff should not guess.

Staff should not say:

• “I think it is safe.”
• “It should be fine.”
• “The chef usually makes it without that.”
• “There probably is not any in there.”
• “It is not listed, so it must be allergen-free.”

Instead, staff should:

1. Listen carefully to the customer.
2. Confirm the allergen involved.
3. Check the written allergen information.
4. Speak to the chef or manager if required.
5. Explain the answer clearly.
6. Record or communicate the request to the kitchen.
7. Confirm any cross-contamination risk.

A confident answer is only useful when it is accurate.

7. INTRODUCE A REFRESHER TRAINING CYCLE

One training session is not enough.

Hospitality teams change regularly. Menus change. Suppliers change. Temporary staff join the business. Busy service periods can lead to shortcuts.

Use a refresher cycle that includes:

• Allergen training during induction
• Regular refresher sessions
• Short team briefings
• Menu-change updates
• Supplier-change reviews
• Practical kitchen checks
• Incident reviews
• Staff knowledge checks

Keep a training record for every team member.

The record should show:

• Course completed
• Date of training
• Staff member’s name
• Trainer or provider
• Refresher date
• Any further action required

A refresher process helps turn allergen management into a daily workplace standard.

QUICK-CHECK GRID FOR UK KITCHENS

If several answers are “No”, the business should prioritise an allergen management review.

BOOK FOOD SAFETY TRAINING WITH ZEMS ACADEMY

Allergen control is part of effective food safety management.

Zems Academy provides practical food safety training and hospitality training for food handlers, chefs, catering staff, managers and food business owners.

Available training includes:

• Food Allergen Awareness
• Level 2 Food Hygiene and Safety for Catering
• Level 1 Food Hygiene and Safety
• Food safety and manufacturing courses

Zems Academy’s Food Allergen Awareness course covers:

• The 14 regulated allergens
• Allergies, intolerances and coeliac disease
• Food allergen legislation
• Allergen contamination
• Cross-contamination prevention
• Storage and segregation
• Food labelling
• Customer communication
• Allergen-related incidents
• Allergen management procedures

The course is available through flexible online learning, with certification on successful completion.

Do not wait for Owen’s Law to become mandatory.

Train your team now.

Review your menus now.

Improve your allergen controls now.

Book Food Allergen Awareness training with Zems Academy.

IMPORTANT REMINDER

Owen’s Law is currently a campaign and is not yet law.

The March 2025 FSA guidance recommends written allergen information at the point of ordering for non-prepacked food.

The government is evaluating industry uptake, with results expected in 2026.

Natasha’s Law already applies to PPDS food and requires a full ingredients list with allergens emphasised.

Food businesses should follow current legal requirements, use FSA best practice guidance and seek advice from their local authority if they are unsure about their responsibilities.

Review the FSA’s official allergen guidance.

Book training. Update your controls. Prepare your kitchen before the rules change.