The allergen matrix: what it is, and where it falls short

If you run a menu of any size, you've likely been asked for an "allergen matrix" — a grid of dishes against allergens. It's the workhorse document of allergen management. In our experience it can also give a false sense of security, because a grid records conclusions but not the evidence behind them.

Note: this is general guidance, not legal advice. Confirm your obligations with a suitably qualified professional.

What an allergen matrix is

An allergen matrix is a table of dishes (rows) against allergens (columns), with each cell marking contains, may contain, or free from.

The columns are not arbitrary. In the UK and EU, Regulation (EU) No 1169/2011 (Food Information to Consumers), Annex II defines the 14 allergens that must be declared: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphur dioxide and sulphites (above the specified threshold), lupin, and molluscs. (Source: EU 1169/2011, Annex II — legislation.gov.uk / EUR-Lex; verify the retained-UK version.)

The United States defines a different set. Under the Food Allergen Labeling and Consumer Protection Act (FALCPA) 2004, plus the FASTER Act 2021 which added sesame as the 9th major allergen (effective 1 January 2023), US "major food allergens" are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. (Sources: FALCPA 2004; FASTER Act 2021 — fda.gov; verify current FDA guidance.)

Building a defensible one (practitioner view)

The regulations define which allergens to declare; the points below are our recommended practice, not a legal standard:

1. Work from real ingredients, not the dish name — build each row from the stock, thickener, garnish and so on.
2. Distinguish contains from may contain. The FSA's position is that precautionary ("may contain") labelling should reflect a genuine, assessed cross-contamination risk rather than be applied as a blanket disclaimer. (Source: FSA precautionary allergen labelling guidance — food.gov.uk; verify the current page.)
3. Record the source of each call — label, supplier spec, or documented decision.
4. Date it and attribute it to a named person.
5. Re-check when anything changes — a new supplier or reformulated product can silently change a row.

The gap a grid leaves

A matrix is a summary. By itself it doesn't hold the evidence behind each cell — no photo of the label a call was read from, no record of who decided, no timestamp, no trail from cell to ingredient. That's fine until a claim is challenged, which is when the evidence, not the summary, is what counts.

The second weakness is staleness: a matrix is a snapshot, and nothing about the document signals when a recipe or supplier change has made a row out of date.

A better shape: matrix on top of evidence

The fix isn't to drop the matrix — front-of-house still needs the at-a-glance grid. It's to put evidence underneath it: a photo of the label each call was read from, the name of the person who signed it, the date, and a flag when something changes and a card needs re-checking. That's the model PlateProof uses — photograph the packets, allergens are read and tagged by source, a named chef signs each dish, and you can still print a clean matrix or per-dish card on top, now backed by evidence you can produce on demand.

See it on your own menu →

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Sources (verify before relying)

• Regulation (EU) No 1169/2011 (Food Information to Consumers), Annex II — legislation.gov.uk / EUR-Lex
• Food Allergen Labeling and Consumer Protection Act (FALCPA) 2004 — fda.gov
• FASTER Act 2021 (sesame as the 9th US major allergen) — fda.gov
• Food Standards Agency: allergen guidance & precautionary allergen labelling — food.gov.uk

Citations name the primary sources; confirm exact wording, the version in force, and the live URL before publishing or relying on any claim.