Most allergen guidance was written for a counter. A customer stands in front of you, points at something, and asks whether it has nuts in it — and the law lets you answer out loud, or point at a sign that says “ask a member of staff.” That works when there’s a member of staff to ask. Online, at half nine on a Friday, there isn’t. The order goes through a screen, and the screen has to do the job the counter used to.

That shift is the whole reason allergen rules feel murkier online than they do in the shop. The duty hasn’t changed — you’ve always had to give customers accurate allergen information. What’s changed is when and how, because a website can’t say “ask staff” and mean it.

The 14 allergens, and where the duty actually falls

UK law requires you to tell customers about 14 named allergens when they’re present in the food you sell: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide/sulphites.

The duty falls on whoever prepares and sells the food — which, for a takeaway or restaurant, is you. It doesn’t matter whether the order came through your own site, over the phone, or across the counter. If you made it and sold it, you’re responsible for declaring what’s in it.

The part that trips people up is that the format of the declaration depends on how the food is packed:

• Made-to-order and non-prepacked food — the vast majority of takeaway orders, cooked when the order comes in. Allergen information has to be available, but it can be provided in writing or by clearly directing the customer to where they can get it.
• PPDS (prepacked for direct sale) — food you’ve packed before a customer orders it, on the same premises you sell it from. Think a sandwich made this morning and put in the chiller, or a tub of coleslaw pre-portioned for the shelf. Since Natasha’s Law came in, these need a label carrying the full name and ingredients list, with the 14 allergens emphasised within it.

Most online takeaway orders are made-to-order, so PPDS labelling rules often won’t apply to the cooking. But if you sell anything off a shelf — cakes, cold drinks you’ve decanted, pre-packed sides — that item may be PPDS even though the hot food next to it isn’t.

Why “please ask staff” doesn’t survive online ordering

Selling food through a website counts as distance selling, and distance selling has its own wrinkle: the customer can’t ask. So the guidance expects allergen information to be available at two separate points.

• Before the order is placed. The customer needs to be able to get allergen information at the point they’re choosing what to buy — on the menu, on the ordering page, before they’ve paid. A sign on the wall of the shop doesn’t reach someone ordering from their sofa.
• Again when the food arrives. The information also has to be available at the moment of delivery or collection — so the physical handover isn’t the first time an allergy-aware customer can check.

“Please ask a member of staff” fails the first test outright. There’s no member of staff in the transaction. If your allergen information lives only behind a phone number or a “call us to check” note, an online customer has no way to get it before they commit — which is exactly the point the law wants covered.

What “available before checkout” looks like in practice

This is where a digital menu earns its keep, because the information can live inside the ordering flow rather than in a PDF nobody opens.

• Allergens attached to the dish, not a separate document. When a customer taps a product, the allergens for that specific item are right there. No hunting through a linked matrix, no cross-referencing item numbers against a grid.
• A public allergen view they can check before ordering. A page or filter that lets someone see, before they’ve added anything to a basket, what’s safe for them. This is the “before purchase” point handled properly.
• Accuracy that survives a menu change. The reason paper allergen matrices go wrong is that the menu changes and the matrix doesn’t. When allergens are set against the product itself, updating the dish updates the declaration — there’s no second document to forget.

The goal isn’t to bury the customer in disclaimers. It’s that an allergy-aware diner can answer their own question — can I eat here? — without needing you on the other end of a phone.

The honest bit about accuracy

None of this helps if the underlying data is wrong. A declaration that’s present but inaccurate is worse than useless — it’s the exact failure mode the law exists to prevent. Two things matter more than the format:

• Somebody owns it. Allergen data drifts when nobody’s job is to keep it current. New dish, changed supplier, swapped ingredient — each is a chance for the declaration to fall out of step with the kitchen.
• Modifiers count. Adding cheese adds milk. Adding a brioche bun adds egg and often sesame. If your allergen data stops at the base product and ignores what customers can add to it, the declaration on the final order can be wrong even when the base dish is right. That problem is big enough to deserve its own post — but it’s worth flagging here, because it’s the most common gap.

Getting allergens right online isn’t about doing more than the counter demanded. It’s about doing the same duty in a place where you’re not there to answer. The customer used to ask you. Now the menu answers for you — so it’s worth making sure it answers correctly.