What is an allergen matrix?
An allergen matrix (also called an allergen chart or allergen grid) is a table that maps every food product you sell against every allergen it contains. It is your primary internal reference for allergen management — the thing you consult when building a customer allergen menu, training staff, or responding to an inspector.
It is not the same as a customer-facing allergen menu, though both should derive from the same source of truth. Your matrix is the working document; the allergen menu is the formatted output customers see.
The FIC Regulation requires disclosure of allergen information but does not mandate a specific internal format. However, a well-maintained matrix is the most practical way to demonstrate compliance in an inspection, and the FSAI recommends it as best practice.
What to include in your allergen matrix
A compliant allergen matrix must cover all food products you sell and all 14 allergens regulated under EU FIC. At minimum it should contain:
- Product name — exactly as it appears on your menu or label
- A column for each of the 14 regulated allergens
- Contains / Does not contain markers — tick/cross, Y/N, or colour coding. Must be unambiguous.
- May contain (precautionary) markers — for allergens not intentionally present but where cross-contamination risk has been assessed. Separate notation from confirmed "contains".
- Date of last review — when was this entry last verified?
- Version number or revision history — so you can demonstrate the state of your records at any point in time
Optionally but usefully:
- A notes column for context (e.g. "gluten-free certified oats used")
- Ingredient-level breakdown as a supporting document
- Source/supplier reference for key allergen-bearing ingredients
How to build it: step by step
01 — List every product you sell
Include everything — mains, sides, sauces served separately, drinks with added syrups, desserts, snacks. If a customer eats it, it belongs in the matrix. Group by category if helpful.
02 — For each product, list every ingredient
Not just main ingredients — every component. A chicken burger includes the bun, patty, sauce, lettuce, pickle, and garnish. Compound ingredients (commercial mayo, stock cubes) must be broken down using the supplier's product specification.
03 — Map each ingredient to the 14 allergens
Go allergen by allergen for each ingredient. Use supplier specifications as your primary source. Do not guess. If you don't have a specification, request one.
04 — Roll up to product level
If any ingredient contains an allergen, the product contains that allergen. The matrix entry reflects the union of all ingredient allergens. One allergen-bearing ingredient is sufficient.
05 — Assess cross-contamination risk
For allergens not intentionally present, consider whether cross-contamination is possible through shared equipment, surfaces, fryer oil, or nearby storage. Document your assessment. Where genuine risk exists, add a "may contain" marker.
06 — Date-stamp and save a version
Record the date completed or last reviewed. Save previous versions. Store the matrix somewhere accessible to kitchen and floor staff, not just in a head office folder.
07 — Derive your customer-facing allergen menu
Produce a customer-facing chart or menu from the completed matrix. This is a separate document — formatted for readability, not for internal management.
08 — Brief all relevant staff
Every staff member who may be asked about allergens — floor, kitchen, delivery — needs to know your allergen policy and where to find information. Record who was trained, when, and on what.
Example allergen matrix
Simplified example for a small café. In a real matrix, "Nuts" would be broken down by species and compound ingredients like "Caesar dressing" would have their own ingredient-level breakdown as a supporting document.
| Product | Gluten | Crustaceans | Eggs | Fish | Peanuts | Soy | Milk | Nuts | Celery | Mustard | Sesame | Sulphites | Lupin | Molluscs |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| BLT Sandwich | ✓ | – | ~ | – | – | – | ✓ | ~ | – | ✓ | ~ | – | – | – |
| Caesar Salad | ✓ | – | ✓ | ✓ | – | – | ✓ | – | – | ✓ | – | – | – | – |
| Mushroom Risotto (v) | ~ | – | – | – | – | – | ✓ | – | ✓ | – | – | ✓ | – | – |
| Fish & Chips | ✓ | – | – | ✓ | – | – | – | – | – | – | – | – | – | – |
| Chocolate Brownie (gf) | ~ | – | ✓ | – | ~ | – | ✓ | ✓ | – | – | ~ | – | – | – |
Customer-facing allergen format
Your internal matrix is not what customers need. The law requires customers can access allergen information — but does not mandate the exact format, provided the information is accurate, complete, and accessible.
Common customer-facing formats:
- Printed allergen menu: A formatted version of your matrix available on request or on every table. The most legally secure approach.
- Allergen chart on the wall or counter: A laminated A3/A2 chart. Must be updated whenever the matrix changes.
- Digital menu with allergen filtering: Must pull from the same source as your matrix.
- Verbal disclosure with written backup: Staff communicate allergen information orally, backed by a written reference. A notice must inform customers that information is available on request.
Whatever format you choose, it must reflect the current state of your allergen matrix. A customer-facing menu that hasn't been updated since last year's seasonal change creates false security — and is worse than having no system at all.
Maintaining your matrix
A completed matrix is not a done job. The most common cause of allergen enforcement actions is having a system that was correct once and hasn't been maintained.
Establish a clear process for when and why the matrix must be updated:
| Trigger event | Required action |
|---|---|
| New menu item added | Add to matrix before the item is available to customers. Do not wait until the next scheduled review. |
| Supplier change | Request new product specification. Compare allergen profile to the previous spec. Update matrix if changed. |
| Recipe modification | Re-map every ingredient in the modified recipe. Even minor changes — a new sauce, a garnish swap — can introduce undisclosed allergens. |
| Seasonal menu rollout | Treat a seasonal menu rollout as a full matrix review. All new items must be mapped before launch. |
| Supplier formulation change | Establish a process to receive and act on formulation change notifications. A supplier updating their bread mix is your problem too. |
| Allergic incident or near-miss | Immediately audit the matrix for the product involved. Investigate, update, and re-train staff. |
| New allergen added to EU list | Review the entire matrix against the new allergen. Rare, but lupin was added in 2006. |
Review your matrix formally at least once every 6 months, or more frequently if your menu changes regularly. Treat it like a food safety record — a living document, not a one-off project.
Assign one person — an allergen lead — responsible for maintaining the matrix and ensuring all staff work from the current version. This is typically a senior chef or manager.
What Environmental Health Officers look for
An EHO inspecting your allergen management system is assessing whether you have a credible, maintained, and actionable system. They will typically:
- Ask to see your allergen matrix or information system
- Check it covers all products currently on your menu
- Ask staff (not management) how they find allergen information
- Check for supplier specifications supporting your allergen claims
- Ask how the system is updated when recipes or suppliers change
- Check staff training records
The questions an EHO is most likely to ask:
Can you show me your allergen matrix or information system?
How do you update your allergen information when a recipe changes?
How do you train new staff on allergen procedures?
How do customers ask about allergens, and how does your staff respond?
What supplier documentation do you hold for your ingredients?
Has anyone here had an allergic reaction in the last 12 months?
How do you handle a customer who says they have a severe allergy?
The key is that any member of staff — not just the manager — should be able to answer Q1 and Q4. If the matrix exists but front-of-house staff don't know about it, that is a practical failure.
Common failures and how to fix them
| Common failure | Risk | How to fix it |
|---|---|---|
| Matrix not updated after supplier or recipe change | High | Establish a formal change control process. Whoever approves a new supplier or recipe change must also trigger a matrix review. |
| Matrix exists but staff don't know how to use it | High | Train staff specifically on how to find allergen information. A matrix in the office during dinner service is useless. |
| Compound ingredients not traced to component allergens | High | Every sauce, stock, spice blend, and marinade must be mapped. "Spice blend" on the matrix is not compliant. |
| "May contain" not reflected in matrix | Medium | Cross-contamination risk should be formally assessed and documented. Add a separate "may contain" notation to your matrix where relevant. |
| Matrix not customer-accessible | Medium | The matrix is your internal document. Customers need a separate, customer-facing allergen menu derived from it. |
| No version control or date stamps | Low–Med | Date every version. In an enforcement investigation, you may need to prove what your allergen information was on a specific date. |