One dish, two sets of rules

How we work

Why we settle allergens before the menu

Since October 2021, food that a business packs on the premises from which it sells it, before the customer orders it, has been treated as prepacked for direct sale. That food must carry a label giving the name of the dish and a full list of its ingredients, with each of the fourteen regulated allergens emphasised within that list so that it stands out rather than hiding in the middle of a sentence. The change came out of a death, and it closed a gap that had let a wrapped sandwich on a shelf carry less information than the identical sandwich sold in a supermarket.

What makes it genuinely awkward for a caterer is that the obligation attaches to the packing rather than the food. The same tray of coxinha is prepacked for direct sale if it is boxed in the morning and sold from a counter at lunch, and not prepacked if it is plated when somebody orders it. For non-prepacked food there is no labelling duty, but the allergen information must still be available and accurate, and there has to be clear signposting telling customers to ask. So a kitchen running takeaway, mobile stands and event catering at once is operating under both regimes in the same week, and the only way to stay on the right side of it is to know every dish properly rather than per service.

Brazilian food gives that a sharp edge because the assumptions people arrive with are so often wrong. Pão de queijo is made with cassava starch and is usually gluten free, while containing milk and cheese that nobody asks about. Coxinha contains wheat and generally milk. Brigadeiro is condensed milk. Paçoca is peanuts all the way through. Moqueca brings fish or crustaceans. None of that is obvious from looking, which is why an allergy question deserves a fact and not a hedge. Where this kitchen cannot promise the absence of cross contact, because it handles nuts, milk, wheat and sesame daily, we say so plainly. An assurance that is not true is the one thing more dangerous than no assurance at all.