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The fourteen, declared

Fourteen substances are named in law, and a counter has to be able to say, about any item on it, which of the fourteen are in it. That answer is not a label design problem. It is a question of knowing what each component of an item is made of, keeping that written down, and keeping it written down again every time a component changes.

The list, and where each turns up

The fourteen, with the components that usually carry them
Named in lawWhere it turns up on this counter
CeleryStock powders and seasoning blends in a savoury filling.
Cereals containing glutenWheat flour above all, then barley malt, rye, oats and spelt. The one declared most often here.
CrustaceansNot on the sweet side. Declared wherever a savoury filling uses it.
EggsSponge, custard, meringue and the wash brushed on before a bake.
FishNot on the sweet side. Declared wherever a savoury filling uses it.
LupinLupin flour, which appears in some blends sold as gluten-free.
MilkButter, cream, chocolate, and the whole of the drinks side.
MolluscsNot on the sweet side. Declared wherever a savoury filling uses it.
MustardDressings and savoury seasoning blends.
PeanutsPeanut fillings and the toppings that use them. Separate in law from tree nuts.
SesameSeeded toppings, tahini, and some enriched doughs.
SoyaSoya flour, soya lecithin in chocolate, and soya drinks at the pour station.
Sulphur dioxide and sulphitesDried fruit and some fruit purées. Declared above 10 mg/kg or 10 mg/l.
Tree nutsAlmond, hazelnut, walnut, pecan, cashew, pistachio, macadamia or Queensland nut, and Brazil nut.

Two kinds of item, two kinds of answer

An item made up at the counter when it is ordered — a drink poured, a sponge filled to order — is answered for in person, out loud, with a written notice at the counter saying that the question can be asked and that the component sheets are behind it. An item wrapped before it is ordered and sat in the dome or the deck is a different thing: it carries its own label, with the full list of ingredients and every one of the fourteen emphasised in the list rather than mentioned beside it.

The practical consequence is where the work happens. For the made-to-order side the work is at the pass, in the asking. For the wrapped side the work is at the bench, before the item ever reaches the run, because a label cannot be corrected once a dome lid is down over forty of them.

A component is the unit, not the item. A filled sponge is a base, a filling, a glaze and a topping, and each of those has its own declaration. Change the glaze and the item's declaration changes with it — which is why the folder is kept by component and not by finished item.

Building a declaration

The declaration for a finished item is the union of its components. Nothing is averaged, nothing is left off because it is a small quantity, and nothing is added because it seemed likely. The allergen matrix on sheet 01 does the union for five components and names which component contributed each line, so a swap can be traced without rebuilding the whole declaration from the beginning.

MethodC1

One
Write the components of the item down as separate lines, in the order they are assembled.
Two
Take each component's declaration from the supplier's specification, not from the carton front.
Three
Combine them. If two components carry the same allergen, both are recorded against it.
Four
Date the sheet and file it by component in the folder at the pass.
Five
On any substitution, the component sheet is rewritten before the item goes back on the run.
Leaves the pass with The component sheet folded inside the carrier, and the answer already given out loud.

Two things are deliberately not done. A precautionary line is not printed as a habit: a warning about contact belongs on an item where contact has actually been assessed as possible, and printing it on everything tells a customer nothing and removes their choice. And a verbal answer is never given from memory when the folder is three steps away — the folder is the answer, and the three steps are part of the job.