| Who sets the guidance | The Food Standards Agency for England, Wales and Northern Ireland; Food Standards Scotland in Scotland. Local authorities enforce. | The FDA for menu labelling and packaged food labels. State and local health departments enforce the food code they have adopted. |
| Allergens to declare | The 14 allergens, including celery, lupin, molluscs, mustard and sulphites above ten parts per million. | The 9 major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame (sesame since 1 January 2023). |
| Dishes served or sold loose | England, Wales and Northern Ireland: allergen information for every item containing any of the 14, in writing or verbally with a written notice telling customers how to ask; the FSA advises written information backed by a conversation. Scotland: available before purchase, on a menu, chalkboard, shelf label or from staff (Food Standards Scotland). | The FDA Food Code asks for written notification of major food allergens in unpackaged food (3-602.12(C), added in 2022 and kept in the 2026 edition, the latest), where the state or locality has adopted it. |
| Food packed on site before it is ordered | Prepacked for direct sale (PPDS): since 1 October 2021, a label with the name and a full ingredients list with the 14 allergens emphasised, in all four nations. | The FDA says the allergen labelling law extends to food-service establishments that package, label and offer food, not to food wrapped after the customer orders it. |
| Calories on menus | England only, from 6 April 2022: businesses with 250 or more employees (franchisees counted with the franchisor) show kcal and portion size, and “adults need around 2000 kcal a day”. | Covered establishments: chains of 20 or more locations under the same name with substantially the same menu, or registered with the FDA. Calories next to the name or price, two statements, and written nutrition information on request. |
| Short-run and test dishes | Exempt from calorie labelling when on the menu for less than 30 consecutive days and less than 30 days in total in a calendar year. | Daily specials, temporary menu items (less than 60 days in a calendar year) and customary market tests (less than 90 consecutive days) are not standard menu items. |
| How calories are worked out | From the manufacturer’s analysis, the ingredients or established data; GOV.UK guidance treats plus or minus 20% as an acceptable margin and recommends keeping records. | A reasonable basis (databases, cookbooks, laboratory analyses), with the method and data, and signed statements, given to the FDA on request. |
| Online and phone orders | Allergen information before the purchase is completed and on delivery (FSA). In England, the website or app shows the calories for food from a business covered by the rules. | Menus on the internet count as menus for covered establishments, so they show calories too. |