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HACCPAllergen matrix

Allergen matrix for HACCP: example with the 14 allergens

An allergen matrix is a table that records, for each dish, which of the 14 mandatory allergens it contains. It keeps the information on the menu and in the kitchen the same. The 14 allergens are listed in Annex II of EU Regulation 1169/2011 on food information to consumers. The duty to state them follows from Article 9, and for non-prepacked food from Article 44. Allergens are also a hazard in your HACCP plan and in your hazard analysis. The NVWA (Dutch Food and Consumer Product Safety Authority)  lists them alongside microbiological, chemical and physical hazards. You record the matrix as part of the HACCP checklist.

For non-prepacked food, such as a restaurant dish, you have two ways to inform guests. In writing or digitally, for example on the menu. Or verbally, provided guests can clearly see that they can ask about allergens, for example through a note on the menu. In both cases the information must be available in writing or electronically for staff and for the NVWA (source: KHN (Royal Dutch Hospitality Association) ). The matrix is the usual tool for this. You do not have to hand it to the guest.

The 14 allergens

The list below follows Annex II of Regulation 1169/2011. Use the names as they appear in your matrix, and mark for each dish whether the allergen is present or absent.

NoAllergenExamples in the kitchen
1Cereals containing glutenWheat, rye, barley, oats, spelt, flour, breadcrumbs, stock cubes with wheat
2CrustaceansPrawns, crab, lobster, some fish stocks and bisques
3EggsMayonnaise, pasta, pastries, some sauces and binders
4FishFish, fish stock, Worcestershire sauce, some Caesar dressings
5PeanutsPeanut sauce, satay sauce, peanut butter, some biscuits
6SoybeansSoy sauce, tofu, soy flour, soy products in meat substitutes
7MilkButter, cream, cheese, yoghurt, milk powder, some sauces
8Tree nutsAlmonds, walnuts, hazelnuts, cashews, pecans, pistachios
9CeleryCeleriac, celery salt, some stocks and spice mixes
10MustardMustard, some dressings, sauces and marinades
11Sesame seedsTahini, sesame seeds on bread, some Asian sauces
12SulphitesWine, wine vinegar, dried fruit, some sauces. Only above 10 mg per kg or per litre
13LupinLupin flour, some meat substitutes and baked goods
14MolluscsMussels, squid, oysters, some fish stocks

Pure refined peanut or soy oil falls outside the allergen list. If you are unsure, check the supplier specification. The examples are a tool for the kitchen. The question that matters is whether the allergen is in the dish, not whether it appears in the example. A bought ready-made sauce, for example, may contain milk or mustard that you would not expect.

Example: allergen matrix for a bistro

A fictional bistro has six dishes on the menu. The matrix looks like this. A cross means the allergen is in the dish.

DishGlutenCrustaceanEggFishPeanutSoyMilkNutCeleryMustardSesameSulphiteLupinMollusc
Steak with chipsxxxx
Fish of the dayxxxxx
Musselsxxxx
Pasta carbonaraxxx
Caesar saladxxxxx
Vegetarian burgerxxxxx

A matrix is only useful if you update it with every change. A new dish or a new supplier for the sauce is enough to make the matrix out of date.

How to build the matrix

Work through four steps for each dish:

  1. Write down the recipe, with all ingredients, including herbs, sauces and stock.
  2. For each ingredient, check whether it contains any of the 14 allergens. For bought products, read the label or the supplier specification.
  3. Mark the matrix and note the date and the version of the recipe.
  4. Repeat this with every change, and have the person responsible check the matrix every year.

Step two carries the biggest risk. A supplier can change a recipe without you noticing. That is why checking purchase specifications belongs in your hazard analysis, where allergens are assessed as a hazard.

What the auditor or inspector wants to see

At an inspection, the inspector asks for the matrix and picks out one dish. They then check whether the recipe matches the matrix, whether staff can name the allergen, and whether the information given to the guest is correct.

Check for yourself whether:

  • the matrix includes every dish on the current menu
  • the version number and date are on the matrix
  • staff know where the matrix hangs and how to use it
  • a new supplier or a new ingredient leads to an immediate update

Common mistakes

  • A matrix that only covers the main ingredients, while sauces and stock carry most of the allergens
  • A matrix that is not linked to the dish on the menu, so two versions exist
  • Forgetting sulphites, even though they are in wine and wine vinegar, for example in mussels with white wine
  • Relying on the supplier’s allergen list without checking it

Where the matrix fits in your HACCP system

The matrix is a record, but it is also a control measure. It belongs in the HACCP checklist under allergens. In your plan, it belongs under the hazard analysis for the steps where an allergen can be mixed up, such as portioning and labelling. An example of that step is in the HACCP plan example.

For the lists that support the matrix day to day, see HACCP lists for hospitality.

Frequently asked questions about allergens

Do I also need to state traces of allergens?

You record the 14 allergens that are an ingredient of the dish in the matrix. Traces from cross-contamination, for example nuts on the same chopping board, you handle separately in your hazard analysis and in what you tell the guest. Do not use vague wording such as “may contain traces” to avoid responsibility. Justify your choice.

What do I do with a dish I cannot make safely?

Then you tell the guest and do not present the dish as safe. Note in the matrix that the composition is uncertain.

How often do I need to update the matrix?

Whenever a recipe, a supplier or the menu changes. In addition, plan a fixed annual check of the whole matrix.

Sources

HACCP lists for hospitalityCleaning schedule for hospitality