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EU 1169/2011: the allergen rules every charter chef should know

Fourteen allergens, three regimes (EU, UK, US) and how to brief them to a multi-flag guest list.

By Azul Provisions Compliance · Head of food safetyPublished May 16, 20268 min read

Why this matters more on a charter than in a restaurant

A charter is a closed environment. There is no kitchen porter to dispatch to a third pharmacy at midnight if a guest has an unmanaged tree-nut reaction in international waters. Allergen management on board is a safety-critical workflow, not a regulatory checkbox.

The 14 allergens under EU 1169/2011

  1. Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut)
  2. Crustaceans
  3. Eggs
  4. Fish
  5. Peanuts
  6. Soybeans
  7. Milk (including lactose)
  8. Nuts (almonds, hazelnuts, walnuts, cashews, pecan, Brazil, pistachio, macadamia)
  9. Celery
  10. Mustard
  11. Sesame seeds
  12. Sulphur dioxide and sulphites (>10 mg/kg or 10 mg/L)
  13. Lupin
  14. Molluscs

What changes outside the EU

  • UK FSA — same 14 allergens, same labelling regime; "Natasha's Law" requires PPDS labelling, which charter chefs adopt as a matter of practice.
  • US FDA "Big 9" — wheat, milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, soy, sesame (added 2023). No celery, mustard, sulphites, lupin, molluscs.

For a multi-flag guest list, default to the EU 14 — it is the strictest and covers all three regimes.

How we brief on board

When our allergen engine [blocked] detects a conflict between a guest's declared allergens and a product on the order, the cart blocks the line and surfaces the conflict to the captain. We never let a flagged item ship without an explicit override and a printed acknowledgement.

Cross-contamination on board

  • Dedicated chopping boards for the flagged allergen
  • Sealed-bag handling in the fridge (no open ramekins)
  • Tongs and gloves not shared between stations
  • Final plate plated by the chef, not the stew

The pre-charter conversation

Ninety percent of allergen incidents are preventable with a pre-charter call. We send the broker a structured form at T-72 that captures:

  • Allergen list (with severity)
  • Dietary preferences (kosher, halal, vegan, low-FODMAP, etc.)
  • Special preparations (no raw fish, only filtered water, etc.)
  • EpiPen / antihistamine declarations

That form rides with the manifest into the central kitchen and onto the boat. It is the spine of safe charter catering.

#allergens#eu-1169#food-safety#chef#charter