Fish on the menu: where it appears and how to label it

What it covers and what it doesn’t

Point 4 of Annex II of Regulation (EU) 1169/2011, which still applies in the UK, covers “Fish and products thereof”, with just two exceptions:

• fish gelatine used as a carrier for vitamin or carotenoid preparations;
• fish gelatine or isinglass used as a fining agent in beer and wine.

Everything else counts: fresh, frozen, salted, smoked, tinned or dried fish; roe; stocks and extracts; fish sauces; pastes such as surimi. Crustaceans and molluscs are separate allergens with their own numbers.

Where it hides

Stocks and broths

• Fish stock in risottos, paella, chowders, fish soups and bouillabaisse.
• The sauce in fish pie, seafood pasta sauces and fillings.

One stock often goes into several dishes. If you use it in a sauce or a “vegetable” risotto, that dish contains fish too.

Anchovies

• Caesar salad and Caesar dressing.
• Salsa verde, tapenade, puttanesca and pizzas, depending on the recipe.
• Anchovy butter on steak and anchovy paste on toast.
• Worcestershire sauce, which contains anchovies: it turns up in Bloody Marys, steak tartare, Welsh rarebit, gravies and many marinades.

Tuna and other tinned fish

• Tuna mayo sandwiches and jacket potatoes, tuna melts, niçoise salad.
• Fishcakes, fish pie, vitello tonnato.

Smoked and cured fish

• Smoked salmon on bagels and blinis, kippers, kedgeree, gravadlax, taramasalata, bottarga.

Bought-in products and Asian cooking

• Seafood sticks.
• Thai and Vietnamese fish sauce, in pad thai, many curries and dipping sauces.
• Traditional kimchi, often made with fish sauce or salted shrimp.
• Dashi made with bonito flakes, in miso soup and many ramen broths.
• Sushi, sashimi, poke and tataki.

Cross-contamination

Fish is one of the allergens most at risk of cross-contact in the kitchen, especially in frying:

• The fryer. In a fish and chip shop, anything fried in the same oil as the fish (chips, onion rings, battered sausages) may carry traces of fish.
• The grill and the flat-top, if they go from fish to meat or vegetables without being cleaned.
• Boards and knives, especially at sushi counters and in smoking and curing areas.
• The base stock shared between dishes that are not “fish dishes”.

If a dish may contain traces for these reasons and you cannot avoid it, mark it “may contain fish”. If you can avoid it (another fryer, another area of the grill), that is a better option than the warning.

Fish, crustaceans and molluscs

In a seafood restaurant, remember that fish (4), crustaceans (2) and molluscs (14) are marked separately. A seafood paella made with fish stock, prawns and mussels carries all three. Someone allergic to fish may tolerate shellfish, or the other way round, so grouping them under “fish and seafood” leaves them with nothing useful to go on.

A quick check before you print the menu

Ask yourself these questions with your dish records in front of you:

• Which stocks and broths do you use, and which dishes do they end up in?
• Does the house salad contain tuna or anchovy?
• Does any sauce, dressing, marinade or cocktail use Worcestershire sauce or fish sauce?
• Do your chips or vegetables share a fryer with fish?
• Has the brand changed on any bought-in product, such as fishcakes, seafood sticks or stock?

If any answer makes you hesitate, check the product label. On prepacked food the 14 allergens have to be emphasised in the ingredients list, in bold, colour or capitals, so that is where to look.

In the US

Fish is one of the FDA’s nine major food allergens, and US labels must name the species, such as “anchovy” or “cod”, rather than just “fish”. So a US bottle of Worcestershire sauce will declare anchovies. The FDA’s definition covers bony fish such as cod, salmon and tuna, and cartilaginous fish such as shark and skate.

How to mark it on your menu

Fish is number 4 in Annex II. Mark the allergen on every dish that contains it as an ingredient, a base or a sauce. Pay special attention to salads, house dressings and cocktails with Worcestershire sauce, which is where it most often slips through.

As well as marking it on the menu, your front-of-house team needs to be able to check what is in each dish. The allergen matrix is the easiest way to keep it all on one sheet.

In MenuDesign you mark allergen 4 dish by dish, choose whether it shows as an icon, number or name, and use the same data to download the matrix in A4 for your premises.