Gluten on the menu: which cereals count and where it hides

What the law actually says

Point 1 of Annex II of Regulation (EU) 1169/2011 does not just say “gluten”. It lists cereals containing gluten: wheat (including spelt and khorasan wheat, often sold as Kamut), rye, barley, oats and their hybridised strains, plus all products made from them. In Great Britain the regulation still applies as assimilated (formerly “retained”) EU law, enforced through the Food Information Regulations 2014 and their equivalents in Scotland, Wales and Northern Ireland. The list of cereals is closed: maize, rice, millet, quinoa and buckwheat (which, despite the name, is not wheat) are not on it.

The annex itself exempts four highly processed derivatives:

• wheat-based glucose syrups, including dextrose;
• wheat-based maltodextrins;
• glucose syrups based on barley;
• cereals used to make alcoholic distillates, including ethyl alcohol of agricultural origin.

That is why whisky and gin do not carry the allergen and beer does. It is also why you may see “dextrose (wheat)” on an ice cream label without it being emphasised: that ingredient is exempt, but read the rest of the list.

Where it hides in British and American kitchens

Everyone knows about bread, pasta, pizza and pastry. The slip-ups usually come from here:

• Gravy and thickened sauces: gravy made with flour or gravy granules, roux-based sauces, the white sauce in lasagne, cauliflower cheese or fish pie, and stews and pie fillings where the meat is floured before browning.
• Batter and breadcrumbs: fish and chips, scampi, onion rings, chicken nuggets and tenders, Scotch eggs, fishcakes, tempura.
• Hidden bread and rusk: many British sausages and burgers contain rusk; stuffing, meatballs, bread sauce and crumb toppings on gratins and crumbles do too.
• Grains you might not think of: couscous, bulgur in tabbouleh, semolina, freekeh and seitan, which is pure wheat gluten.
• Bought-in products: soy sauce (most is brewed with wheat), stock cubes and gravy granules, spice blends, sausages and burgers with rusk or breadcrumbs, frozen chips and wedges with a crispy coating.
• Drinks: beer, lager, stout and malted drinks. Malt vinegar is made from barley as well.
• Breakfast and puddings: porridge and granola, pancakes and waffles, cheesecake bases, crumbles, sticky toffee pudding, doughnuts, and ice cream with cookie pieces or a wafer.

Cross-contamination: where a safe dish stops being safe

A dish with no gluten ingredients can still fail at the last step. The danger points in a pub or restaurant kitchen are always the same:

• The shared fryer. Chips fried in the same oil as battered fish or breaded scampi are no longer suitable for a coeliac guest.
• The grill and the toaster where breakfast toast and burger buns are done.
• The pasta water, if you reuse it for gluten-free pasta.
• Flour in the air when someone is dusting or kneading nearby.
• Boards, knives, sieves and ladles that move from one dish to the next.

If you cannot remove one of these risks, mark that specific dish “may contain gluten”. FSA guidance says precautionary warnings should only follow a risk assessment that finds a risk you cannot control. A targeted warning is more useful, and more honest, than a blanket disclaimer at the bottom of the menu.

“Gluten-free” is not the same as “no gluten ingredients”

The “gluten-free” claim is regulated: you can only use it if the food, as sold, contains no more than 20 mg/kg of gluten. “Very low gluten” (up to 100 mg/kg) also exists, but only for products made with cereals specially processed to reduce gluten. Both come from Regulation (EU) 828/2014, and the FSA confirms they apply to restaurant dishes, not just packaged food.

A dish without gluten ingredients is not automatically gluten-free: you also have to control how it is made. The FSA advises against “no gluten-containing ingredients” statements because they can mislead. If you use one anyway, make clear the dish is not suitable for people with coeliac disease.

Be careful with “gluten-free” beer. Many are brewed from barley with the gluten reduced, and the label still emphasises barley. Copy what the label says onto your menu rather than interpreting it.

In the US

The FDA’s major allergen is wheat, not gluten: any species of wheat, including spelt, durum, semolina, khorasan and triticale. Barley, rye and oats are not among the nine major allergens, so a US “Contains” statement will not flag them; read the ingredient list. A “gluten-free” label in the US means less than 20 ppm, and the FDA says restaurants using the term should stay consistent with that definition.

How to mark it on your menu

In the Annex II numbering, gluten is number 1. You can show it with an icon (usually an ear of wheat), the number or the word, as long as the menu has a key. Also:

• Mark it on sides, sauces and the bread served with the dish.
• If you have gluten-free bread, say so and explain how it is served: wrapped, toasted separately.
• Keep what a dish contains apart from what it may contain through cross-contamination.
• Make sure front-of-house staff know which dishes can be adapted and which cannot. “I don’t think so” is not an answer.

In MenuDesign you mark gluten dish by dish, choose whether it shows as an icon, number or name, and the same data produces the allergen matrix for your premises. The “Gluten free” label is separate from the allergen: only use it when you can meet the legal limit. If you need the symbols on their own, download the allergen icons, and find the other pages in the guide to the 14 allergens.