Restaurant allergen requirements in United States
Allergens that must be declared in United States
- Milk
- Eggs
- Fish
- Crustacean shellfish
- Tree nuts
- Peanuts
- Wheat
- Soybeans
- Sesame
Source: FDA Big-9 Food Allergens (FASTER Act, 2021).
The Big 9, and what changed in 2023
US federal labelling law identifies nine major food allergens. Sesame was added by the FASTER Act and took effect on 1 January 2023, making it the first addition since the original eight were set in 2004. Recipe data assembled before that date frequently does not carry sesame at all, which is the single most common gap in an older US allergen dataset.
Labelling law and restaurant practice are different things
The federal allergen labelling requirements are written for packaged food. Restaurant menus are regulated primarily through the FDA Food Code as adopted by each state and locality, so the specific obligations on a restaurant vary by where it operates rather than being uniform nationally.
The direction of travel is toward more disclosure, not less, and several states have moved ahead of the federal baseline on staff allergen training. Treat the nine as the floor for what you record, and check your state and city requirements for what you must display.
The gap a US guest will notice
The Big 9 does not include celery, mustard, lupin or sulphites, all of which are statutory in the EU and UK. A restaurant serving international guests — or a US operator opening in Europe — will find the American dataset is missing fields the European menu needs.
Recording against the wider set costs nothing extra at data-entry time and means the same menu can be published into either market without a re-audit.
How Intermenu helps
Allergen tags are recorded once per menu item as structured data and render in every language you publish, so a guest filtering for an allergen gets the same answer whichever version of the menu they are reading. Nothing is inferred silently — the operator sees the mapping at upload time.