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Allergen Matrix

Allergen 7 of 14 · Mi

Milk: the knob of butter at the end

Milk is in more dishes than any other allergen, often added at the last second: butter on the vegetables, cream in the soup, cheese on top. Lactose counts as milk too.

Checked against the official guidance on 18 September 2026

What the law covers

Annex II lists “milk and products thereof (including lactose)”.

Exempt from declaration (Annex II):

  • Whey used for making alcoholic distillates, including ethyl alcohol of agricultural origin
  • Lactitol

Where it hides in a UK kitchen

WhereWhy
Butter to finishOn vegetables, steak, fish, mash and sauces: the recipe card often doesn't list it.
Whey and milk powderIn crisps, breads, sausages, seasonings and some gravy granules.
Ghee and paneerBoth are milk: curry houses use ghee in many dishes, naan often has yoghurt.
ChocolateMilk chocolate is milk; dark chocolate is often made on lines shared with milk.
PestoParmesan or Grana Padano.

In the free matrix builder, typing any of these ticks milk automatically: Brioche, Croissant, Cake, Pancake, Yorkshire pudding, Hollandaise, Caesar dressing, Pesto, Bechamel, Cheese sauce, Custard, Milk chocolate, Hazelnut spread, Frangipane, Milk, Cream These prompt a label check instead, because it depends on the recipe or the brand: Burger bun, Naan, Chapati, Crumpet, Batter, Pastry, Biscuit, Horseradish sauce, Taramasalata, Chocolate, Praline, Dairy-free spread.

Cross-contact to think about

  • Shared butter, shared spoons in a bain-marie.
  • Grill brushed with butter.
  • Milk steam wand used for dairy and plant milks without purging.

Where your risk assessment finds a risk you cannot control, mark the dish “may contain” on the matrix. Don't use it as a blanket statement: when “may contain” is justified.

On a PPDS label

NOT ENOUGH

Paneer, ghee

CLEAR

Paneer (milk), ghee (milk)

Words like butter, cream, cheese and yoghurt already say milk and are emphasised; names that don't (paneer, ghee) get “(milk)”.

Make a PPDS label with allergens emphasised automatically →

Mistakes we see on matrices

  • Finishing butter not on the recipe card.
  • Oat, soya or almond milk swapped in without changing the column.
  • Assuming dark chocolate is dairy-free.

Milk: questions from kitchens

Is lactose intolerance covered by the milk column?

Yes. The legal wording is “milk and products thereof (including lactose)”, so lactose is declared as milk.

Official sources

  1. Regulation (EU) No 1169/2011, Annex II — substances or products causing allergies or intolerances legislation.gov.uk (version applying in Great Britain).
  2. Allergen guidance for food businesses Food Standards Agency (GOV.UK), updated 17 July 2026.
  3. Food allergen labelling and information requirements: technical guidance Food Standards Agency (GOV.UK), published 23 August 2023, revised March 2025.
  4. Regulation (EU) No 1169/2011, Article 21 — labelling of allergens legislation.gov.uk.

All sources opened and checked on 18 September 2026. This page is general information, not legal advice.