How to add allergen info to your menu (EU 1169/2011 compliance guide)

If you operate a restaurant, cafe, food truck, or hotel kitchen anywhere in the European Union or the United Kingdom, you are required by law to disclose the presence of 14 specific allergens in the food you serve. The rule has been in force since December 13, 2014 under EU Regulation 1169/2011, and it applies to unpackaged food just as much as packaged.

This is not a "nice to have." Local food-safety authorities can issue fines for non-compliance, and a single anaphylactic reaction traced back to incomplete allergen information can become a criminal liability case. The bar to meet the law is genuinely low, but you have to actually meet it.

This guide covers:

• What the regulation requires in practice
• The 14 allergens you must declare
• Acceptable formats for disclosing the information
• How to set this up systematically in a digital menu
• Common failure modes and how to avoid them

What EU 1169/2011 actually says

The regulation is long, but the core obligation for restaurants comes from Article 44, supplemented by Annex II (the allergen list). Restated in operator language:

1. You must inform the customer of allergen presence before they order. The information has to be available — not on request only, not hidden in a back office.
2. The information must be accurate. "May contain traces" hand-waving does not cover a dish where the allergen is definitely present.
3. The information can be provided in writing, electronically, or verbally — but if verbal, written backup must exist on-premises. Many member states have layered additional national rules requiring written information.

The UK retained the regulation post-Brexit and added the "Natasha's Law" amendment in 2021 for pre-packaged-for-direct-sale food, but for plated restaurant meals the rule is effectively identical to the EU baseline.

The 14 allergens you must declare

Annex II of EU 1169/2011 lists 14 substances or products causing allergies or intolerances. You must disclose each whenever it is an intentional ingredient:

1. Cereals containing gluten — wheat, rye, barley, oats, spelt, kamut, and their hybridised strains
2. Crustaceans — shrimp, prawn, crab, lobster, langoustine
3. Eggs
4. Fish
5. Peanuts
6. Soybeans
7. Milk (including lactose)
8. Nuts — almonds, hazelnuts, walnuts, cashews, pecans, brazil nuts, pistachios, macadamia
9. Celery
10. Mustard
11. Sesame seeds
12. Sulphur dioxide and sulphites (over 10 mg/kg or 10 mg/L)
13. Lupin
14. Molluscs — clams, mussels, oysters, snails, squid, octopus

Note that "nuts" in the regulation specifically excludes peanuts (those are legumes and have their own entry) and coconut. Sesame is its own entry — do not assume it folds in with seeds generically.

What "providing the information" actually looks like

The regulation permits several formats:

Option 1: On the menu itself

Each dish carries a clear, legible allergen indication. This is the gold standard and the only fully self-service option.

In practice this is done with either icons, a numeric/letter footnote system, or inline text:

Caesar Salad (1, 3, 4, 7) — Romaine lettuce, anchovies, parmesan, egg, croutons

Contains: cereals containing gluten (1), eggs (3), fish (4), milk (7).

Icons are friendlier for customers but you still need a key. A pure-icon menu without a legend will not satisfy most inspectors.

Option 2: A separate written document available to all customers

A binder, laminated card, or A4 sheet that lists every dish with allergens. The catch: it has to be offered proactively, not just "available on request." Many inspectors interpret "on request" as non-compliant because the customer first needs to know to ask.

Option 3: Electronic / digital display

A QR-code menu, tablet, or kiosk that surfaces the allergen information per dish. This is explicitly permitted under the regulation and is, frankly, the easiest format to keep accurate.

A digital allergen system has three advantages no paper version can match:

• It is searchable. A guest with a peanut allergy can filter to "no peanuts" and see only what is safe.
• It is updated instantly. Swap a supplier and update one ingredient; every affected dish reflects the change.
• It scales across languages. Translate once, every guest sees the right language.

Qarte's allergen management treats the 14 categories as first-class entities — every menu item gets tagged from a controlled list, and the public menu renders icons, a filter chip, and a per-item details card.

What inspectors actually check

From published inspection reports across France, Germany, Spain, Italy, the Netherlands, and the UK, the recurring failure modes are:

1. Information missing entirely. No menu allergen disclosure, no separate document. Easy fine.
2. "On request" wording without proactive offer. The customer has to ask, which the regulation does not permit.
3. Outdated information. The menu still says no nuts in the pesto when the chef switched to pine nuts last month. This is the most dangerous failure — a customer can be hospitalised.
4. No information in the language of the country. A German restaurant publishing allergens in English only will fail an inspection.
5. Staff unable to confirm allergens verbally. Even if your menu is correct, staff need to be trained — inspectors do ask servers directly.

Building a defensible workflow

To get from "we have a paper menu with peanut icons next to two dishes" to a defensible compliance posture:

Step 1: Audit your recipes

For every dish on your menu, write down every ingredient. Not "salad dressing" — every component of the salad dressing. This is tedious; do it once and you can reuse it forever.

Step 2: Tag each ingredient against the 14 categories

A spreadsheet works. Columns: ingredient, then one column per allergen (Y/N). Roll up to the dish level.

Step 3: Decide your display format

The simplest path: a digital menu with allergen filter and per-dish allergen list. Customers self-serve. You back this up with a verbal SOP for staff: "If a guest asks about allergens, you confirm by reading from the digital menu — never from memory."

Step 4: Document a change-management process

When a recipe changes, the allergen tags must update before the new version of the dish goes out of the kitchen. This is the single biggest source of compliance failure. The discipline must be: ingredient changes are a menu update, not a kitchen change.

A digital menu makes this enforceable. The menu version that hits the customer always reflects the latest tagging. Paper menus require you to reprint or risk serving with stale information.

Step 5: Train staff and document the training

Inspectors will ask, "How do you know if this dish contains celery?" Your staff must have an answer. Acceptable answer: "I check our menu — every dish lists its allergens." Unacceptable: "I think the chef would have mentioned it."

Where Qarte fits

We built allergen management because we kept seeing restaurants fail compliance not from negligence but from the workflow being too painful to maintain. The system:

• Maintains the 14 allergen categories as a controlled vocabulary
• Lets you tag each menu item with the relevant allergens
• Renders an allergen filter on the public menu so guests with restrictions self-serve
• Renders allergen icons per item with a legend
• Exports a printable allergen sheet for inspectors and staff training
• Updates instantly when an ingredient or recipe changes

Combined with multilingual menus, every guest sees correct allergen information in their language without you maintaining N parallel allergen documents.

A note on cross-contamination

The 14 allergens listed in the regulation are about intentional ingredients. Cross-contamination ("may contain traces") is a separate disclosure that you can add at your discretion. Best practice for any restaurant with a real risk (open kitchen, shared fryer, shared work surfaces with nuts) is to add a single line on the menu: "Our kitchen handles nuts, gluten, and other allergens. We cannot guarantee complete absence of trace contamination."

That sentence is not legally required, but it is honest and it protects you.

TL;DR checklist

• [ ] Tag every dish with the 14 allergen categories
• [ ] Make allergen information available before the customer orders — proactively, not on request
• [ ] Use a digital menu, a written document, or both — never verbal-only
• [ ] Information must be in the language of the country (multiple languages is better)
• [ ] Train staff on the SOP for allergen questions
• [ ] When recipes change, update the menu before service
• [ ] Add a cross-contamination disclaimer if your kitchen has shared risk

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If you want allergen compliance off your operations checklist, start a free Qarte trial. Import your menu, tag in minutes, and ship a compliant public menu the same day.