Allergen Labelling on the Menu (EU Food Information Law): The Guide

This article serves as general orientation and expressly does not constitute legal advice. The requirements for food labelling arise from EU law and supplementary national provisions; the specific implementation can differ in detail and depend on the individual case.

When in doubt, clarify open questions with the food safety authority responsible for you or with qualified legal advice. This applies especially when it comes to liability questions, the permissible form of verbal information or borderline cases in the composition of dishes. Don't rely on general guides alone where the correct information affects guests with allergies.

The EU Food Information Regulation is the EU regulation on the provision of food information to consumers. Among other things, it stipulates that guests must be informed about certain allergenic ingredients – and not only on request after the meal, but as a matter of principle before the purchase decision.

For hospitality, the area of non-prepacked goods is especially decisive. That covers the bulk of what a restaurant, a café or a takeaway serves: dishes that are prepared and served openly, so-called loose goods. Here too there is an obligation to provide information about the main allergens contained.

The obligation applies regardless of channel: it concerns the printed menu just as much as notices, boards and digital menus. Anyone who puts their menu online or offers it via QR code is covered by the same requirements as for the paper menu.

The underlying idea is consumer protection: people with food allergies or intolerances should be able to recognise before ordering whether a dish is suitable for them. A reaction can be serious in the worst case, which is why the information has to be reliable and traceable. So it isn't just about formalities, but about a genuine protective function towards your guests.

The information obligation is aimed at food business operators who supply dishes to end consumers. In practice that concerns the whole of hospitality and communal catering:

• Restaurants, eateries, cafés and bars
• Takeaways, food trucks and delivery kitchens
• Bakeries and patisseries with open goods
• Canteens, refectories and catering
• Hotels with a food offering

What is decisive is the supply of food to guests, not the size of the business. Small businesses are covered by the obligation too. The requirements as to the form of the information can differ depending on the situation – the fundamental obligation to inform about the main allergens remains.

The following 14 main allergens and the products derived from them are subject to labelling. This list is set uniformly across the EU:

• Cereals containing gluten (e.g. wheat, rye, barley, oats) and products derived from them
• Crustaceans and products derived from them
• Eggs and products derived from them
• Fish and products derived from them
• Peanuts and products derived from them
• Soybeans and products derived from them
• Milk and products derived from it (including lactose)
• Tree nuts (e.g. almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts)
• Celery and products derived from it
• Mustard and products derived from it
• Sesame seeds and products derived from them
• Sulphur dioxide and sulphites (above the legally defined amounts)
• Lupin and products derived from it
• Molluscs and products derived from them

Note that not only the pure allergen but also ingredients derived from it are covered – for example wheat flour, soy lecithin or cream. For sulphur dioxide and sulphites, labelling applies above certain concentrations; they often play a role in wine, dried fruit or some convenience products.

The law requires that the information on the main allergens is available before the purchase decision, clear and easily accessible. For the specific form there are essentially two recognised routes.

In writing on the menu

The details can appear directly with the respective dish, in practice often via footnotes or abbreviations with a key. What matters is that the assignment is unambiguous, easily legible and not hidden. A key with letters or numbers is common, provided it is explained on the same menu and the guest finds it without effort.

Verbal information with a notice and documentation

Verbal information can be permissible under certain conditions. Typically there must then be a clearly visible notice about the option of verbal information, and the allergen details must additionally be documented in writing and be able to be produced on request – for example for guests or the authority.

The exact permissible form of the verbal option depends on the individual case and on supplementary national requirements. Anyone relying on verbal information should keep the internal documentation complete and up to date and train the service team accordingly.

In practice, written labelling on the menu is often the most transparent solution for guests, because the information is available at all times and doesn't depend on the presence or knowledge of a single member of staff. Which option suits your business is something you should decide deliberately and, when in doubt, coordinate with the responsible authority.

In practice, problems arise less from bad intent than from carelessness. These points are especially often overlooked:

• Outdated details after a recipe or supplier change – a new sauce can bring a new allergen with it.
• A missing or unfindable key, so that abbreviations on the menu aren't explained.
• Verbal information without the required written documentation in the background.
• Inconsistent details between the paper menu, the board and the digital menu.
• Allergens as unstructured free text, which easily becomes faulty with translations or changes.

Such mistakes aren't only a legal risk but can have serious health consequences for guests with allergies. Care and a clear internal process are more important here than any quick fix.

It has proven worthwhile to build the allergen details firmly into the process for every menu or recipe change: anyone adjusting a dish checks the assigned allergens in the same step. That way updating becomes a routine rather than an exception that gets lost in day-to-day business.

A digital menu makes correct allergen labelling considerably easier – provided the allergens are stored in a structured way per dish and not written as free text in the description. Structured means: each dish has the relevant allergens assigned to it as fixed, selectable attributes.

Several practical advantages follow from this:

• Consistency: an allergen assigned once appears uniformly everywhere and with the same designation.
• Multilingual support: the details stay unambiguous in every language offered, because they don't have to be reformulated each time.
• Currency: recipe or supplier changes can be updated immediately and apply at once.
• Filterability: guests can search for dishes that suit them, instead of reading every description individually.
• Readability: the information is visible before ordering, without overloading the menu.

A further advantage of structured handling is the upkeep day to day: if an ingredient changes, you adjust the allergen in one place, and the detail is immediately correct across the whole menu and in all languages. That lowers the risk of contradictory or forgotten details, which easily arise with manual upkeep across several documents.

The gastronomx "Digital Menu" feature is designed for exactly this: allergens are handled in a structured way per dish, so they are presented consistently, multilingually and always up to date. The professional responsibility for the accuracy of the details naturally remains with the business, which knows its recipes and suppliers – the digital menu makes sure these details reach guests cleanly and uniformly.

Besides allergens, there are further food-law labelling obligations. Certain additives must be made identifiable, for example colourings, preservatives, flavour enhancers or sulphured products treated with further substances. Here too, labelling via footnotes or a key on the menu is common.

The exact list of additives subject to labelling and the permissible form are covered in a dedicated article in this cluster. What is important to understand: allergen and additive labelling are two separate requirements that both have to be met and can be presented cleanly on the menu.

Anyone with an online presence – with a website, digital menu, reservations or online ordering – touches on further areas of law beyond food law. We cover these in detail in dedicated articles; here is a short overview for orientation.

Data protection (GDPR)

As soon as you process personal data – for instance with reservations, orders or newsletter sign-ups – the General Data Protection Regulation applies. This includes a legal basis for the processing, transparent information for guests and careful handling of the data. How data protection is organised at gastronomx is described separately.

Legal notice (imprint)

Commercial websites need a legal notice (imprint) with the provider details required by law. The obligation arises from the relevant national digital services law, which has replaced earlier rules. Which details are specifically needed for the restaurant website is shown in a dedicated post.

Privacy policy

In addition to the legal notice, a website needs a privacy policy that sets out clearly which data is processed and for what purpose. It should be tailored to the features actually in use.

Accessibility

Accessibility legislation brings accessibility requirements for certain digital offerings. Whether and to what extent your offering is affected depends on the specific situation – here too, a dedicated, detailed article follows.

Till security and fiscal recording

Electronic point-of-sale systems are subject to requirements for till security, in particular the technical security device and receipt issuance. This topic is independent of the digital menu, but it is part of many businesses' duties and is dealt with separately.

Allergen labelling under EU food information law is mandatory: guests must be informed about the 14 main allergens before the purchase decision – on the paper menu, on notices and on the digital menu alike. Permissible forms are the written details on the menu or verbal information with a visible notice and written documentation.

Digitally, the obligation can be met most reliably when allergens are handled in a structured way per dish – that way the details stay consistent, correct in every language, filterable and always up to date. Data protection, the legal notice, the privacy policy, accessibility and till security are further building blocks that we explore in this cluster. For legal grey areas, a visit to the responsible authority or to legal advice remains the safe route; for the practical implementation, the Help Centre is there to help.