Allergen labelling for restaurants: the 14 allergens, the menu, and EU Reg. 1169/2011

Allergen labelling is, for many operators, the most uncomfortable duty on the menu: fiddly, always shifting, and a mistake can be costly. Yet the principle is simpler than it looks — and done well, it protects the guest and you at the same time. First, the essential note: this article is not legal advice. How you must label in your specific case, which wording is expected and how it's enforced depend on your country, your business and the current state of the rules. For your own situation, ask your food-safety consultant or your local food-safety authority. What follows is the principle and the practice, not an opinion on your menu.

One EU rule, many national names

The foundation is the same across the whole EU: Regulation (EU) 1169/2011 on food information to consumers. In English it's often shortened to the "Food Information to Consumers" rule; in Germany and Austria it's the LMIV; in France, the "règlement INCO". Same law, different everyday name. If you operate across borders, that's worth knowing — because the core applies to everyone the same way.

What the regulation asks of a restaurant fits in one sentence: before ordering, the guest must be able to find out which of the 14 declarable allergens a dish contains. Each country then transposes the detail under its own national implementation, and the enforcement authority differs from place to place. The 14 allergens, though, are identical across Europe — so that's where we start.

The 14 allergens that belong on the menu

Fourteen groups are declarable, no more and no fewer: cereals containing gluten (wheat, rye, barley, oats, spelt), crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), tree nuts (almond, hazelnut, walnut and others), celery, mustard, sesame, sulphur dioxide and sulphites (above the threshold), lupin and molluscs (mussels, squid, snails).

The list is the easy part; the trap is that an allergen often hides where you don't expect it. Sulphites in wine and dried fruit, celery in a stock cube, mustard in a ready-made sauce, soy in the breading. So for every bought-in semi-finished product the rule is the same: read the label, carry its allergens across. How to turn that into a clean, dish-by-dish declaration is covered in the allergen table guide; the free allergen table hands you the grid to fill in.

Non-prepacked food: the case that defines restaurants

Most of what a restaurant serves is non-prepacked food — prepared fresh and plated open, not sealed in a supermarket package. That category has its own, often more flexible information routes than the labelled bottle on a shelf. In practice it means the allergen information must be available and accessible before the guest decides — on the menu, in a footnote, on a notice, or via a clearly signposted verbal answer backed by a written record staff can rely on. Which of these routes is enough where you operate is a question for your local authority: the exact implementation varies, the accessibility principle doesn't.

Footnotes and letter codes: how the labelling looks

On the menu, a small number of systems have become standard. The most common is a superscript number or letter after the dish, resolved in a key at the foot of the menu — "beef roulade ¹,³,⁷" with "1 = cereals containing gluten, 3 = eggs, 7 = milk". Italy's asterisk tends to flag frozen products rather than allergens; for allergens, codes or footnotes are the clean choice, because a single dish can carry several.

Two things decide quality: completeness and legibility. A key set in six-point type that nobody can read doesn't do the job — legally or humanly. And a verbal answer doesn't simply replace the written one: whoever informs guests by mouth generally needs a documented basis the staff work from. The principle holds: the guest decides before ordering, not after the first bite.

Additives: an extra declaration in some countries

Worth flagging because it's often confused with allergens: in several countries — the German-speaking region in particular — there's a second, separate duty alongside allergens, covering additives. Colourings, preservatives, antioxidants, flavour enhancers, sweeteners, sulphited or nitrite-cured items, phosphates, caffeine — these are flagged too, usually through their own key. It touches the cola, the cured sausage, the preserved olive, the coloured drink. Where it applies, plan for two keys, not one: allergens and additives live side by side, often in the same footnote block, but follow different logic. Whether your country requires the additive declaration is another point to confirm locally.

The declaration has to be right — every day

The most common failure isn't a missing key, it's an out-of-date one. The supplier changes the sauce recipe and suddenly there's mustard in it; the kitchen switches from butter to margarine and one allergen drops out while another appears. A printed menu can't keep up: it's updated when it's reprinted, which is rarely.

This is where a digital menu earns its place. With Menudetto, the AI detects the allergens in a dish and its ingredients and proposes the labelling — but before anything is published, a human reviews the suggestions. The AI takes the busywork; responsibility for the plate stays in the kitchen. When a product changes, you correct the entry in seconds from your phone, and the menu behind the QR code is instantly current. It's the same reason a well-run gluten-free offer works: the information matches what's actually coming out of the kitchen today.

In short

Allergen labelling in restaurants follows EU Regulation 1169/2011 — known by different names in each country: 14 allergens the guest must be able to identify before ordering; non-prepacked food has its own accessible information routes; on the menu, codes and footnotes work more cleanly than an asterisk; and in some countries an additives declaration sits alongside. What matters most is that the information matches what's served today. For how you must label in your specific case, ask your consultant and your local authority — this article is a practical guide, not legal advice.