Allergens in restaurants: what EU Reg. 1169/2011 actually requires of you

"Does it all have to go on the menu?" "Does homemade count?" "What if the guest just asks out loud?" On allergens, restaurateurs everywhere ask the same questions, and fear of an inspection tends to produce either a menu buried in codes or nothing at all. Let's take the obligation apart calmly, without jargon. First, the note that matters: this article is not legal advice. The exact procedures, expected wording and enforcement depend on your country, your business and the current state of the rules; for your case, ask your food-safety consultant or your local enforcement authority. What follows is the principle and the practice, not an opinion on your menu.

The rule, at its core

The foundation is European: Regulation (EU) 1169/2011 on food information to consumers — the rule France calls the INCO regulation and Germany calls the LMIV. It applies across the whole EU, and the core requirement is the same everywhere: before ordering, the guest must be able to find out whether a dish contains any of the 14 declarable allergens. Each country then sets the detail for non-prepacked food — the plates served in your dining room — through its own national implementation. Which 14 allergens they are is spelled out in our allergen table guide; here we're talking about the obligation, not the contents of the list.

Written display or information on request

This is the question that comes up most, and the answer has two parts. Allergen information must be available to the guest before they order; how you deliver it can take several forms — but none of them dispenses with an accessible written basis. In practice, two routes coexist:

• Direct written information: the allergens on the menu, dish by dish, by key or code. The most legible route, and the safest if you're inspected.
• Information on request, provided a clear sign points the guest to it (something like "allergen information available on request") and an internal written record exists, consultable, that staff rely on to answer.

What doesn't exist is a third route: "we know our dishes by heart" with nothing written down. Spoken word alone, with no record behind it, isn't enough. Check the exact expected form with your local authority or consultant: the implementation has its nuances, the accessibility principle doesn't.

Homemade, processed, bought-in: the responsibility stays yours

"Homemade" is a strong selling point, but it changes nothing about the duty: whether a dish is slow-cooked on site or assembled from a semi-finished product, whoever serves it to the guest answers for it. A bought-in processed product arrives with its ingredient label; it's your job to read that label and carry its allergens into your declaration. The supplier informs you; they don't discharge you.

The classic trap is the "almost homemade" dish: the ready-made sauce, the baker's bread, the artisan's ice cream. Each brings its own allergens, and each can change them without warning. The survival rule: for anything that enters the kitchen already prepared, the label comes first. It's the same reflex a well-run gluten-free offer demands, where the smallest trace counts.

Staff have to be able to answer

An information duty is only worth as much as the person on the floor who carries it out. A server who tells an allergic guest "I don't think there's any in it" creates a health risk and a legal one at once. Three habits are enough to make service safe:

• A current record, accessible on the floor: the allergens per dish, checkable in ten seconds.
• The right default answer: when in doubt, don't guess — go and check. "Let me confirm with the kitchen" is always the best sentence.
• Honesty about traces: a kitchen that handles flour, tree nuts and fish often can't rule out cross-contamination. Saying so — "we can't guarantee the absence of traces" — isn't an admission of weakness, it's candour, and it protects the guest as much as you.

An obligation that has to follow the menu

The most common failure isn't missing information, it's out-of-date information. The recipe changes, the supplier switches, the daily special rotates — and the allergen record stays frozen on last month's printed version. An information duty that doesn't follow the kitchen becomes a risk rather than a protection.

This is where a digital medium changes everything. With Menudetto, the AI detects the allergens in a dish and its ingredients and proposes the declaration — but before anything is published, a human reviews and confirms. The AI does the busywork; responsibility for the plate stays in the kitchen, where it belongs. When a dish changes, you update the record in seconds from your phone, and the information behind the QR code is instantly the right one — for the menu and for the staff who rely on it. Need to start from the list itself? The free allergen table gives you the grid.

In short

Regulation (EU) 1169/2011 — the INCO rule — requires that the guest can learn the allergens before ordering: the information may be written on the menu or available on request, but never purely spoken with no written basis; homemade and bought-in alike carry your responsibility, the supplier label first; staff must be able to answer and to say honestly what they can't guarantee; and the information only protects if it follows the kitchen day by day. For the exact procedures where you are, talk to your consultant or your local authority — this article is a practical guide, not legal advice.