Restaurant allergen menu: the 2026 guide to EU Regulation 1169/2011
If you run a restaurant, a pizzeria or a café, listing allergens isn't optional housekeeping — it's a legal duty, and increasingly the first thing a coeliac or allergic guest checks before they sit down. This guide explains, without the jargon, what you have to declare, where, and how — and how to keep it all current without reprinting the menu every week.
What the law says, in plain terms
The rule comes from EU Regulation 1169/2011 — the Food Information to Consumers (FIC) Regulation — which has applied across the Union since 13 December 2014. It boils down to one thing: anyone serving food must let the guest know which of the 14 allergens are in each dish, before they order and pay.
It applies to all "non-prepacked" food — the food you make and serve on the spot: the dish of the day, the pizza, the sandwich at the counter. Answering verbally on request is not enough on its own: the information must be available in a written, verifiable form. You can put it on the menu, or display a clearly visible notice pointing to a written source (an ingredients register) that is always available to consult. What is not acceptable is "only the chef knows".
Why so strict? Because for an allergic guest a mistake isn't an annoyance, it's a clinical risk. The law protects the customer — but it protects you too: a clear allergen chart is your documented proof that you did things properly.
The 14 allergens you must declare (the full list)
Annex II of the Regulation sets the mandatory list of 14 allergens. Here they are, each with an example dish where they most often hide:
- Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut) — fresh pasta, bread, gnocchi, béchamel, most breaded fried items.
- Crustaceans — seafood pasta, prawn dishes, langoustine risotto.
- Eggs — egg pasta, mayonnaise, tiramisù, many batters and coatings.
- Fish — anchovies (watch out: often "hidden" in sauces), salt cod, tartare.
- Peanuts — desserts, ethnic sauces, some frying oils.
- Soybeans — soy sauce, tofu, many industrial bases.
- Milk (including lactose) — béchamel, butter, cheeses, grated parmesan on a pasta, cream in a risotto.
- Nuts (almonds, hazelnuts, walnuts, cashews, pistachios…) — pesto, mortadella with pistachios, dry pastries.
- Celery — the base soffritto, stock, many sauces and ragùs. It's the most-forgotten "invisible" allergen.
- Mustard — dressings, some meat sauces, sweet-and-sour dishes.
- Sesame — "seeded" breads and breadsticks, hummus, some oriental dishes.
- Sulphur dioxide and sulphites (above 10 mg/kg or mg/l) — wine, vinegar, dried fruit, some preserved products.
- Lupin — alternative flours, some vegan and gluten-free products.
- Molluscs — clams, mussels, squid, cuttlefish, octopus.
The practical point: nobody forgets the "obvious" allergens (fish, crustaceans). The trouble comes from the two most common hidden allergens — celery in the soffritto and sulphites in the wine you deglaze with — which end up in half the menu without anyone thinking about them.
Where and how to display them: menu, board, QR
There's no single mandated format: what matters is that the information is complete, correct and available before the order. The three most common routes:
On the menu, next to each dish
The most transparent option. Typically you use a numbered or lettered key (1 = gluten, 7 = milk…) and put the numbers next to each dish. Guests prefer this because they don't have to ask anything.
With an ingredients register
An "allergen book" — paper or digital — listing the allergens present in each dish. In this case you must display a clearly visible notice (e.g. "For allergen and intolerance information, ask our staff for the register"). The notice isn't optional: it's what makes the "on request" method compliant.
With a digital / QR menu
The QR on the table opens the full menu with an always-current allergen chart. This is the fastest-growing option, because it combines two wins: the guest gets the information before ordering and you update once, with no reprints. A well-built QR menu shows allergens dish by dish and can even filter the dishes a guest can safely eat.
Whichever route you pick, the golden rule is one: no verbal-only information. The server's word can add to the written source — never replace it.
The mistakes that cost you (and the penalties)
Regulation 1169/2011 sets the duty; penalties are set at national level and, for missing or wrong mandatory information, routinely run into thousands of euros/pounds — in Italy the sanctions regime (D.Lgs. 231/2017) reaches tens of thousands of euros. You don't need an incident: a routine health-authority inspection finding the chart missing, incomplete or inaccessible is enough.
The mistakes we see most often:
- No written information. "Ask the waiter" alone isn't enough: without a register or an allergen menu you're non-compliant.
- Incomplete chart. Celery missing from the soffritto, sulphites from the cooking wine, milk from the béchamel. Small omissions, real fines.
- Menu and kitchen out of sync. You change a recipe or a supplier but the chart stays the old one. This is the most dangerous mistake, because it produces wrong information, not just missing.
- No notice when you rely on the "on request" register: the method is only allowed if the notice is displayed.
- Traces and cross-contamination left unmanaged: if you fry breaded items and chips in the same oil, gluten "travels". It has to be assessed and communicated.
How to keep them current without reprinting
The real obstacle isn't filling in the chart the first time: it's keeping it current. The menu changes — seasons, suppliers, specials — and every recipe tweak can change the allergens. With printed menus that means reprinting (or, worse, pen corrections). That's why it pays to:
- Start from the recipe, not the dish. Map allergens ingredient by ingredient once; then every dish "inherits" the allergens of its ingredients.
- Flag the "hidden" sources. Note the soffritto (celery), wine/vinegar (sulphites), coatings (gluten, eggs) from the start: those are the ones that slip through.
- Update in one place. If the menu lives digitally, you change the ingredient once and the allergen chart, the QR and the print stay aligned automatically.
- Review every season change and every time a new supplier comes in.
This is exactly where a digitally managed menu earns its keep: allergens aren't a separate sheet to re-fill, they're information that follows the dish. Update the recipe and the chart updates itself — on the table menu, on the QR and on the printable version.
In short
A mandatory allergen chart isn't bureaucracy for its own sake: it protects your guest and gives you concrete documented cover. To recap: declare the 14 allergens from Annex II, put them in writing (menu, register plus notice, or QR), don't rely on "verbal only", and above all keep them aligned with the real kitchen.
If updating the chart on every menu change feels like a losing battle, it's probably because you're managing it on paper. Managing your menu by talking — and letting allergens, QR and print update themselves — removes the most expensive mistake of all: the old chart on a new dish.