The fourteen
Annex II of Regulation (EU) No 1169/2011 names fourteen substances that must be declared whenever they are present. The regulation entered into application on 13 December 2014 and the list has not changed since.
- Cereals containing gluten -- wheat, rye, barley, oats, spelt, kamut, and their hybrids
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk, including lactose
- Nuts -- almond, hazelnut, walnut, cashew, pecan, Brazil, pistachio, macadamia
- Celery, including celeriac
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites, above 10 mg/kg or 10 mg/litre expressed as SO2
- Lupin
- Molluscs
The ones kitchens miss
In practice the same few cause most of the errors, and none of them are the obvious ones.
- Celery hides in stock cubes, bouillon, and a great many commercial sauce bases. It is the most commonly missed of the fourteen.
- Sulphites are in wine, dried fruit, and some potato products, and the threshold is low enough that a garnish can cross it.
- Mustard is in mayonnaise, most vinaigrettes, and a lot of pre-made marinades.
- Milk appears in things that are not dairy dishes -- brioche buns, some breads, and a butter finish on a steak.
- Lupin flour turns up in imported bakery products and is genuinely easy to overlook.
Every one of these comes from an ingredient someone else made. Which means the allergen data for your menu is only as good as the supplier specifications you have read.
Why it applies to a restaurant at all
Most of Regulation 1169/2011 concerns packaged food on a shelf. The part that reaches a restaurant is Article 44, which covers food offered for sale without prepackaging -- a plate of food served at a table, a dish at a buffet, something wrapped at the point of sale for a customer.
For that category, the allergen information listed in Annex II is mandatory. There is no exemption for small venues, no exemption for daily specials, and no exemption for a dish the chef improvised at service.
What counts as providing the information
This is where most guides overstate the rule, so it is worth being exact.
The regulation makes the information mandatory. On the means of providing it, Article 44 allows member states to adopt national measures. That is why the practical requirement differs across the union: some countries require the allergen information to be written and visible with the food on offer, while others permit it to be given on request provided a clearly signposted written notice tells the customer that the information is available and how to ask for it.
Two things follow from this for anyone running a digital menu. First, if written information is the requirement, a menu behind a QR code can carry it -- provided the information is genuinely reachable and not buried behind a tap nobody makes. Second, the compliant-and-easy option is usually to write it down regardless of whether your market strictly requires it, because it removes the failure mode where a busy server guesses.
Buffets, specials, and the dishes that change
A buffet is fourteen separate declarations sitting next to each other, and the practical requirement is that a guest can tell which dish carries which allergen. A single sign covering the whole table does not do that.
Daily specials are the harder case, because the whole point of a special is that it was decided this morning. Two approaches work:
- Keep the specials inside the same structured menu rather than on a separate chalkboard, so the allergen fields are filled as a condition of the dish existing.
- Constrain the specials to a set of components whose allergen profile is already recorded, so the declaration is assembled rather than researched at 11am.
The second is what most well-run kitchens converge on. It also has nothing to do with software.
Cross-contamination and what you may claim
The fourteen declarations describe what is deliberately in the dish. Cross-contamination -- a shared fryer, a shared grill, flour in the air of a bakery kitchen -- is a different statement and is voluntary.
The rules to hold onto:
- A precautionary statement is not a substitute for the mandatory declaration. "May contain nuts" does not discharge the duty to say that a dish contains nuts.
- It must not be used to paper over uncertainty about your own recipe. If you do not know whether the sauce base contains celery, the answer is to find out, not to hedge.
- It should describe a real risk in your kitchen, not sit on every dish as a blanket disclaimer. A precaution attached to everything tells a guest nothing and is treated as noise.
- "Gluten-free" is a regulated claim with a specific threshold. Do not use it loosely as a synonym for "no wheat in the recipe".
The United Kingdom, briefly
The UK retained the same fourteen allergens after leaving the EU, so the list itself is unchanged. Two differences are worth knowing.
The first is prepacked for direct sale, or PPDS -- food packed on the same premises it is sold from, such as a sandwich made in the morning and put in a chiller. Since October 2021, under what is commonly called Natasha's Law, PPDS items need a full ingredient list on the packaging with the allergens emphasised. That is a stricter requirement than the one covering a plated dish, and it catches a lot of cafes that did not think of themselves as packaging anything.
The second is that written allergen information, or a clearly signposted route to it, is the practical expectation for non-prepacked food rather than an option nobody takes.
A workflow that survives a menu change
The compliance question is answered once. The operational question -- is it still true after this week's changes -- is answered forever. Structure for the second one.
- Record allergens against the item, not against the printed menu. A menu is a view; the item is the fact.
- Record them against variations too. A dish served with a different bun or a different dressing is a different declaration.
- Source from supplier specifications, not memory. Keep the specification, because when a supplier reformulates, the change arrives silently.
- Treat any AI-suggested allergen value as a draft. Someone who knows the recipe approves it before a guest sees it.
- Re-check when a supplier changes, when a recipe changes, and on a fixed schedule regardless.
The operational side of getting this onto a live menu is covered in how to put allergen information on a digital menu, and what our own product models per item is set out on the nutrition and allergens feature. If you also operate in the United States, the rules there moved recently: see US restaurant allergen disclosure after California's ADDE Act.