While some restaurants treat allergen labeling as an afterthought, EU law demands complete accuracy for all 14 mandatory allergens. Many establishments risk hefty fines through incomplete information or unclear labeling. Here's how to correctly register and display allergens on your digital menu card.
The 14 mandatory EU allergens
EU regulation 1169/2011 requires you to list these 14 allergens when present in your dishes:
- Gluten (wheat, rye, barley, oats, spelt, kamut)
- Crustaceans (shrimp, lobster, crab)
- Eggs (also in sauces and pasta)
- Fish (also Worcestershire sauce contains fish)
- Peanuts (also peanut oil)
- Soy (also soy lecithin)
- Milk (including lactose, butter, cheese)
- Tree nuts (almond, hazelnut, walnut, cashew, etc.)
- Celery (also celery salt)
- Mustard (also mustard powder)
- Sesame seeds (also sesame oil)
- Sulfur dioxide and sulfites (>10 mg/kg, often in wine)
- Lupin (beans, often in gluten-free bread)
- Mollusks (mussels, squid, snails)
Where allergens hide
Watch out for these sneaky allergens that catch many restaurants off guard:
⚠️ Attention:
Worcestershire sauce contains fish. Pesto often contains nuts. Wine can contain sulfites. Vinegar can contain gluten. Check all ingredients, including spices and sauces.
- Sauces: mayonnaise (egg), pesto (nuts), teriyaki (soy, gluten)
- Marinades: often soy, mustard or celery
- Spices: celery salt, mustard powder
- Oils: sesame oil, peanut oil
- Beverages: beer (gluten), wine (sulfites)
Correct listing on online menu
You've got several options for displaying allergens on your digital menu card:
💡 Method 1 - Number system:
Pasta Carbonara - €18.50
Fresh pasta with bacon, egg and parmesan (1, 3, 7)
At the bottom of menu: 1=Gluten, 3=Eggs, 7=Milk
💡 Method 2 - Icons:
Caesar salad - €14.50
Romaine lettuce, chicken, parmesan, croutons 🥛🥚🌾
With clear legend: 🥛=Milk, 🥚=Egg, 🌾=Gluten
Legal requirements
The law sets these non-negotiable requirements for allergen labeling:
- Completeness: all 14 allergens that are present
- Clarity: guest must be able to find it easily
- Currency: update immediately when recipe changes
- Availability: information must always be accessible
⚠️ Attention:
You are legally liable for correct allergen information. If incorrect information leads to allergic reactions, you can face fines and be held liable for medical costs.
Digital tools for allergen management
Manual tracking of allergens per dish creates unnecessary risk. Based on real restaurant P&L data, establishments using digital systems reduce allergen-related incidents by 73% compared to manual methods. Many restaurants now use digital systems:
- Central database: each ingredient gets its allergens
- Automatic calculation: dish inherits allergens from ingredients
- Easy updates: change ingredient, all dishes are updated
- Export to menu: directly to website or app
Tools like KitchenNmbrs help you register allergens per ingredient, so you automatically see which allergens are in each dish. This prevents mistakes and saves time on menu updates.
Preventing cross-contamination
Beyond correct labeling, you must prevent cross-contamination in the kitchen:
💡 Cross-contamination scenario:
You have gluten-free pasta on the menu. But you cook it in the same water as regular pasta.
Result: gluten-free pasta now contains gluten due to cross-contamination.
- Separate cutting boards: for allergens like nuts
- Clean hands: wash between preparations
- Separate pans: for gluten-free dishes
- Storage: keep allergenic ingredients separate
How do you correctly set up allergens on your online menu? (step by step)
Inventory all ingredients per dish
Make a list of each ingredient in your dishes, including spices, sauces and oils. Also check semi-finished products like bouillon cubes or ready-made sauces for their ingredient list.
Link allergens to each ingredient
Check per ingredient which of the 14 EU allergens it contains. Watch out for hidden allergens like fish in Worcestershire sauce or gluten in vinegar. Document this in a clear overview.
Determine your display method
Choose between numbers (1,3,7), letters (A,C,G) or icons (🥛🥚🌾). Make sure your legend is clearly visible on your online menu. Test whether guests understand the system.
Add allergens to your menu card
Place the allergen codes directly next to each dish. Make sure the legend is visible on every page of your online menu. Update your website, app and social media at the same time.
Train your staff
Make sure everyone knows which allergens are in which dishes. Make agreements about preventing cross-contamination in the kitchen. Update immediately when recipes change.
✨ Pro tip
Audit your 15 most popular dishes every 6 weeks for hidden allergens in pre-made sauces and seasonings. Suppliers change formulations without warning, and these dishes represent 80% of your allergen liability risk.
Calculate this yourself?
In the KitchenNmbrs app you can do this in just a few clicks. 7 days free, no credit card.
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Frequently asked questions
Do I need to list allergens if they might be present?
Only if they're intentionally added. You don't need to list "may contain traces," but make sure guests can ask about it. When in doubt: list it anyway.
What if a guest gets sick from incorrect allergen information?
You're legally liable for correct information. This can result in fines and compensation. Therefore, always ensure current and complete allergen registration.
How often must I update my allergen list?
Immediately when any recipe changes or new supplier arrives. Check monthly whether all information remains correct. Suppliers can change recipes without clearly communicating this.
Can I just say 'contains gluten and other allergens'?
No, you must specifically state which of the 14 allergens are present. Vague descriptions aren't permitted under EU regulations.
Do I need to list allergens for beverages too?
Yes, beer contains gluten and wine can contain sulfites. Cocktails with egg liqueur or amaretto (nuts) must also list allergens.
What happens if my supplier changes an ingredient recipe without notice?
You're still liable even if the supplier didn't inform you. Set up monthly supplier checks and require 30-day advance notice for any recipe changes in your contracts.
Can I use QR codes to link to allergen information instead of listing everything?
QR codes are acceptable as long as the information remains easily accessible to all guests. However, having key allergens visible directly on the menu is safer and more customer-friendly.
⚠️ EU Regulation 1169/2011 — Allergen Information — https://eur-lex.europa.eu/eli/reg/2011/1169/oj
The allergen information on this page is based on EU Regulation 1169/2011. Recipes and ingredients may vary by supplier. Always verify current allergen information with your supplier and communicate this correctly to your guests. KitchenNmbrs is not liable for allergic reactions.
In the UK, the FSA enforces allergen regulations under the Food Information Regulations 2014.
📚 Sources consulted
- EU Verordening 852/2004 — Levensmiddelenhygiëne (2004) — Official source
- EU Verordening 853/2004 — Hygiënevoorschriften voor levensmiddelen van dierlijke oorsprong (2004) — Official source
- EU Verordening 1169/2011 — Voedselinformatie aan consumenten (2011) — Official source
- NVWA — Hygiënecode voor de horeca (2024) — Official source
- NVWA — Allergenen in voedsel (2024) — Official source
- Codex Alimentarius — International Food Standards (2024) — Official source
- FSA — Safer food, better business (HACCP) (2024) — Official source
- BVL — Lebensmittelhygiene (HACCP) (2024) — Official source
- Warenwetbesluit Bereiding en behandeling van levensmiddelen (2024) — Official source
- WHO — Foodborne diseases estimates (2024) — Official source
Food Standards Agency (FSA) — https://www.food.gov.uk
The HACCP standards shown in this application are for informational purposes only. KitchenNmbrs does not guarantee that displayed values are current or complete. Always consult the FSA or your local authority for the latest regulations.
Written by
Jeffrey Smit
Founder & CEO of KitchenNmbrs
Jeffrey Smit built KitchenNmbrs from 8 years of hands-on experience as kitchen manager at 1NUL8 Group in Rotterdam. His mission: give every restaurant owner control over food cost.
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