EU law requires restaurants to identify specific allergens in every dish since 2014. A generic disclaimer won't cut it legally. You need precise allergen information for each menu item.
The 14 mandatory allergens
Europe mandates 14 allergens that restaurants MUST identify when present in dishes. This list applies to all Dutch restaurants:
- Gluten (wheat, rye, barley, oats, spelt, kamut)
- Crustaceans (shrimp, lobster, crab)
- Eggs (also in sauces and pasta)
- Fish (also in Worcestershire sauce)
- Peanuts (also peanut oil)
- Soy (also soy sauce and tofu)
- Milk (including lactose, butter, cheese)
- Tree nuts (almond, hazelnut, walnut, cashew, pecan, brazil nut, pistachio, macadamia)
- Celery (also celery salt)
- Mustard (also mustard powder)
- Sesame seeds (also sesame oil)
- Sulfur dioxide and sulfites (>10 mg/kg, often in wine)
- Lupin (bean, sometimes in flour)
- Mollusks (mussels, squid, snails)
⚠️ Note:
Generic warnings like "This dish may contain traces of nuts" don't meet legal standards. You must identify specific allergens in each dish.
What needs to be on your menu?
You've got 3 ways to communicate allergen information:
- Option 1: List all allergens for each dish directly on the menu
- Option 2: Reference a separate allergen card or detailed list
- Option 3: "Ask us about allergens" + provide verbal information
Most establishments go with options 2 or 3 since option 1 creates cluttered menus.
💡 Example menu note:
At the bottom of your menu:
"Have an allergy or dietary requirement? Ask our staff about ingredients. We'll gladly inform you about the 14 legally required allergens."
How do you register allergens per dish?
Each dish requires allergen tracking through this process:
- Examine every ingredient for allergen content
- Compile all allergens from recipe components
- Document findings in a dish-by-dish overview
💡 Example: Pasta Carbonara
- Pasta: Gluten (wheat)
- Eggs: Eggs
- Bacon: no allergens
- Parmesan: Milk
- Butter: Milk
Allergens in this dish: Gluten, Eggs, Milk
Hidden allergens to watch out for
Allergens lurk in unexpected places. From years of working in professional kitchens, I've seen these trip up even experienced chefs:
- Gluten: in soy sauce, certain bouillon cubes, beer
- Fish: in Worcestershire sauce, Caesar dressing
- Eggs: in mayonnaise, pasta, marzipan
- Milk: in dark chocolate, some margarines
- Sulfites: in wine, dried fruit, shrimp
⚠️ Note:
Always verify ingredient lists from suppliers. Manufacturers change recipes without warning, introducing allergens that weren't previously present.
Digital vs. paper registration
Allergen tracking works on paper or digitally. But digital systems offer clear advantages:
- Automatic ingredient-to-dish conversion
- Fast lookups during busy service periods
- Simple updates when suppliers modify products
- No misplaced documentation
Digital platforms can streamline allergen registration per ingredient and dish. However, accuracy remains your responsibility - software can't verify your data entry.
💡 Example digital system:
You input allergens once per ingredient:
- Parmesan → Milk
- Wheat flour → Gluten
- Eggs → Eggs
The system auto-calculates dish allergens based on your recipes.
What happens during an inspection?
NVWA inspectors regularly audit restaurant allergen compliance. Violations result in:
- Warning: for first-time and minor violations
- Fine: for repeat or serious infractions
- Closure: when public health faces immediate danger
More critically: if guests suffer allergic reactions and you can't prove proper disclosure, you face significant liability exposure.
How do you set up allergen registration? (step by step)
Create an ingredient list with allergens
Go through all your ingredients and note which of the 14 allergens are in each one. Check the labels from your suppliers and ask for ingredient lists if in doubt. This is the foundation of your entire system.
Link allergens to your recipes
For each dish, add up all the allergens from all ingredients. A pasta carbonara, for example, has gluten (pasta), eggs (egg) and milk (cheese and butter). Record this per dish in an overview.
Train your staff and communicate with guests
Make sure your service staff knows where to find allergen information and how to communicate it. Note on your menu that guests can ask about allergens. Update your list every time you change recipes or suppliers.
✨ Pro tip
Focus on your 7 signature dishes first and map their allergens completely within 2 weeks. This covers most customer inquiries while you systematically add remaining menu items.
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 all 14 allergens on my menu?
No, only list allergens actually present in your dishes. But you must identify all 14 when guests inquire about specific items.
What if I'm uncertain whether an ingredient contains allergens?
Treat it as 'possibly present' and inform the guest. Request detailed ingredient lists from suppliers or source products with clear allergen information.
Can I just use 'may contain traces' on my menu?
No, that doesn't meet legal requirements. You must identify specific allergens in each dish rather than using generic disclaimers.
How often should I update my allergen information?
Update whenever you modify recipes, change suppliers, or suppliers alter their ingredients. Review quarterly at minimum to catch any changes.
What happens if I miss listing an allergen?
Guest illness creates liability exposure for your business. NVWA can also impose fines for non-compliance with allergen regulations.
Do cooking methods affect allergen requirements?
Cooking doesn't eliminate allergen labeling requirements. Even if proteins break down during preparation, you must still declare original allergen sources.
⚠️ 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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