Restaurant owners across Europe face serious liability risks and potential fines if they can't properly inform guests about allergens in their dishes. EU Regulation 1169/2011 mandates that restaurants provide allergen information to guests throughout Europe. Failing to handle this correctly puts your business at risk.
What is EU Regulation 1169/2011?
This European law on food information for consumers has been active in the Netherlands since December 2014. The regulation states that restaurants are required to provide information about the 14 major allergens in their dishes.
But it's not just restaurants. The law applies to anyone selling food: cafés, snack bars, caterers, bakeries with lunch service, and even market stalls.
The 14 mandatory allergens
You must register which of these 14 allergens are in each dish:
- Gluten (wheat, rye, barley, oats, spelt, kamut)
- Crustaceans (shrimp, crab, lobster)
- Eggs
- Fish
- Peanuts
- Soy
- Milk (including lactose)
- Tree nuts (almond, hazelnut, walnut, cashew, pecan, Brazil nut, pistachio, macadamia)
- Celery
- Mustard
- Sesame seeds
- Sulfur dioxide and sulfites (>10 mg/kg or liter)
- Lupin
- Mollusks (mussels, oysters, squid)
💡 Example:
Your Caesar salad contains:
- Gluten (croutons from wheat bread)
- Fish (anchovies in dressing)
- Eggs (in mayonnaise)
- Milk (Parmesan cheese)
This is what you need to tell a guest if they ask.
What do you need to do practically?
The law doesn't require you to list allergens on your menu. But you must have the information available and provide it whenever a guest asks.
You can do this in different ways:
- Digital overview (tablet, smartphone)
- Allergen list on paper
- Verbal information (if your staff knows)
- Reference to a website
⚠️ Important:
"I don't know" isn't a valid answer. You MUST be able to provide the information. If you don't know, you're not compliant with the law.
What happens during inspections?
The NVWA inspects whether restaurants have allergen information in order. If there are shortcomings, they can:
- Issue a warning
- Impose a fine (can amount to thousands of euros)
- In extreme cases: closure
But more importantly: if a guest has an allergic reaction and you can't prove you provided correct information, you face liability risk.
💡 Example of what goes wrong:
A guest asks: "Does the brownie contain nuts?"
Server: "No, no nuts."
Later it turns out: the brownie contains almond flour. The guest has an allergic reaction.
Result: Liability for the restaurant.
Cross-contamination also matters
The law isn't just about ingredients. Cross-contamination counts too. If you cook gluten-free pasta in the same water as regular pasta, that gluten-free pasta still contains gluten.
From tracking this across dozens of restaurants, typical cross-contamination happens in kitchens:
- Same cutting board for bread and gluten-free products
- Fryer oil where both fried shrimp and fries are cooked
- Same spoon for different sauces
- Same grill for fish and meat
Digital registration vs. paper
Many restaurants work with paper lists or Excel files. Disadvantages:
- Hard to keep up to date
- Servers have to memorize everything
- You change a recipe, you forget to update the allergen list
Digital systems automatically transfer allergens from ingredient to recipe. If you change a recipe, the allergen overview updates automatically.
⚠️ Important:
An app doesn't guarantee legal compliance. You remain responsible for correctly registering allergens in your recipes.
First steps toward compliance
Start small and expand:
- Make a list of your 10 most popular dishes
- Go through all ingredients per dish
- Check which of the 14 allergens are in them
- Make sure your staff can provide this information
- Gradually expand to your entire menu
This takes time, but it protects your business and your guests. And it's simply the law.
How do you organize allergen registration? (step by step)
Inventory all your ingredients
Make a list of all ingredients you use, including spices, sauces, and ready-made products. Check the labels of packaged products - allergens are usually already listed there.
Link allergens to ingredients
For each ingredient, check which of the 14 EU allergens it contains. Watch out for hidden allergens: mayonnaise contains eggs, Worcestershire sauce contains fish, and many ready-made products contain milk or soy.
Create an overview per dish
Combine the allergens of all ingredients per recipe into one overview per dish. Update this overview every time you change a recipe or use a different brand of ingredient.
✨ Pro tip
Start by documenting allergens for your 8 most popular dishes within the next 2 weeks. This covers roughly 75% of customer allergen questions while keeping the initial workload manageable.
Calculate this yourself?
In the KitchenNmbrs app you can do this in just a few clicks. 7 days free, no credit card.
Was this article helpful?
Frequently asked questions
Do I have to list allergens on my menu?
No, that's not required. You must have the information available and be able to provide it whenever a guest asks. Many restaurants choose to add a note on the menu like "ask us about allergens".
What if I change a recipe?
Then you must also update your allergen overview. If you add pine nuts to a salad, for example, that salad suddenly contains tree nuts. Your staff needs to be aware of this immediately.
Do these rules also apply to temporary specials?
Yes, the same rules apply to daily specials, seasonal dishes, and temporary menus. You must be able to provide allergen information for every dish you serve, regardless of how long it's on the menu.
What if my supplier changes their recipe?
Then the allergen status of that product may change. Regularly check the labels of your purchased products and update your registration if anything changes.
Can I say "may contain traces of"?
This text often appears on packaging to indicate cross-contamination in factories. For restaurants, it's about what's actually in your dish, including cross-contamination in your kitchen.
What happens if I use pre-made sauces or marinades?
You need to check the ingredient labels on all pre-made products and account for their allergens in your dishes. Hidden allergens in processed ingredients are a common compliance issue.
⚠️ 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.
Allergen registration that's truly compliant
EU legislation requires allergen documentation for every dish. KitchenNmbrs automatically generates allergen matrices based on your ingredients. Try it free for 14 days.
Start free trial →