A guest asks whether the gnocchi contains celery. The kitchen switched stock base three weeks ago, the printed card still carries the old footnote numbers, and the chef who knows the new recipe is off today. That gap — between what the kitchen does and what the menu says — is where EU allergen rules for restaurants bite hardest. It looks like a printing problem. It is really a version control problem, which is why it is worth solving once rather than patching every season.
What Regulation 1169/2011 actually asks of you
Regulation (EU) No 1169/2011 — the Food Information to Consumers regulation, known in Germany as the LMIV — requires information on 14 defined allergens for non-prepacked food as well as packaged goods. Non-prepacked means everything you serve: the plate of pasta, the soup of the day, the cake at the counter, the cocktail at the bar. There is no small-business exemption, no food-truck exemption, none for a two-line lunch card chalked up at 11am.
Two details get underestimated. First, the information has to reach the guest before they decide and before money changes hands — not when the plate lands on the table. That covers phone orders, delivery listings and your website, not just the card in the room. Second, it has to describe what is genuinely in the dish, which means someone has gone through every component: the sauce, the marinade, the frying oil, the stock cube, the bread alongside. Member states set the mechanics. The duty itself is EU-wide and has been in force since December 2014.
The 14 allergens, and where they actually hide
Anyone in a kitchen can recite the list, and the list is not the hard part. The hard part is the second-order ingredient — the thing inside the thing — because that is where mistakes live. Here is the full set, with the places each turns up when nobody is looking.
- Cereals containing gluten — wheat, rye, barley, oats, spelt, kamut. Beyond bread: roux-thickened sauces, soy sauce, beer batter, sausage bound with rusk, the flour dusting on a pan-fried fish.
- Crustaceans — obvious in a prawn cocktail, invisible in a shellfish bisque used as a sauce base, in the shrimp paste inside a Thai curry, in XO sauce.
- Eggs — mayonnaise and every aioli built on it, fresh pasta, the glaze brushed onto pastry, most ice creams, egg white used to clarify a consommé.
- Fish — Worcestershire sauce and Caesar dressing both carry anchovy. So does most South-East Asian fish sauce, and some kimchi.
- Peanuts — satay, some cold-pressed oils, praline fillings, a long tail of desserts. Peanut is a legume, so it stands separate from tree nuts.
- Soybeans — soy sauce, tofu, miso, edamame, lecithin in chocolate, the emulsifier in a great many burger buns.
- Milk — the butter finish on plain steamed vegetables, ghee, whey powder in bread, casein in some crisps and rolls, the parmesan hiding in a pesto.
- Nuts — almond, hazelnut, walnut, cashew, pecan, Brazil, pistachio, macadamia. Pesto, praline, nut oils used to finish a plate, nut flours in gluten-free baking.
- Celery — the quiet one, and the one most often missed. Stock cubes and bouillons, the mirepoix under almost every sauce, celery salt in spice blends, a Bloody Mary.
- Mustard — vinaigrettes, mayonnaise, curry powders, marinades, most German sausage.
- Sesame — burger buns, hummus and anything built on tahini, gomashio, the crust of many breads.
- Sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre — wine, dried fruit, some processed potato products, pickled vegetables, semi-dried tomatoes.
- Lupin — in gluten-free flour blends and some breads and pastas. Rare on a menu, which is exactly why it gets skipped.
- Molluscs — mussels, clams, squid, octopus, snails, the oyster sauce in a stir-fry.
The regulation does not settle cross-contamination for you. Traces from a shared fryer or board sit outside the mandatory declaration, and a blanket 'may contain everything' line tells an allergic guest nothing. Say in plain language what you can and cannot separate in your kitchen, and let the guest decide.
Written information or a verbal answer? The condition kitchens miss
This is where good restaurants get caught. Most people have heard that staff may answer verbally and stop reading there. The permission is real, but the strings attached to it are the actual rule.
Germany implements the EU regulation through the LMIDV, and the shape of it is this: written documentation of the allergens in each dish must exist, it must be available to the guest on request, and a clearly visible notice must tell guests that information is given verbally and that the written record can be seen. Miss the notice or miss the record, and the verbal answer alone does not satisfy the rule. Spain takes a comparable line through Real Decreto 126/2015, allowing oral information only where additional conditions keep it verifiable and documented.
A practical conclusion falls out of that: the written record has to exist either way. Once it exists, there is little reason to leave it in a folder behind the bar rather than put it where guests actually look — on the menu, next to the dish. The verbal route is not a shortcut. It is the same work, plus a notice, plus a folder someone keeps current.
Allergens are not additives — two labelling systems on one card
Guests and staff blur these two constantly, and the numbering on old printed cards is why. Allergen information under 1169/2011 is one system. Additive declaration is a separate, nationally set one — in Germany it produces its own fixed phrases for the card: mit Farbstoff, mit Konservierungsstoff, mit Geschmacksverstärker, mit Phosphat, mit Süßungsmittel, geschwefelt, koffeinhaltig, chininhaltig. A cured ham, a cola, a jar of olives and a dried-fruit compote can each trigger one, and none of them is an allergen declaration.
Requirements differ by member state, so check what applies where you trade. The design lesson holds everywhere: keep the two apart. Allergens read best as clear per-dish badges; additive phrases belong on their own line, not merged into the same pile of superscript digits. That merge is how a guest ends up believing number 4 means nuts when it means colouring.
What an inspector actually looks at
An allergen check during a routine food safety inspection is fast and fairly predictable. It usually runs through the same handful of things.
- Is the guest-facing notice present, legible and in the right place — not taped inside a menu holder nobody opens.
- Does a written record exist for every dish currently sold, including specials and whatever was added this morning.
- Does the record match the kitchen. Expect a spot-check: one dish at random, then a question about the sauce.
- Can whoever is on shift answer without guessing. Two staff saying the same thing beats one saying it well.
- Is the information reachable before ordering — takeaway flyers, delivery listings and the website included.
- When was it last updated. A record untouched since a supplier change is the finding they write down.
Penalties are set nationally and vary by region, so ignore any figure quoted without a source. A first finding more often ends in a written objection with a deadline and a follow-up visit. The genuinely expensive scenario is not the inspection — it is a guest with a serious allergy who was told the wrong thing.
Why the printed footnote system keeps failing
The classic card carries superscript numbers next to each dish and a legend in six-point type at the bottom. On the day it is printed it works perfectly. Then a supplier substitutes a stock base, the sous chef swaps a thickener, a dish comes off and another goes on — and correcting the card means reprinting and re-laminating fifty covers. So nobody reprints. The legend gets patched with a marker, the new dish goes on a chalkboard with no allergen line, and over a season the card and the kitchen drift apart. None of that is negligence. It is what happens when the record of a changing thing is printed on something that cannot change.
How a digital menu keeps allergen information current
A digital menu closes that gap, because the guest reads a page you can still edit rather than paper you already handed out.
- Allergens are tagged per dish and shown as readable badges — the word celery, not the digit 9 that a guest has to decode from a legend.
- Change a recipe, update the tag once, and everyone who scans from that moment sees the correct version. No outdated cards stay in circulation.
- On yourmenu.app the printed QR code encodes a permanent short link rather than the menu address, so you can rename the menu, redesign it or move it to a custom domain and the codes already on your tables keep working.
- Run out mid-service and you mark the dish sold out from your phone; it greys out live.
- Dietary badges — vegan, vegetarian, halal — ride along the same structure, so the guest checks one place.
- Allergen tagging is part of the free plan on yourmenu.app. Compliance work is not something to put behind a paywall.
Two honest limits. AI translation sits on the Premium plan and every string stays hand-tunable, which matters most here — allergen vocabulary is the one place to read the output word by word, because 'nuts' and 'peanuts' are legally different things in every language. More important: no tool knows your kitchen. The menu shows what you tell it. Your team still has to be trained, and the digital card is the always-current reference the team and the guest finally read from together.
Moving your current card over, without losing a service
The migration is one focused afternoon, and it goes far better in this order than dish by dish as they come to mind.
- Start from the current card. Upload a photo or PDF and let the AI extraction draft the sections, dishes, prices and descriptions, then review that draft instead of typing from a blank page.
- Break every dish into components, not headline ingredients: sauce, marinade, garnish, frying medium, stock base, side bread.
- Pull spec sheets for every bought-in compound product. Stocks, dressings, buns, sausage, pickles and dried fruit hold the surprises.
- Tag each dish, and check the awkward group first — celery, mustard, sulphites and sesame catch out more kitchens than gluten ever does.
- Write your cross-contamination position in one plain sentence, and make sure the floor team says that same sentence.
- Brief the team on where the record now lives, then scan the code yourself from a guest's seat.
- Set a rhythm: re-check on any supplier change, any recipe change, every seasonal card change. Fifteen minutes, not a project.
Allergen information is the part of a menu where being roughly right is worth nothing. It is also that rare compliance job that gets easier once you stop printing the answer and start maintaining it. Build a complete menu with allergen tags on the free plan at yourmenu.app, print one permanent QR code, and every guest sees the current version before they order.