Menu Allergens: Legal Requirements and How to Manage Them

Quick answer

Across the EU (and mirrored in UK law), you must declare the presence of the 14 allergens in Annex II of EU Regulation 1169/2011 in any dish that contains them. The information must be in writing and accessible to the customer before they order: on the menu, in a consultable register, or on a visible sign. A verbal-only answer is not enough. Fines reach into the thousands, but the real risk is clinical: anaphylactic shock can be fatal.

The law in two lines: what actually matters

The foundation is EU Regulation 1169/2011 on food information to consumers. For food service (non-prepacked food served at the table or for takeaway) the operating rule is this:

• you must indicate which of the 14 allergens are present in each preparation;
• the information must be written and accessible before the customer orders;
• the format is flexible (menu, register, sign, QR code) as long as it is clear, legible and kept up to date.

You are not obliged to print everything on the paper menu: you can keep an allergen register in the kitchen, provided a visible sign tells customers they can ask for it. But note: the information must be available at the time, not "I'll let you know tomorrow."

The 14 allergens you must declare

This is a closed list that applies across the EU. Learn it by heart: these and only these are mandatory.

| # | Allergen | Typical hiding spots in the kitchen | |---|----------|--------------------------------------| | 1 | Cereals containing gluten | Wheat, spelt, barley, rye: bread, pasta, breadings, flour-thickened sauces | | 2 | Crustaceans | Prawns, langoustines, crab, lobster | | 3 | Eggs | Mayonnaise, fresh pasta, desserts, batters | | 4 | Fish | Fillets, fish stock, gelatine, some sauces (Worcester) | | 5 | Peanuts | Peanut oil, Asian sauces, snacks | | 6 | Soybeans | Soy sauce, lecithin, plant-based products | | 7 | Milk | Butter, cream, cheese, lactose, béchamel | | 8 | Tree nuts | Almonds, hazelnuts, walnuts, pistachios, cashews | | 9 | Celery | Stocks, bouillon cubes, mirepoix, some sauces | | 10 | Mustard | Dressings, condiments, some cured meats | | 11 | Sesame seeds | Bread, hummus, ethnic dishes | | 12 | Sulphur dioxide and sulphites | Wine, dried fruit, preserved products (over 10 mg/kg or mg/l) | | 13 | Lupin | Alternative flours, vegan products | | 14 | Molluscs | Mussels, clams, squid, octopus, snails |

The most common mistake is forgetting "hidden" allergens: celery in stock, mustard in a vinaigrette, sulphites in the wine used for a reduction, milk in a breading. It's rarely the obvious dish that causes the incident; it's the ingredient inside an ingredient.

How to display allergens: the three valid options

You have three compliant routes. Pick the one your operation can actually sustain:

1. On the menu next to each dish. Maximum transparency, but the menu must be updated every time a recipe changes. Use numbered symbols (1-14) with a legend, or plain text.
2. A consultable allergen register. A folder or tablet with a sheet per dish listing its allergens. You must display a sign telling customers it exists.
3. A single sign. Suitable for venues with a small, fixed menu. It must be clearly visible and complete.

In all cases, add a line directing customers to staff for specific requests, but again: verbal answers supplement the written record, they don't replace it.

Cross-contamination: the problem the law won't solve for you

Declaring ingredients is the bare minimum. The real operational risk is cross-contamination: traces of an allergen ending up in a dish that "shouldn't" contain it. The same fryer for battered fish and chips, one board used for bread and then for the coeliac's salad, a ladle moving from béchamel to the vegan plate.

For a customer with a severe allergy, even a few milligrams can trigger a reaction. The law lets you use the precautionary statement "may contain traces of...", but only when the risk is genuine. Slapping it on everything to cover yourself is counterproductive: it makes the information useless and won't protect you if a supposedly "clean" dish causes a reaction.

Minimum anti-contamination procedure:

• dedicated equipment, or thorough washing, for allergen-free preparations;
• work order: prepare the allergen-free items first, then the rest;
• separate, closed and labelled storage;
• service briefing: when an "allergy" order comes in, the workflow changes.

What to do when a customer declares an allergy

This is the critical moment. Standardise it like an HACCP checklist:

1. Whoever takes the order stops and asks which allergen (not "is it serious?" but "exactly what?").
2. Check the register or menu, never from memory.
3. Flag the kitchen with a clear signal (a ticket marked "ALLERGY + allergen name").
4. The kitchen applies its dedicated procedure.
5. The dish leaves identified and is handed to that customer with verbal confirmation.

A quick numerical example of the risk: a standard 60 g portion of sauce containing 1% of a milk-based thickener holds about 600 mg of milk protein. For a highly allergic person the reaction threshold can be below 10 mg. That's 60 times over the limit, which is why "I only used a tiny bit" is no defence.

Common mistakes

• Verbal-only declarations. The most-penalised failure: you always need a written backup.
• Out-of-date menu. You change the recipe but not the allergen document, the information becomes false and your liability grows.
• "May contain traces" on everything. It drains the warning of meaning and won't protect you.
• Ignoring hidden allergens. Celery in stocks, sulphites in wine, gluten in thickened sauces.
• Untrained staff. If the server doesn't know where to look, the system collapses at the decisive moment.
• No anti-contamination procedure. Labelling perfectly and then frying everything in the same oil is an own goal.

Related resources

To build a robust allergen system, integrate it into your wider food-safety setup. Worth reading next:

• What Is HACCP and How a Food Safety Plan Works
• HACCP Plan: Step by Step