EU Regulation 1169/2011: The Practical Allergen Guide for Restaurants

Since December 2014, EU Regulation 1169/2011 has required every food business — including restaurants, cafés and bistros — to provide allergen information for non-prepacked food. More than a decade later, spot checks across the EU still find a large share of menus non-compliant. Here is what the regulation actually demands, without the legal fog.

The 14 allergens you must declare

The regulation names fourteen substances: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphur dioxide and sulphites (above 10 mg/kg), lupin, and molluscs. If a dish contains any of them — including in stocks, marinades, garnishes or frying oil — the guest must be able to find that out before ordering.

What "providing information" means in practice

Member states implement the details differently, but the common baseline is: the information must be available in written form or reliably provided by trained staff, it must be accurate for the dish as actually prepared, and it must be accessible before the sale. In the Czech Republic, the established practice is numbered allergen labels (1–14) printed next to each menu item — the same numbering ProMenu uses.

The myths that cause fines

• •"A general disclaimer is enough." It is not. A sentence like "our dishes may contain allergens, ask the staff" does not replace per-dish information if staff cannot actually answer accurately.
• •"Only main ingredients count." Wrong — a celery-based stock or sesame oil in a dressing counts fully.
• •"Cross-contamination must be labeled." Actually no — the regulation covers deliberate ingredients. "May contain traces" statements are voluntary, but honesty here builds trust with allergic guests.
• •"The chef knows, so we're covered." Only if that knowledge is transferred to every server on every shift — which in practice means writing it down.

Why paper menus keep failing audits

Recipes drift. A supplier substitutes a pesto with cashews for one with pine nuts; the printed menu stays the same for months. The failure mode of paper is silent divergence between the kitchen and the menu. A digital menu fails differently — and better: you update the dish once, and every QR code on every table serves the corrected version instantly.

Making compliance a one-time job

The sustainable approach is to make allergen data part of the dish record, not a separate document. Each dish should carry its allergen numbers wherever it appears — menu, lunch menu, PDF export, translations. When ProMenu imports a menu, its AI suggests allergen labels per dish which you then verify against your recipes — the verification step is yours by law, but the bookkeeping stops being a job.

Takeaway

Allergen compliance is not a poster on the wall; it is per-dish, written, current information. Digitize the dish record once, verify it honestly, and the regulation turns from a recurring risk into a solved problem.