Allergens on the menu: what the law asks in six countries.

The 14 allergens.

Regulation (EU) No 1169/2011 lists them in its Annex II. Any of them, or an ingredient made from one, that is still in the finished dish has to be declared.^{1, 2, 3}

• Cereals containing gluten
• Crustaceans
• Eggs
• Fish
• Peanuts
• Soybeans
• Milk
• Nuts
• Celery
• Mustard
• Sesame seeds
• Sulphur dioxide and sulphites
• Lupin
• Molluscs

Not only packaged food.

The duty covers food sold without packaging too, which is what a restaurant serves. The European Commission says allergen information is mandatory there, and that each country may decide how it is given (Article 44 of the regulation).^{1, 2}

Country by country.

• Portugal. Decreto-Lei n.º 26/2016 asks food service to state the allergens in what it serves, on a medium the customer can take in easily. A dish’s name may wait until the customer asks, if how to ask is clearly shown; the allergens have no such exception.⁴
• Spain. Real Decreto 126/2015 asks for the information in writing, on labels or notices near the food. Staff may give it instead, if it is also recorded in writing or electronically on the premises, within reach of staff, inspectors and anyone who asks, and a notice says where it is or that staff can be asked.⁵
• France. The Code de la consommation (articles R412-12 to R412-16, from décret n° 2015-447) asks places that serve meals to give the information in writing, readable and visible, or to say how the written version can be consulted, directly and freely.⁶
• Italy. Decreto legislativo n. 231/2017 (article 19, paragraph 8) asks for each dish’s allergens before it is served, on the menu, a register, a notice or an equivalent system, digital included, kept in view. A digital system needs written documentation behind it, easy to find for the authority and the customer. Instead, the menu or a notice may send customers to staff, if the answer is in that written documentation.⁷
• Germany. The LMIDV (§ 4) accepts the information on a sign by the food, on the menu or price list, on a notice, or in another written or electronic form the customer can reach directly and easily. Staff may give it orally, on request and before the sale, if a written or electronic record of each dish’s ingredients is within reach of the authority and, on request, the customer, and a notice says the information is given orally and the record can be seen.⁸
• Ireland. S.I. No. 489 of 2014 asks for the allergens in writing, where the food is presented, sold or supplied, in English (or Irish and English), legible and easy to find before the sale. The Food Safety Authority of Ireland says a QR code, alone, does not meet the rule.³

What this means on a menu.

In all six, each dish’s allergens must be possible to find before the customer orders, in writing or with a written record behind them. Writing them on the menu, beside each dish, is the plainest way. Three of the six (Spain, Italy and Germany) let staff answer instead, always with a written record and a notice that says so.^{3, 4, 5, 6, 7, 8}

With Apronta.

Apronta’s menu has an allergens step: it suggests the 14 from each dish’s name and you confirm them one by one. The page will not publish while a dish has no answer, and the menu shows each dish’s allergens to whoever reads it on a phone. Apronta does not know your recipes: what you confirm is what the page says.

Where the law asks for the information in writing on the premises, print the menu or an allergen table as well: in Ireland, the QR code alone is not enough.³