If you run a restaurant, cafe, bar or hotel anywhere in the European Union, you must tell guests whether your dishes and drinks contain any of 14 allergens. That duty comes from Regulation (EU) No 1169/2011 on food information to consumers, which has applied since 13 December 2014. It covers food that is not prepacked, which means almost everything you serve. What changes from country to country is how you give the information. This guide explains the EU rule, the 14 allergens, real national examples, whether a QR menu counts, and what the new wine e-labels mean for bars.
Allergen information is mandatory for every dish and drink you serve (Article 44(1)(a)). The EU leaves the format to each member state (Article 44(2)). Some countries demand written information, others allow oral information with conditions. Written, dish-by-dish information is the safest approach everywhere.
What Regulation (EU) 1169/2011 says about allergens
The regulation, often called the FIC or INCO Regulation, sets the basic labelling rules for food sold in the EU. Three provisions matter most for hospitality:
- Article 9(1)(c) makes it mandatory to indicate any ingredient or processing aid listed in Annex II, or derived from one, that is used to make the food and is still present in the finished product, even in an altered form.
- Article 21 sets how allergens appear on prepacked food: emphasised in the ingredients list, for example in bold. If you sell prepacked items, such as bottled sauces under your own brand, this applies to their labels.
- Article 44 covers non-prepacked food. Paragraph 1(a) says the allergen particulars are mandatory. Paragraph 2 lets member states adopt national measures on the means through which this information is made available and how it is presented. Paragraph 3 requires them to notify the Commission of those measures.
There is one more point for delivery and online ordering. Under Article 14, when non-prepacked food is sold by distance communication, the allergen information must be available before the purchase is concluded, at no extra cost to the customer. Your website, ordering app or delivery platform listing needs allergen information, not just your dining room.
The 14 allergens in Annex II
These are the 14 substances or products causing allergies or intolerances that you must declare. The legal text includes exemptions for some highly processed derivatives, such as wheat-based glucose syrups, fully refined soybean oil or whey used to make distillates for spirits, so check Annex II if a borderline ingredient comes up.
The list is the same in the UK, which kept these rules after Brexit. If you also operate there, see our guide to UK restaurant menu rules on calories and allergens.
How member states apply Article 44: five examples
Because Article 44(2) leaves the format to national law, the same dish can be compliant in one country and not in another. These examples are taken from national legislation and food authority guidance:
The pattern is clear. No country lets a restaurant stay silent. Where oral information is allowed, there is almost always a written backup behind it and a sign telling guests to ask. If you trade in a country not listed here, check the national food authority's guidance before you design your menu.
Can allergen information be oral, digital or on a QR code?
Oral: only where national law allows it, and usually with conditions. Germany, Spain and the Netherlands accept it with a written record and a visible notice. France and Ireland require written information.
Digital: the EU regulation itself does not rule out electronic formats. Germany's LMIDV explicitly lists electronic information provided by the business, as long as it is directly and easily accessible and guests are told where to find it. Ireland's FSAI accepts allergen information in hard copy or electronic format if it is easy to find and legible.
QR code menus: a QR menu is a digital format, so the same conditions apply. It should be easy to reach from the table, show allergens for each dish, and be in place before the guest orders. Two habits make a QR menu safer from a compliance point of view:
- Keep a paper backup. Some guests do not have a smartphone, and Wi-Fi or mobile data can fail. A printed allergen matrix behind the counter covers both cases.
- Signpost it. Add a short line near the QR code, such as "Allergen information for every dish is in our menu. Please ask staff if you have any allergy."
For a wider look at what digital menus must show, read our article on QR code menu legal requirements.
Wine e-labels and QR codes: what bars need to know
Since 8 December 2023, wine has had its own labelling change. Regulation (EU) 2021/2117 amended the EU common market organisation rules so that wines produced from that date must carry an ingredients list and a nutrition declaration. Producers can show only the energy value on the physical label and provide the full nutrition declaration and ingredients list electronically, typically through a QR code on the bottle. Wines produced before that date can be sold until stocks run out.
Allergens are the exception to the electronic option. Under Delegated Regulation (EU) 2023/1606, when the ingredients list is given electronically, substances causing allergies or intolerances, such as sulphites or egg and milk products used as fining agents, must still appear on the physical label. The Commission published a question-and-answer notice on these rules in November 2023.
What changed in 2026
The "wine package", Regulation (EU) 2026/471, was published in the Official Journal on 26 February 2026. It harmonises the terms used for lower-alcohol and alcohol-free wine, including the new term "low-alcohol", and gives the Commission powers to set harmonised rules for electronic labelling of ingredients and nutrition information. The detailed rules are being prepared in follow-up acts, so watch for changes in how e-labels on bottles look.
Why this matters at the bar
The e-label is the producer's job and lives on the bottle. Your job is what you serve. Wine by the glass, cocktails, draught beer and coffee drinks are non-prepacked, so Article 44 applies to them like any dish. Typical traps behind the bar include:
- Sulphites in wine, cider and some mixers, above the 10 mg per litre threshold.
- Egg white in sours, milk in cream liqueurs and coffees, and nuts in almond syrups and nut liqueurs.
- Cereals containing gluten in beer, plus celery in some Bloody Mary mixes.
One more point: drinks above 1.2% alcohol by volume are exempt from the general ingredients list and nutrition declaration under Article 16(4) of Regulation 1169/2011. That exemption does not extend to allergens.
"May contain" warnings are currently voluntary in the EU and not harmonised. The Commission has started work on common rules for precautionary allergen labelling, but the timeline is still open. Until then, use such warnings only where there is a real cross-contact risk, and never as a blanket disclaimer.
Practical steps: get your allergen information right
Most of this work happens once. After that, you only update it when a recipe or supplier changes.
- 1List every item you sell โ Food, drinks, sauces, sides, specials, desserts and anything on the bar. Include items that only appear on a chalkboard.
- 2Collect recipes and supplier labels โ Allergens often hide in bought-in products: stocks, spice mixes, syrups, liqueurs, bread and sauces.
- 3Map each item against all 14 allergens โ Use an allergen matrix. Name the specific nut or cereal where you can, for example "nuts (almond)" rather than just "nuts".
- 4Check your country's rules on format โ Written or oral, on the menu or in a separate booklet, paper or digital. Follow the national measure where you trade.
- 5Publish it where guests choose โ On the menu, next to the dish, or one clear step away with a visible notice telling guests where to find it.
- 6Train staff and review regularly โ Staff should know where the information is, never guess, and update it every time a recipe or supplier changes.
The hardest part is keeping information consistent across the printed menu, the allergen matrix, the website and delivery platforms. A digital menu you edit in one place reduces that risk. With MenuMan, for example, you can upload a photo of your menu and AI turns it into a multilingual QR menu with suggested allergens, ingredients and calories. You review and confirm every suggestion, because only your kitchen knows exactly what goes into each dish. The free plan includes 10 AI credits. If you are still comparing tools, our roundup of the best QR code menu apps for 2026 may help, and our menu compliance guide for the UK, EU and US covers prices and calories too.
Frequently asked questions
Do restaurants in the EU have to declare allergens even though their food is not prepacked?+
Yes. Article 44(1)(a) of Regulation (EU) 1169/2011 makes the allergen particulars of Article 9(1)(c) mandatory for non-prepacked food, which includes dishes served in restaurants, cafes, bars and canteens. Most other labelling particulars are optional for non-prepacked food unless a member state requires them.
Are there really only 14 allergens?+
There are 14 groups listed in Annex II of the regulation. Several groups are broad: "nuts" covers eight tree nuts and "cereals containing gluten" covers several grains. Some derived products are exempt, such as wheat-based glucose syrups or fully refined soybean oil. Guests may of course have other allergies, and it is good practice to help them where you can.
Can I tell guests about allergens verbally?+
It depends on the member state. Article 44(2) lets each country decide how the information is made available. France and Ireland require it in writing. Germany, Spain and the Netherlands allow oral information under conditions, such as a written record on site and a visible notice.
Is a QR code menu enough to meet EU allergen rules?+
The EU regulation does not ban digital formats, and Germany and Ireland explicitly accept electronic information that is easy to access. Rules vary by country, though, so keep a paper allergen matrix or printed menu as a backup for guests without a smartphone, and add a visible notice that tells guests where to find the information.
Does the wine e-label rule mean I must list ingredients for wine by the glass?+
No. The e-label rules apply to the labelling of wine products placed on the market, mainly the bottle. Wine served by the glass is non-prepacked, so the general allergen rule applies: if it contains sulphites above 10 mg per litre, guests must be informed in the way your national rules require.
Official sources
- Regulation (EU) No 1169/2011 on the provision of food information to consumers (EUR-Lex) โ
- European Commission: Food information to consumers legislation โ
- Regulation (EU) 2021/2117 amending the CMO Regulation, incl. wine labelling (EUR-Lex) โ
- Regulation (EU) 2026/471, the 2026 wine package (EUR-Lex) โ
- Germany: Lebensmittelinformations-Durchfรผhrungsverordnung (LMIDV), ยง 4 โ
- France: Dรฉcret nยฐ 2015-447 du 17 avril 2015 (Lรฉgifrance) โ
- Spain: Real Decreto 126/2015 (BOE) โ
- Ireland: FSAI, Allergen information for non-prepacked food โ
- Netherlands: Ondernemersplein, Voedselveilig werken โ
This article is general information, not legal advice. National rules change, so check with your local food authority if you are unsure.
Bottom line: all 14 allergens, for every dish and drink, before the guest orders, in the format your country requires. Written information with a friendly "any allergies?" from staff works everywhere in the EU.


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