Yes, QR code menus are legal in the UK, the EU and the US. No major market bans them. But a QR code is only a way to deliver information, and the law cares about the information itself: allergens, prices, calories, and whether every guest can actually get to it. A QR-only setup can fall short on some of those duties. This guide explains where, region by region, and ends with a checklist you can run through in ten minutes.
A QR menu is fine as your main menu. Keep three things alongside it: a printed price list at the entrance where local rules require one, a non-digital way to get allergen information, and a menu that works without sign-up or tracking. That covers most of the risk in all three regions.
This article is general information, not legal advice. Rules change and local enforcement varies. Check the official sources at the end, or ask your local authority or a lawyer about your specific situation.
Digital menu rules at a glance
The table summarizes what matters for a QR menu. The sections below explain each row.
| Topic | 🇬🇧 UK | 🇪🇺 EU | 🇺🇸 US |
|---|---|---|---|
| Allergens | Legal minimum: any means, with a sign if given verbally. FSA best practice: written info, paper or digital, plus a non-digital alternative. | Mandatory for loose food (Art. 44, Reg. 1169/2011). Each country decides the means. Ireland requires writing as a minimum. | Varies by state. The 2022 FDA Food Code model calls for written notice (physical or electronic). California SB 68 allows QR but requires a non-digital option. |
| Prices at the door | Price Marking Order 2003: prices at or near the entrance, visible before entering (up to 30 items, or at least 30). | Country rules. France and Germany both require a price display at or near the entrance. | No general federal rule. Local and state consumer rules may apply. |
| Calories | England: businesses with 250+ employees, at every point of choice, including online and app menus. | Not mandatory EU-wide for restaurants. | Chains with 20+ locations. FDA's definition of a menu includes electronic menus and menus on the Internet. |
| Accessibility | Equality Act 2010 duty to make reasonable adjustments. | European Accessibility Act from 28 June 2025 for e-commerce services. Microenterprises providing services are exempt. | ADA Title III. DOJ guidance (2022) points to WCAG. |
| Privacy | UK GDPR + PECR. Some analytics cookies can now run without consent under strict conditions. | GDPR + ePrivacy: consent for non-essential cookies and trackers. | State privacy laws (e.g. California). No single federal law. |
1. Allergens: does a QR menu count?
Allergen rules apply to almost every venue, whatever its size. Regulators generally accept digital formats; the catch is guests who can't use their phone.
UK: digital is allowed, but have a backup
In England, Wales and Northern Ireland, the legal minimum hasn't changed: information on the 14 regulated allergens must be available by any means, with a sign telling customers when it will be given verbally. The Food Standards Agency's best practice guidance (published February 2025) goes further. It says written allergen information should be easily available, ideally without guests having to ask, and supported by a conversation with staff.
On digital menus specifically, the FSA says businesses can choose paper or digital. If you go digital, you should also have an alternative way to access the information in case the digital version fails, and for people who may not be able to access it digitally. Online, allergen info should ideally be no more than one click away. So a QR menu with allergens on every dish is a good fit, as long as a printed allergen matrix or menu is behind the counter. For the details, see our UK menu rules guide.
EU: allergens are mandatory, the format is national
Under Article 44 of Regulation (EU) No 1169/2011, allergen information is mandatory for non-prepacked food, but each member state may set national rules on how it is made available. That is why the answer differs by country. Ireland, for example, requires allergen information in writing as a minimum. The Food Safety Authority of Ireland accepts hard copy or electronic format, but says customers must have the information before buying and must not have to ask for it. A QR code on every table can meet that. A QR code behind the counter that guests have to request probably can't. Our guide to the EU's 14 allergens covers what to declare.
US: state law, and a new California rule that names QR codes
There is no single federal allergen rule for restaurant menus. The 2022 FDA Food Code, a model that states can adopt, calls for written notification of major food allergens in unpackaged food, and it allows physical or electronic formats. Adoption varies by state and county.
California went further. SB 68, in effect since July 1, 2026, requires restaurant chains with 20 or more locations to disclose the nine major allergens for each menu item. The law explicitly allows a digital format, including a QR code, but chains that use it must also offer a non-digital alternative, such as an allergen menu, chart or booklet. Even if you are not covered, it is a sensible model to copy.
Online ordering and delivery
If guests order through your QR menu for delivery or collection, distance selling rules apply too. In the UK and EU (Article 14 of Regulation 1169/2011), allergen information must be available before the purchase is concluded and again at the moment of delivery, at no extra cost to the customer.
2. Prices: a QR code at the door is not a price list
This is where QR-only menus most often go wrong. Several countries require prices to be visible before the guest walks in, and a QR code on the door doesn't show any prices.
- UK: The Price Marking (Food and Drink Services) Order 2003 requires prices for an eating area to be shown at or near the entrance, so that a customer can see them before entering. If you offer up to 30 food items, all need a price; above 30, at least 30 (including five soft drinks if you sell them), plus five wines and each fixed-price meal.
- France: Under an order dated 27 March 1987, restaurants must display their menus or carte outside during service, including prices of a selection of wines or other drinks, according to the DGCCRF, the French consumer authority. Menus inside must match the ones outside.
- Germany: Section 13 of the Price Indication Ordinance (PAngV) requires a price list at the table, handed to guests before ordering, or clearly displayed, plus a price list next to the entrance showing the main food and drinks.
- US: There is no general federal rule on displaying restaurant prices at the door. State and local consumer protection laws still apply, especially to fees.
The practical fix is simple: a printed list in the window or by the door, and a QR menu inside that shows the same prices. Mismatched prices between channels are a common complaint. Mandatory charges are their own topic; see our guide to service charges and hidden fees.
3. Calories: covered businesses must show them on digital menus too
- England: Businesses with 250 or more employees must show calories at every point of choice. The government guidance says this covers electronic and online menus, and food sold through websites and apps.
- US: Chains with 20 or more locations must show calories on menus and menu boards, plus the statement that 2,000 calories a day is used for general nutrition advice. FDA's definition of a menu explicitly includes electronic menus and menus on the Internet. More in our FDA menu labeling guide.
- EU: No EU-wide calorie rule for restaurants. Adding calories voluntarily is allowed and increasingly expected by guests.
4. Accessibility: can every guest use your menu?
A QR menu that only works on a recent smartphone, with good eyesight, excludes some guests. Accessibility law is catching up with that.
EU: the European Accessibility Act
The European Accessibility Act (Directive (EU) 2019/882) applies from 28 June 2025. For hospitality, the relevant category is e-commerce services: broadly, services provided at a distance through websites or apps that lead to a consumer contract. A QR menu that lets guests order and pay looks much closer to that than a menu that only displays dishes. Two important limits:
- Microenterprise exemption: businesses providing services with fewer than 10 people and annual turnover or balance sheet total of €2 million or less are exempt from the accessibility requirements. That covers many independent restaurants and cafes.
- National law: each country transposed the directive itself, so details and enforcement differ.
US: ADA and WCAG
Title III of the Americans with Disabilities Act covers businesses open to the public, including restaurants. In March 2022 the Department of Justice published guidance confirming its view that the ADA applies to web content, and recommending existing standards such as the Web Content Accessibility Guidelines (WCAG). The guidance is not a regulation and courts have not all agreed on how far the ADA reaches online, but restaurant sites and apps have faced ADA lawsuits, including Robles v. Domino's.
UK: reasonable adjustments
The Equality Act 2010 requires service providers to make reasonable adjustments for disabled people. A printed or large-print menu, and staff who can read the menu out, are low-cost adjustments.
Real text instead of a scanned PDF image. Strong color contrast. Pinch-to-zoom that isn't disabled. Allergen icons with text labels, not color alone. Buttons a screen reader can name. And a printed menu for anyone who asks.
5. Privacy: when your QR menu tracks guests
A paper menu doesn't collect data. A QR menu is a web page, and it can. Privacy advocates have criticized QR menus that add ad trackers or ask for a phone number before showing the food.
- EU: GDPR applies to personal data such as emails, phone numbers, order histories and device identifiers. Under the ePrivacy rules, non-essential cookies and similar trackers generally need consent.
- UK: UK GDPR and PECR apply. Following the Data (Use and Access) Act 2025, some cookies used only for statistical purposes can be set without consent, but only if users get clear information and an easy way to object. The ICO says advertising cookies still need consent.
- US: There is no single federal privacy law, but state laws such as California's give consumers rights over their data and require a privacy notice.
The safest design: guests can view the full menu without logging in, there are no advertising trackers, and a short privacy notice is one tap away. If you collect contact details for ordering or loyalty, say why, keep only what you need, and limit staff access.
Why a printed alternative is still worth it
One pattern runs through all three regions: digital is accepted, digital-only is risky. The FSA recommends a non-digital alternative, California requires one for covered chains, and price rules in the UK, France and Germany expect something physical at the door. Generate the printed version from the same data as the QR menu so both always match. Our menu compliance guide for the UK, EU and US covers the wider rules.
QR menu compliance checklist
Keeping digital and print in sync
Most of the work above is keeping allergen, ingredient and price information complete and consistent. With MenuMan, you upload a photo of your existing menu and AI turns it into a multilingual QR menu with suggested allergens, calories and ingredients for each dish. You review and confirm every suggestion, since only your kitchen knows exactly what goes into a recipe. The free plan includes 10 AI credits. If you are comparing tools, see our comparison of QR code menu apps for 2026, or try MenuMan free.
Frequently asked questions
Is it legal to offer only a QR code menu?+
In most places there is no law that bans QR-only menus. The problem is that specific duties may not be met by a QR code alone: printed price displays at the entrance (UK, France, Germany), written allergen info that guests can access without asking (Ireland), or a non-digital allergen option (California SB 68 for covered chains). Keeping a printed fallback is the simplest way to stay safe.
Does a QR menu count as written allergen information?+
Generally yes, if the allergen information itself is on the digital menu. The UK FSA says businesses can choose paper or digital, but should have an alternative for people who cannot access it digitally. Ireland's FSAI accepts electronic format but customers must not have to ask for the information.
Do I need calorie information on my QR menu?+
Only if you are covered. In England that means businesses with 250 or more employees, and the rules cover online and app menus. In the US it means chains with 20 or more locations; FDA's definition of a menu includes electronic menus and menus on the Internet. Smaller venues can add calories voluntarily.
Does the European Accessibility Act apply to my restaurant's QR menu?+
It depends. The EAA covers e-commerce services, broadly services at a distance that lead to a consumer contract. A QR menu that lets guests order and pay is more likely to be in scope than one that only displays dishes. Microenterprises (fewer than 10 people and turnover or balance sheet of €2 million or less) that provide services are exempt. Check your national implementing law.
Can my QR menu collect guest data?+
Yes, but only lawfully. In the EU and UK, you need a lawful basis under GDPR, a clear privacy notice and, for non-essential cookies or trackers, usually consent. Asking for a phone number or email just to view a menu is hard to justify. A menu that works without sign-up is the safer default.
Sources
- FSA: Allergen information for non-prepacked foods, best practice (2025) ↗
- FSA: Food sold online (distance selling) ↗
- The Price Marking (Food and Drink Services) Order 2003 ↗
- Calorie labelling in the out of home sector: implementation guidance (DHSC) ↗
- Regulation (EU) No 1169/2011, Article 44 (non-prepacked food) ↗
- Regulation (EU) No 1169/2011, Article 14 (distance selling) ↗
- FSAI: Allergen information for non-prepacked food (Ireland) ↗
- DGCCRF: Restaurants, rights and obligations of professionals (France) ↗
- Preisangabenverordnung § 13 (Germany) ↗
- European Commission: European Accessibility Act ↗
- Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex ↗
- FDA: Menu labeling requirements ↗
- 21 CFR 101.11 (definition of menu or menu board) ↗
- California SB 68 (Allergen Disclosure for Dining Experiences Act) ↗
- U.S. DOJ: Guidance on web accessibility and the ADA ↗
- ICO: Guidance on the use of storage and access technologies (exceptions) ↗
Bottom line: QR menus are legal and practical. Put allergens on every dish, keep a printed price list at the door and a paper fallback inside, make the menu readable for everyone, and don't track guests who only came to eat.
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