Allergens on digital menus: what EU rules ask of restaurants

The rule in one paragraph

Regulation (EU) No 1169/2011 on the provision of food information to consumers, often called FIC, has applied since 13 December 2014. It requires food businesses to tell consumers when any of 14 listed allergens is used in a food. The requirement covers food that is not prepacked, which includes the dishes a restaurant serves. Each member state decides how that information may be provided, for example in writing on the menu, or verbally by staff with a clear sign telling guests to ask.

The 14 allergens

Annex II of the regulation lists the substances that must be declared:

1. Cereals containing gluten: wheat (including spelt and khorasan), rye, barley and oats
2. Crustaceans, such as prawns, crab and lobster
3. Eggs
4. Fish
5. Peanuts
6. Soybeans
7. Milk, including lactose
8. Nuts: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia nuts
9. Celery
10. Mustard
11. Sesame seeds
12. Sulphur dioxide and sulphites, at more than 10 mg per kilogram or 10 mg per liter
13. Lupin
14. Molluscs, such as mussels, clams, oysters and squid

TruePlate’s allergen list covers all fourteen, so each dish can carry exactly what the kitchen declares.

What changes on a digital menu

A digital menu can do something a printed card struggles with: show every dish’s allergens right next to the dish, in the guest’s own language, without a separate binder behind the bar. Used well, that makes the information easier to find than it has ever been.

EnlargeAllergens on the dish

EnlargeAnswers that defer to staff

Three points deserve care:

• Not every guest has a phone to hand. A dead battery or no phone at all should not mean no allergen information. Many authorities expect it to be available without the guest’s own device, so keep a printed allergen list or trained staff ready as well.
• Online and pickup orders. When food is ordered at a distance, the allergen information should be available before the guest completes the order.
• Translations. A translated menu is only as good as its allergen data. Make sure allergens are declared per dish, not buried in a description that might be translated loosely.

Keep one source of truth

Most allergen mistakes are not ignorance of the law. They are data that drifted: a recipe changed and the menu did not, a supplier swapped a product, a new chef added a nut crumb. The fix is one place where each dish’s allergens live, updated the same day anything changes.

Cross-contact deserves its own decision. Statements like “may contain” are voluntary under the regulation, but voluntary information must not mislead guests. Decide what your kitchen can honestly promise, and say it consistently.

Where AI fits, and where it must not

AI is useful around a menu: translating it, drafting nutrition estimates, answering everyday questions. Allergen declarations are different. They have to come from the people who make the dish, because a plausible guess is not good enough.

That is how TruePlate draws the line. Nutrition drafts never include allergens, which stay yours to declare. The AI menu answers allergen questions only from what you declared, and every allergen answer ends with a line asking the guest to confirm with your staff.

A practical checklist

1. List every ingredient in each dish, including sauces, dressings, garnishes and frying oils.
2. Map each ingredient against the 14 allergens, reading supplier labels.
3. Record the allergens on each dish in your menu, in one place.
4. Decide your cross-contact statement and use it consistently.
5. Review a dish the same day its recipe or a supplier changes.
6. Train every shift on where allergen information lives and how to answer.
7. Keep the information available without a phone.
8. Show allergens before checkout on online and pickup orders.

Questions restaurants ask