Allergen labelling in Germany: what belongs on the menu

Who has to declare — and for what

The basis is the Food Information Regulation (LMIV), Regulation (EU) No 1169/2011. It does not bind industry alone: unpackaged food — every dish handed over in a restaurant, snack bar, café or by a caterer without pre-packaging — must come with information on the allergens it contains. In Germany the implementing rules sit in the Lebensmittelinformations-Durchführungsverordnung (LMIDV).

The duty applies regardless of the size of the business, and it covers the dish of the day on the chalkboard, the buffet, the cake in the display and the food truck at the weekly market. One point is easy to miss: the information has to be available before the purchase decision — not once the plate is on the table.

The business is responsible. If a guest reacts, it does not help that “the kitchen knew” when nobody in service was able to answer.

The 14 allergens

Annex II of the regulation names fourteen groups. The list is exhaustive — what is not on it (strawberries, say, or histamine) does not have to be declared, even if guests ask about it:

• Cereals containing gluten — wheat, rye, barley, oats, spelt, kamut and products thereof
• Crustaceans — prawns, crab, lobster
• Eggs
• Fish
• Peanuts
• Soybeans
• Milk — including lactose
• Tree nuts — almond, hazelnut, walnut, cashew, pecan, Brazil nut, pistachio, macadamia
• Celery
• Mustard
• Sesame seeds
• Sulphur dioxide and sulphites — from 10 mg/kg or 10 mg/l
• Lupin
• Molluscs — mussels, squid, snails

In writing or spoken — both are allowed, but not freely

The most common misunderstanding: “we tell guests when they ask”. Spoken information is indeed permitted — but only under conditions, and those are exactly what tends to be missing.

In writing means: on the menu itself, on a notice, on a sign at the buffet, or in a separate allergen folder available at the table. It is the simplest route because it explains itself and does not depend on how well the service staff were briefed.

Spoken information is allowed when two things are added: a written record for every dish that guest and authority can inspect on request — and a clearly visible notice at the point of sale stating that the information is given verbally. Without that notice and without the record behind it, spoken information is not sufficient, even when it happens to be correct.

What it looks like on the menu

In practice the footnote has won: a sequence of numbers or letters after each dish, with the key at the bottom of the menu. What matters is that the key sits on the same menu or is unmistakably referenced — a legend that only hangs on the wall next to the toilets does not do the job.

An example of how a line then reads: “Cheeseburger with fries (a, c, g)” — with a key resolving a as cereals containing gluten, c as egg and g as milk. Whether you use numbers or letters is not prescribed; the letter order taken from the regulation's annex is simply customary.

The declaration has to be clearly assignable to the dish and easy to read. And it has to be true: change the supplier of a sauce and the allergen list can change without anything about the dish looking different. That is the quiet error source number one.

Additives: the second labelling duty people mix up

Next to allergens sits a second duty that has nothing to do with them but lands on the same menu: declaring additives (Zusatzstoffe). It follows the German additives ordinance and uses set phrases familiar from any canteen menu:

• mit Farbstoff — with colouring, e.g. in desserts or liqueurs
• mit Konservierungsstoff — with preservative, common in sausage and deli salads
• mit Antioxidationsmittel — with antioxidant
• mit Geschmacksverstärker — with flavour enhancer, the classic in stocks and ready-made sauces
• geschwefelt — sulphured; dried fruit, wine
• geschwärzt — blackened; olives
• gewachst — waxed; citrus fruit, apples
• mit Phosphat — with phosphate; meat products
• mit Süßungsmitteln — with sweeteners; with aspartame also enthält eine Phenylalaninquelle
• koffeinhaltig / chininhaltig — contains caffeine / quinine; energy drinks, bitter lemon

Cross-contact, and what service needs to know

The declaration describes the recipe — the guest is asking about the plate. Between the two sits the kitchen: the same fryer for breaded fish and chips, the same board for bread and salad, the spoon that travels from the sauce into the soup. For a guest with a severe allergy this is what matters, and a footnote alone does not answer the question.

The voluntary line “may contain traces” is not regulated and must not replace the actual declaration. Printed under the whole menu as a blanket, it reads like an excuse and helps nobody — it makes sense only where cross-contact genuinely cannot be ruled out.

More important than any document is that the person at the table can answer. In a kitchen with an international team that means the allergen list has to exist in a language service actually reads — otherwise people guess, and guessing goes wrong at the worst moment.

What inspections pick up on

Food control checks the allergen information together with the rest of the menu. These points come up regularly:

• No information at all — and no notice about spoken information either.
• A notice without the record: a sign promises information on request, but there is no written list anyone could rely on.
• Missing or unfindable key — footnotes on the menu that are resolved nowhere.
• Outdated list: the recipe changed, the footnotes did not.
• Daily specials without any declaration — the printed menu is clean, the chalkboard is not.
• A blanket “may contain traces” used instead of a real declaration.

Why this stays current more easily when it is digital

The real problem with allergen labelling is not filling it in the first time, it is keeping it true. A printed menu is correct on the day it is printed; then a supplier changes, the bun now comes with sesame, the sauce gets thickened — and the footnotes no longer match. On paper nobody notices until somebody asks.

If the assignment lives on the dish itself, everything derived from it changes along: the menu at the table, the QR menu on the guest's phone, the printout for the inspection. That is how Servio works: photograph the paper menu once, the AI recognises dishes and prices and proposes the allergens under the regulation, you confirm — after that the labelling hangs on the recipe, not on a file.

For the guest it then appears written out in the QR menu, in their own language instead of a string of letters; for printing, Servio produces the menu including the key; and for service the full list stays available in the business — including to the weekend help working their first Friday night.