Allergen labelling in hospitality: obligations, 14 allergens and practical tips

A guest orders and asks whether the dressing contains nuts or egg. The server goes to the kitchen, the chef tries to remember whether today’s batch of sauce was made to the old recipe or the new one, and the guest ends up with an uncertain answer. This is exactly where allergen labelling in hospitality comes in: it makes sure every answer about allergens is correct, no matter who is on shift. For guests with allergies it is a matter of health; for your business it is a legal obligation.

In this article you will learn which 14 allergens you need to label, which rules apply in Germany, Austria and Switzerland, and which labelling methods work in day-to-day operations. You also get a step-by-step guide to setting up your allergen documentation, tips for the bar and drinks menu, and the most common mistakes to avoid.

1. What does allergen labelling in hospitality mean?

Allergen labelling means informing your guests which of the legally defined major allergens are contained in a dish or drink. On packaged food this appears on the label. In hospitality there is no label, so separate rules apply to what is known as loose or unpackaged food. The German Federal Ministry of Agriculture, Food and Regional Identity (BMLEH) makes clear that allergen information is mandatory for unpackaged food as well, explicitly including restaurants.

The key term is ingredient. It covers everything used in preparation that remains in the finished dish, even in altered form. That includes thickeners, marinades, sauces and garnishes. The Austrian Economic Chamber (WKO) points out that ingredients used for garnish or binding are easily overlooked. If you only look at the main components on the plate, your labelling will often be incomplete.

2. The 14 major allergens at a glance

Which substances must be labelled is set out in Annex II of the EU Food Information Regulation (FIR, Regulation (EU) No 1169/2011). There are 14 groups:

• Cereals containing gluten such as wheat, rye, barley and oats
• Crustaceans
• Eggs
• Fish
• Peanuts
• Soybeans
• Milk including lactose
• Tree nuts, for example almonds, hazelnuts or walnuts
• Celery
• Mustard
• Sesame seeds
• Sulphur dioxide and sulphites at concentrations of more than 10 mg per kilogram or litre
• Lupin
• Molluscs such as mussels or squid

For every dish on your menu, ask yourself one simple question: which of these 14 groups are contained in any of the ingredients? In practice gluten, milk, egg, mustard and celery are the usual suspects, because they appear in many sauces, stocks, breadings and dressings. Tree nuts and sesame often hide in pestos, toppings and desserts.

3. Legal basis in Germany, Austria and Switzerland

The obligation itself comes from the EU: under Article 44 FIR, allergen information is mandatory for food sold without pre-packaging too. How the information is provided may be regulated nationally by member states. This results in slightly different rules across the DACH region.

Germany

In Germany the Food Information Implementation Regulation (LMIDV) supplements the FIR. Information can be given in writing, electronically or verbally. If you choose verbal information, the BMLEH requires written or electronic documentation to be easily accessible on request, and a clear notice pointing to it on the premises. The Schwerin Chamber of Commerce (IHK) adds that the information must be given before the purchase is completed and that a tick-box table is sufficient as documentation.

Austria

In Austria the Allergen Information Regulation applies. According to the WKO guidance on the Allergen Information Regulation, each business decides whether to provide the information in writing or verbally. With verbal information, a trained person must always be available during opening hours, and a notice on the menu or a clearly visible sign is required. Documenting the ingredients used is mandatory regardless of the method chosen. For written labelling, letter codes with a clearly visible key are common.

Switzerland

Switzerland is not an EU member and has its own rules in the Food Information Ordinance (LIV). A fact sheet from the Canton of Aargau summarises: under Art. 5 LIV, verbal information for food sold loose is permitted if there is a clearly visible written notice to that effect and staff either have the information in writing or a specialist can provide it immediately. The relevant ingredients are listed in Annex 6 LIV.

What all three countries have in common: in practice it does not work without a reliable written basis. Even if your team informs guests verbally, an up-to-date record has to exist in the background.

4. Three ways to label allergens in your business

Three approaches have become established in day-to-day operations. Which one suits you depends on how often your menu changes and how large your team is.

Labelling directly on the food and drinks menu

Each dish is followed by codes or footnotes explained in a key, for example A for gluten or C for egg. The advantage: guests see the information immediately and your service team needs to check less often. The disadvantage: you have to update the menu with every recipe change. For businesses with a fixed standard menu this is often the best solution. If you are redesigning your menu anyway, take a look at our guide to creating a drinks menu, because the key and layout should be planned in from the start.

Separate allergen menu with a notice

The main menu stays clear, and the allergen information is kept in a separate folder or table. A note on the menu or a sign points guests to it. This approach works well if you offer many dishes and do not want to overload the main menu.

Verbal information backed by documentation

Your team provides information on request, based on written or electronic documentation. This approach is flexible, for example for daily specials, but it only works if the documentation really is up to date and every server knows where to find it. Many businesses combine the approaches: standard dishes carry codes on the menu, while daily and seasonal specials are explained verbally.

5. Allergens on the drinks and cocktail menu

Many businesses think of the kitchen first when it comes to allergens. However, the obligation applies to all food served unpackaged, and the WKO explicitly includes drinks. There are a few typical pitfalls at the bar:

• Egg white in sours: classic sours made with egg white contain the allergen egg.
• Milk and cream: creamy drinks, coffee specialities and milkshakes contain milk.
• Almond syrup: almond-based syrups count as tree nuts.
• Spice mixes: savoury drinks often contain celery, for example as celery salt or juice.
• Wine and sparkling wine: sulphites must be declared above 10 mg per litre.

House-made syrups, infusions and pre-batches are particularly tricky. They are often made once and then used for weeks. If the recipe changes along the way, for instance because a bartender adds nuts to a syrup, the allergen information has to be updated for every drink that contains it.

6. Step by step: setting up your allergen documentation

Reliable documentation is not built in one go, but dish by dish. These four steps have proven effective:

Step 1: Record all ingredients. Write down every component of each dish and drink, not just the main ingredients. Sauces, stocks, marinades, toppings and garnishes all count. For components you make yourself, create a separate base recipe.

Step 2: Assign allergens per ingredient. Check which of the 14 main groups each ingredient contains. For bought-in products, the label and the supplier’s product data sheet help. If you assign allergens at ingredient level rather than dish level, you only need to check a product once, even if it is used in ten recipes.

Step 3: Output per dish or drink. The ingredients give you the list of allergens for each dish. You use this list for the codes on your menu, for the allergen folder, or as the basis for your team’s verbal information.

Step 4: Keep it up to date with every change. A new supplier, a different product, an adjusted recipe: any change can alter the allergen list. Decide who checks changes, and record from when a new recipe version applies.

7. Common mistakes and how to avoid them

Typical weak spots in allergen labelling are listed below. Most of them can be avoided with clear processes:

• Forgotten sub-recipes: the dish is labelled correctly, but the house-made sauce was never checked on its own. Create a separate recipe for every component you make yourself.
• Changing suppliers without checking: the new pesto contains cashews instead of pine nuts. Check the label every time a product changes and update the affected recipes.
• Blanket warnings: a general statement that dishes may contain allergens does not replace labelling. The WKO points out that such notices are not sufficient in Austria and that stating the business is unsuitable for allergy sufferers is not permitted.
• Knowledge only in someone’s head: if only the head chef knows what is in which sauce, the answer is uncertain on their day off. The documentation must be accessible on every shift.
• Number codes without a key: codes only help if the key is clearly visible. The WKO also advises avoiding number codes and using letters or short names instead.

8. Allergens and costing in one recipe

Allergen documentation and costing share the same foundation: a complete recipe with all ingredients and quantities. If you maintain them separately, you do the work twice and risk the lists drifting apart. A Caesar salad shows how closely the two are connected:

The calculation is simple: for each ingredient, multiply the quantity by the purchase price. 150 g of romaine at 3.00 € per kilogram costs 0.45 €, 120 g of chicken breast at 12.00 € per kilogram 1.44 €, 20 g of parmesan at 20.00 € per kilogram 0.40 €, 30 g of croutons at 5.00 € per kilogram 0.15 € and 40 ml of dressing at 9.00 € per litre 0.36 €. Together that gives a cost of goods of 2.80 € per portion.

At a selling price of 14.50 € gross, deducting 7% VAT on food leaves 13.55 € net. Since January 2026 the reduced rate has applied permanently to food in German hospitality, as the Frankfurt am Main Chamber of Commerce (IHK) explains; you can find details in our article on VAT in hospitality 2026. 2.80 € divided by 13.55 € gives a cost of goods ratio of around 21%.

The same ingredients give you the allergen list: the wheat croutons bring gluten, the parmesan milk, and the dressing egg, fish from the anchovies, and mustard. So five of the 14 major allergens are in what looks like a simple salad. If you replace the anchovies in the dressing or switch crouton supplier, costs and allergens change at the same time. That is exactly why both pieces of information belong in the same recipe. Our article on menu engineering shows how clean recipes also help you optimise your menu.

9. Allergen labelling with BarBrain

With BarBrain’s recipe management you manage food, drinks and cocktails centrally, including base and prep recipes such as sauces or syrups. You document ingredients and allergens per ingredient and output them per dish or drink. Because allergens are attached to the ingredient, you only check a product once, and the allergens are output for every dish or drink containing that ingredient.

In the same recipe, BarBrain calculates ingredient costs as quantity times purchase price and puts them in relation to the net selling price. Purchase prices update automatically from your purchasing, so your costing stays up to date. When a recipe changes, a new version is created with a traceable history. Recipes can also be printed for the kitchen and bar so your team has the recipes to hand. You can take over existing ingredients directly from your stocktake. Read more about how these building blocks work together in our article on recipe management, costing and stocktaking.

The difference shows in everyday work: instead of maintaining a separate allergen list by hand, which is easily forgotten at the next recipe change, the information is attached directly to the ingredient and the recipe. Sauces and syrups get their own base recipe, so their ingredients do not only exist in the kitchen team’s heads. And you do not estimate cost of goods per dish separately; you see it in the same recipe that the allergen list comes from.

Want to see how this looks for your menu? Book a demo to see recipe management in action with your own dishes.

10. Frequently asked questions