Food safety
The 14 mandatory food allergens in the EU
"What's in this?" It's one of the most frequent questions in any restaurant dining room — and for someone with a food allergy, the right answer isn't a courtesy, it's a matter of safety. This article sets out what the law requires in concrete terms, dish by dish.
What the law actually says
EU Regulation No. 1169/2011 fixes a closed list of fourteen substances that have to be declared whenever they are present in a dish or a drink — in force since December 2014, and covering non-prepacked meals as well, meaning everything that leaves a kitchen for a table or a counter. In Portugal, it is implemented in national law by Decree-Law No. 26/2016 of 9 June.
Three details that tend to slip by. First, the declaration covers the allergen and the products derived from it — thinking "milk" and forgetting butter or whey isn't enough. Second, the information has to be available before the guest orders, not after the dish is already on the table. Third, it can be given in writing or verbally, but in that case there has to be an accessible, up-to-date written record the team can rely on.
The fourteen
This is the list the law fixes — the same one any menu, digital or printed, has to be able to declare dish by dish:
- Cereals containing gluten
- Wheat, rye, barley and oats, and their hybridised strains. Covers flours, pasta, bread, breaded dishes and sauces thickened with flour.
- Crustaceans
- Shrimp, prawn, langoustine, lobster and crab, including stocks and sauces where the crustacean is no longer visible.
- Eggs
- Whole or separated — mayonnaises, fresh pasta, breaded dishes and meringues.
- Fish
- Every species and derivative. Watch for discreet appearances, such as anchovy paste in salad dressings or stocks.
- Peanuts
- Given a category of their own because of how severe the reactions they cause can be — they turn up in oils, butters and sauces.
- Soybeans
- Beans, flour, lecithin, tofu — and a considerable number of industrial emulsifiers.
- Milk, including lactose
- Butter, cream, cheese and whey. "Lactose-free" is not the same as "milk-free": a lactose-free product can still contain milk proteins.
- Tree nuts
- Almond, hazelnut, walnut, cashew and pistachio, among others. Peanuts don't belong here — they have a category of their own.
- Celery
- Stalk, root, leaves and seeds. One of the most underestimated, because it slips quietly into stocks and soups.
- Mustard
- Seed, powder or paste — present in vinaigrettes, marinades and charcuterie.
- Sesame seeds
- Tahini, hummus and the topping on most burger buns.
- Sulphur dioxide and sulphites
- At concentrations above 10 mg/kg. Present in wine, vinegar, dried fruit and some preserves.
- Lupin
- Lupin flour and beans, increasingly used in bread and in plant-based meat alternatives — one of the most frequently forgotten.
- Molluscs
- Clam, mussel, oyster, octopus and squid.
From the list to the table
Having the list pinned up doesn't solve the problem — what solves it is the allergen being tied to the dish, not to a binder filed away behind the counter. In practice, that means three things.
A spec sheet per dish, with the real ingredients rather than the ones from two years ago: whenever the recipe changes, the information changes with it. Watch for cross-contamination — the same fryer or the same chopping board carries allergens from one dish to another, and that should be communicated honestly rather than left unsaid. And training: on a busy night, the information travels through the person taking the order, not through the poster by the door.
This article is for information purposes and does not constitute legal advice. The accuracy of ingredient and cross-contamination information for each dish is the restaurant's responsibility. For the full text of the applicable obligations, consult EU Regulation No. 1169/2011 and Decree-Law No. 26/2016.