Allergen list for caterers: what do you have to state?

Run a restaurant, a catering business or a meal service from home, and you're legally required to inform customers about allergens in your dishes. That requirement covers all 14 legal major allergens and is based on European law, checked in the Netherlands by the NVWA and in Belgium by the FAVV.

Below we list which allergens you have to state, what the disclosure duty actually requires of you, and how to keep that manageable in daily practice.

The 14 legal allergens

The disclosure duty covers fourteen major allergens: gluten, crustaceans, eggs, fish, peanuts, soy, milk (including lactose), nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin and molluscs.

Those fourteen turn up in your kitchen more often than you'd think, even in products a guest would never suspect.

• Gluten is in bread and pasta, but also in sauces, stock cubes and many ready-made products.
• Milk turns up in dishes where you wouldn't expect it, such as some sausage and cold meat products.
• Nuts can turn up in pesto, baked goods and herb mixes.
• Sesame is in sesame seeds, but just as much in tahini, hummus and certain breads.
• Sulphur dioxide occurs in dried fruit, wine and many preservatives.

For every dish you serve or deliver, you have to be able to state which of these allergens are present, including cross-contamination that can occur during preparation.

What the disclosure duty requires of you

The law makes a distinction by type of hospitality business. A restaurant may give allergen information verbally, for example because staff can tell guests at the table.

A catering business or meal service often doesn't have that direct contact, because guests order in advance and receive the meal later. In that case you have to make the information available in writing or digitally, for example on the quote, the menu or the delivery note.

During inspections, the regulator looks specifically at how complete and clear your allergen information is, and is stricter still with businesses serving vulnerable groups, such as care homes or meal services for the elderly.

Lactose intolerance: the most common one

Of all fourteen allergens, you'll probably get the most questions about milk and lactose. Lactose intolerance happens because the body doesn't produce enough of the enzyme lactase, so milk sugar isn't digested properly.

That can develop at any age, even in people who tolerated dairy without any trouble their whole life. The symptoms, such as bloating, stomach ache or diarrhoea, are unpleasant but in most cases not dangerous.

For you in the kitchen that means mainly one thing: you need to know which dishes contain milk or milk derivatives, including in less obvious places such as certain breads, sauces or cold meats. A guest who asks wants a definite answer straight away, not 'I don't think so'.

Communicating allergens well

It isn't necessary, and is often actually confusing, to hand every guest a full list of all fourteen allergens. It's more practical to state, per order or per dish, only the allergens that are actually present.

That way you give clarity instead of a long list nobody reads through. A guest with a peanut allergy wants to know if that's in there, not whether lupin shows up somewhere in your catalogue.

That does require you to keep allergen information up to date per dish, even when you swap an ingredient or change a supplier. An allergen that wasn't in there last month can suddenly be in there after a recipe change.

An allergen list that works in practice

Most mistakes don't happen because nobody knows the rules, but because the information is disconnected from how you actually work: a spreadsheet nobody opens, or knowledge that only lives in the chef's head.

So link allergens to the dish itself. Then the information automatically travels to every document that needs it: the delivery note for the customer, the prep list for the kitchen, the event sheet on site and the driver's list for delivery.

That way everyone, from the kitchen team to the driver to the guest, can see at a glance which allergens belong to which dish, without anyone having to search a separate list every time. Change a recipe, and the list changes on every document that uses it.

Netherlands and Belgium: who checks what

In the Netherlands, the NVWA enforces the allergen disclosure duty, as part of the wider food safety rules. In Belgium this falls under the FAVV (Federal Agency for the Safety of the Food Chain), which includes allergen information in the self-checking guide for the hospitality sector.

The basic requirement, communicating all fourteen allergens correctly and on time, is the same in both countries. Only how it's enforced and the exact paperwork differs.

Frequently asked questions

Do I always have to give guests a full allergen list?

No, that's often actually confusing. State only the allergens that are actually present, per dish or order, instead of a list with all fourteen.

Can I give allergen information verbally?

As a restaurant with direct customer contact, that's allowed, provided your staff can give the correct information at any time. If you work with catering, delivery or pre-ordered meals, the information has to be available in writing or digitally.

Do I have to state cross-contamination in the kitchen too?

Yes, your allergen information per dish also covers cross-contamination that can occur during preparation. If you work with nuts or sesame on the same worktop, that belongs in the picture you give the guest.

Is lactose intolerance the same as a milk allergy?

No. Lactose intolerance is a problem digesting milk sugar, while a milk allergy is an immune system reaction and can be more dangerous. For the disclosure duty that makes no difference: you have to state milk either way.

Does the disclosure duty also apply to one-off event menus?

Yes. Even a menu you only serve once at an event falls under the same rules as your regular menu. The allergens have to be known per dish and passed on to the guest, just the same.

In Catermonkey you record allergens on the dish itself, not in a separate list next to it. From there they carry through to the delivery note, the prep list and the event sheet, so the kitchen and the driver see the same information as the customer.

Try for free