Allergen Labelling on a Digital Menu: What Restaurants Need to Show

A guest with an allergy looks at a menu and needs one thing above all: to know what is in the dish. When the menu moves from paper to a phone, restaurant owners ask the same questions again. Do I still have to show allergens? Where? Is "ask the waiter" enough?

This article answers them, with the focus on Germany, and shows how BiteTwo handles allergen and additive labels. It is general information, not legal advice. Your local food control authority (Lebensmittelüberwachung) and your trade association (IHK or DEHOGA) have the final word for your business.

The short answer

Yes, you have to inform guests about the 14 listed allergens, also for food that is served loose in a restaurant. A digital menu does not change that.
You may do it in writing, electronically or orally. Orally only if you keep a written record and tell guests about it.
Guests must get the information before they order, and be told how to find it if it is not directly on the menu.
In Germany, additives such as "with colouring" or "with preservative" follow the same route as the allergen information.

Which allergens do I have to show?

The EU requires information on 14 allergens (Regulation (EU) No 1169/2011, Article 9 and Annex II). German-language menus often use the letter codes in the last column, which BiteTwo also uses for restaurants in Germany, Austria and Switzerland.

No.	Allergen	German name	Letter
1	Gluten (wheat, rye, barley, oats and others)	Glutenhaltiges Getreide	A
2	Crustaceans	Krebstiere	B
3	Eggs	Eier	C
4	Fish	Fisch	D
5	Peanuts	Erdnüsse	E
6	Soy	Soja	F
7	Milk (including lactose)	Milch (einschließlich Laktose)	G
8	Nuts	Schalenfrüchte	H
9	Celery	Sellerie	L
10	Mustard	Senf	M
11	Sesame	Sesam	N
12	Sulphur dioxide and sulphites	Schwefeldioxid und Sulfite	O
13	Lupin	Lupinen	P
14	Molluscs	Weichtiere	R

In Germany, the rules for loose food are in § 4 LMIDV. Reading it for a digital menu, three points matter:

Electronic information is allowed. Next to menus, price lists and signs, "other written or electronic information" is listed, as long as it is immediately and easily accessible.
It must be there before the guest decides. The information has to be available before the purchase is completed and before the food is handed over.
If it is not on the menu itself, guests must be told where to find it. When information is electronic, the food or a notice has to say how to reach it.

When your whole menu is on the guest's phone and the allergens are part of it, the information is where the guest decides. That is the simplest case. Where it gets harder is the rest of your restaurant: the guest who orders from the waiter, the daily special on the blackboard.

Is "ask the waiter" enough?

In Germany it can be, but only under conditions (§ 4 Abs. 4 LMIDV). Oral information is allowed when:

a written or electronic record of the ingredients exists, which the authorities can see and which guests can see on request, and
the menu or a notice says clearly that the information is given orally and that the record is available, and
trained staff give the information immediately when a guest asks, before the order is completed.

"Just ask us" without a record and a notice does not meet this. If you work with daily specials, a common approach is to label the standard dishes in writing and to point to the oral information for the specials. The guidance of the chambers of commerce, such as the IHK Hannover, describes this in more detail.

What about additives?

German law also asks for certain additives to be named on loose food, for example "with colouring", "with preservative", "with antioxidant", "with flavour enhancer", "with sweetener" or "with phosphate" (§ 5 LMZDV). For a digital menu, one rule is easy to miss: if you have to give allergen information, additives must be given in the same way and through the same medium. So if your allergens are on the phone menu, your additives belong there too.

And in Austria, Switzerland, the UK and the US?

Austria and Switzerland: national rules apply, and the letter codes above are common on German-language menus there as well. Check with your local authority or chamber of commerce.
United Kingdom: the 14 allergens apply too. The duty to inform has not changed, but the Food Standards Agency's guidance for non-prepacked food recommends having written allergen information available, also for food ordered online. The guidance is updated from time to time, so read the current version in the FSA's allergen guidance for food businesses.
United States: the federal list of major allergens has nine entries (sesame was added in 2023), but that labelling rule is about packaged food. What applies to restaurant menus depends on your state and city, so check locally.

How BiteTwo handles allergens

BiteTwo does not decide what is in your dishes. You do, and it shows what you enter in the format guests expect. Concretely:

One entry per dish. In the menu editor you tick the allergens, additives and diet (vegetarian, vegan) once. Add-ons such as extra cheese have their own labels.
Your country decides the format. For a German, Austrian or Swiss restaurant, the marks are the letters from the table, plus the German additive labels. For the UK they are numbers with symbols for the common ones, for Ireland numbers, and for the US the nine major allergens.
Guests see it before they order. Marks sit next to the dish name, and when a guest opens a dish, the allergens and additives are listed by name with a note to ask the staff in case of questions.
Guests can filter. A guest picks a diet or the allergens to avoid, and the menu hides the dishes that contain them. Add-ons that do not fit the filter are hidden until the guest asks for them.
The public menu has a key. If you publish your menu as a web page, the letters are explained at the bottom, listing only what appears on that menu.
A record you already have. The labels you entered can serve as the written record for your team, and the public page shows them with the key. Whether that is enough for your inspection is for your authority to say.

What BiteTwo does not do

So that you know where your own responsibility stays:

It does not check your recipes. The labels are only as correct as your entries. When a supplier changes an ingredient, update the dish.
Cross-contact is up to you. BiteTwo has no separate field for "may contain traces". Put it into the dish description if you want to state it.
Orders taken by staff need the same care. For guests who order from the waiter, your routine for oral information (record, notice, trained staff) still applies.
It is not legal advice. The law differs between countries and changes. Check with the authority for your location.

Frequently asked questions

Do I have to show allergens if I only offer a few dishes?

Yes. The duty applies to every business that serves food, also for a short menu.

No. Guests need to know which allergens are in which dish. A general note does not tell them.

Yes, as long as the key is easy to find. In BiteTwo the dish details spell out each allergen by name, and the public menu page shows the key.

What if a dish changes from day to day?

Update the dish or switch it to unavailable. For specials that are not on the menu, use your oral information routine with a written record.

Conclusion

A digital menu does not remove your duty to inform guests about allergens, but it can make it easier to meet: the information sits next to the dish, in the format guests know, and is always as current as your last edit. Enter your dishes with their labels once, check them when recipes change, and keep your oral routine for the rest.

Start for free or book a demo to see how the labels look on the guest's phone.