Digital menu and allergen information: what does Belgian law say?

Oplossingen

Yes, every hospitality business in Belgium is legally required to provide clear and legible allergen information to guests. European Regulation 1169/2011, transposed into Belgian law by the Royal Decree of 13 September 2014, establishes 14 mandatory allergens that must be visible on every menu, whether printed or digital. With Unipage, you configure this allergen information once at product level in your POS system, after which it automatically appears in permanent sync on the digital menu.

In brief:

  • Every hospitality business in Belgium must list the 14 mandatory allergens on the menu, even if that menu is digital.

  • The legal basis is EU Regulation 1169/2011, transposed by the Belgian Royal Decree of 13 September 2014.

  • With every menu change, allergen information must be updated immediately, including on a digital menu.

  • A separate update of your menu after a POS change is time-consuming and increases the risk of errors.

  • With Unipage, you configure allergen information once at product level: the digital menu updates automatically whenever you change something in the POS.

Why allergen information on your menu is a legal obligation

Allergen information is not optional: it is a legally enforceable right of every guest. European Regulation 1169/2011 requires all food service operators to provide information on the 14 allergenic ingredients before the order is placed. This obligation applies to restaurants, chip shops, cafeterias and every other hospitality concept, both for food consumed on the premises and for takeaway orders.

The Belgian Royal Decree of 13 September 2014 translates this European rule into national practice. Hospitality businesses may choose how they provide the information: verbally through trained staff, in writing on a printed card, or via a digital menu. What is not permitted: omitting the information or only making it available on the explicit request of the guest.

The 14 mandatory allergens

EU Regulation 1169/2011 defines the following substances as mandatory allergens to be declared, listed in Annex II of the regulation:

  1. Gluten (wheat, rye, barley, oats and variants)

  2. Crustaceans

  3. Eggs

  4. Fish

  5. Peanuts

  6. Soy

  7. Milk (including lactose)

  8. Tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts)

  9. Celery

  10. Mustard

  11. Sesame seeds

  12. Sulphur dioxide and sulphites (at concentrations above 10 mg/kg or 10 mg/l)

  13. Lupin

  14. Molluscs

Each ingredient on that list must be clearly identifiable on the menu, preferably via a clear marking or a separate allergen list per dish.

What the law says about a digital menu

A digital menu complies with allergen legislation provided the information is clear, legible and accessible to the guest before they order. The law does not prescribe a specific format: a digital screen, a QR code or a tablet menu are all permitted. The obligation applies to the result, not the medium.

In practice, a digital menu that shows allergen information per dish via icons, colour coding or a pop-up is compliant. What is not sufficient: a general statement on the website without specification per dish, or a reference to another page that the guest must find themselves.

What if your menu changes?

One of the most common compliance problems is not the initial setup, but consistently keeping the information up to date. When a supplier changes an ingredient, when a dish is removed from the menu, or when a new seasonal menu goes live, the allergen information must follow immediately.

A digital menu that is separate from the POS system then requires two separate updates, with the risk that one of them falls behind. With Unipage, the POS product list and the digital menu are one whole. You configure allergen information once at product level and that information is automatically visible live on every screen running the menu. Change a dish in the POS and the menu updates immediately.

Manual allergen information vs. integrated digital menu

Those who manage allergen information separately per system run a higher risk of compliance errors than those who use an integrated system. A comparison on five points:

  • Input: manually per separate system (POS and menu) vs. once at product level in the POS with Unipage.

  • Synchronisation: manual update required with every menu change vs. automatic: POS change is immediately live on the digital menu.

  • Risk of outdated information: high (human error or forgotten update possible) vs. low (POS and menu always in sync).

  • Compliance risk: higher with frequent menu changes vs. minimal: information is always current.

  • Time investment: manually update with every menu change vs. configure once, then zero extra time.

Frequently asked questions

Does the allergen obligation also apply to takeaway and online orders?

Yes. EU Regulation 1169/2011 makes no distinction between eating on the premises and takeaway or online ordering. Anyone ordering via a web shop or order kiosk also has the right to correct allergen information before the order is placed. The information must therefore also be available on the online ordering environment and on the order kiosk, not only in the establishment itself.

Must I list the 14 allergens separately for each dish?

The law requires you to make allergen information available per dish, not necessarily in running text. In practice, most businesses use icons or colour coding per dish, supplemented by a complete allergen list. What is not sufficient: only a general statement without mention per dish. The 14 mandatory substances are set out in Annex II of Regulation 1169/2011.

Can allergen information be provided verbally by staff?

Yes, verbal information via trained staff is permitted under Belgian law. It is estimated that 2 to 4% of the European population has a food allergy (source: EFSA), meaning every busy restaurant regularly receives questions from guests with dietary restrictions. Verbal information places high demands on staff knowledge and availability, especially during busy service periods. Most Belgian hospitality businesses therefore choose written or digital display as a permanent basis, supplemented by verbal explanation where needed.

Is a digital menu legally equivalent to a paper menu for allergen information?

Yes. The law does not prescribe a specific medium, as long as the allergen information is clear and accessible to the guest before ordering. A well-designed digital menu with per-dish allergen information fully meets the requirements of EU Regulation 1169/2011 and the Belgian Royal Decree of 13 September 2014. The advantage of digital: changes are immediately live and the risk of outdated information is lower than with a printed card that must be reprinted with every change.

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