Restaurant allergen management, an allergen list that is always right
The 14 allergens, where they hide, what a Dutch food-safety inspection checks, and why a printed allergen card is always out of date. A practical guide for hospitality.
Around 2 to 3% of Dutch adults have a food allergy, rising to 4 to 8% in children (source: Voedingscentrum). For that guest, your answer to "are there nuts in this?" is not a formality. It is the difference between a good evening and the emergency room.
Since 13 December 2014 it is also the law. The European Food Information Regulation (EU 1169/2011) requires every hospitality business to inform guests about 14 allergens in its dishes and drinks. That sounds manageable. In a kitchen with changing menus, sub-recipes, and suppliers who quietly reformulate their products, it is precisely the information that is hardest to keep correct.
Here is a practical guide: what you must disclose, where allergens hide, what the Dutch food authority (NVWA) checks, and why a laminated card is nearly always out of date.
An allergen list that is always right
A printed allergen card is a photo of one moment. On the day you print it, it is correct. After that it quietly drifts: a supplier changes a product's recipe, you adjust a sauce, the daily menu rotates, a sub-recipe gets a different ingredient. The card on the wall knows none of this.
That is exactly where it goes wrong. The NVWA does not ask for a pretty card. It asks for information that is worked out in advance and that you can give a guest before they order. You may do this orally, but conditions apply (more on that below). The point: there has to be a current, verifiable source behind it. A snapshot on paper is not that.
What you need is not a static card but a living source that moves with your recipes. One place where you work it out properly once, and that updates itself when something changes.
The 14 allergens, and where they hide
These are the 14 allergen groups from Annex II of EU 1169/2011, with the places they often hide unnoticed. Note: for cereals containing gluten and for tree nuts, the NVWA requires you to state which type (so "wheat", "hazelnut"), not just the group.
| Allergen | Often hides in |
|---|---|
| Cereals containing gluten (wheat, rye, barley, oats, spelt) | Soy sauce, stock cubes, thickened sauces, breadcrumbs, spice mixes |
| Crustaceans | Seafood stock, Asian pastes and broths |
| Eggs | Mayonnaise, thickened sauces, pasta, some juice and wine fining, lecithin |
| Fish | Worcestershire sauce (anchovy), Caesar dressing, some stocks |
| Peanuts | Satay sauce, baked goods, some frying fats |
| Soy | Soy sauce, lecithin (E322), meat substitutes, ready-made sauces |
| Milk (including lactose) | Butter and cream in sauces, ghee, baked goods, some fries (in the fat) |
| Tree nuts (almond, hazelnut, walnut, cashew, pecan, pistachio, macadamia) | Pesto, baked goods, dressings, nut oils, some liqueurs |
| Celery | Stock cubes, soups, spice blends, sauces |
| Mustard | Dressings, marinades, mayonnaise, spice mixes |
| Sesame | Rolls and buns, hummus (tahini), sesame oil |
| Sulphur dioxide and sulphites | Wine, dried fruit, pre-prepared potato, vinegar |
| Lupin | Flour blends, gluten-free baking |
| Molluscs | Seafood stock, oyster sauce, paella and bouillabaisse bases |
The common thread: allergens rarely sit where you expect them. They come in through a stock cube, a ready-made sauce, or a prepped component you did not assemble yourself. That is why working it out at ingredient level is the only approach that truly holds: not "are there nuts in this dish", but "which ingredients and sub-recipes are in it, and what does each of those bring with it".
Allergens on changing daily menus, the hardest case
A fixed menu is manageable. It gets genuinely hard with daily menus, specials, and the chef's suggestion. A changing menu gives you no exemption: the duty to inform applies to every dish you serve, however briefly it appears.
And operationally that is the heaviest job. The NVWA requires the allergen information to be worked out in advance, so you can answer immediately on request. For a daily menu that means every new dish has to be mapped before service, including the hidden sources and the risk of cross-contamination, and re-checked whenever you change a recipe or a supplier. A printed card cannot keep that pace. A source that knows your dishes and computes the allergens automatically can.
What an inspection checks around allergens
Since 2021 allergens have been a standard part of NVWA inspections in hospitality. What gets checked:
- Are the 14 allergens disclosed for your non-prepacked dishes?
- Is the information reachable before ordering, so a guest can make a safe choice?
- Does written or electronic information exist for your staff and the inspector, even if you inform orally?
- Do your staff actually know? The NVWA found signs saying "ask our staff", but on follow-up the staff often did not know the allergens.
Both missing and incorrect information count as a violation. NVWA inspections found that roughly 60% of the businesses checked did not have their allergen information in order. In one enforcement round the NVWA issued 591 fines of €525 alongside thousands of written warnings.
Informing orally? That is allowed, under three conditions: you can always give the information directly before the order, it is also available in writing or electronically for staff and inspector, and there is a visible prompt (for example "Ask our staff about allergens").
A word about origin. It belongs in the picture, but in a different box. The allergen check is about the duty to inform; the origin and traceability of your ingredients sit under your HACCP food-safety plan (required via EU 852/2004). Working to an approved hygiene code, such as KHN's Hygiene Code for Hospitality, is one recognised way to meet that HACCP obligation. Allergen management is a fixed part of it.
How moonies helps
In moonies, allergens lean directly on your recipes. You work it out once at ingredient level, and after that the system does the arithmetic:
- Derived automatically per dish. moonies computes each dish's allergens from its ingredients and its sub-recipes (your prep components). Change an ingredient and every dish that uses it updates. You also see where an allergen comes from, for example via your romesco sauce.
- Add by hand where needed. A risk that does not follow from the ingredients, such as cross-contamination from a shared fryer, you add to the dish yourself.
- Search by "free from". A guest with a nut or gluten allergy? Filter in seconds for dishes without that allergen, so you immediately see what does work.
- An overview per allergen. As an owner you see, per allergen, which dishes on your live menu contain it, and which ingredient or sub-recipe it sits in.
Not a laminated card that is out of date the day you print it, but one source that moves with your recipes and your menu. You keep the kitchen current, moonies keeps the allergens current.
Want to see how that works? The Kitchen module is where recipes, ingredients, and allergens come together, and the pricing page shows what it costs, with no surprises.