EU Regulation 1169/2011 on food information to consumers has been in force since December 2014. For resort and hotel F&B operations, it creates specific, non-negotiable obligations — and most properties are not fully compliant. Here's what you need to know.
The 14 Allergens You Must Declare
The regulation requires mandatory labelling of 14 allergens wherever they are present or may be present in a prepared food item:
1. Cereals containing gluten (wheat, rye, barley, oats) 2. Crustaceans 3. Eggs 4. Fish 5. Peanuts 6. Soybeans 7. Milk (including lactose) 8. Nuts (almonds, hazelnuts, walnuts, cashews, pecans, pistachios, macadamia/Queensland nuts) 9. Celery 10. Mustard 11. Sesame seeds 12. Sulphur dioxide and sulphites (at concentrations above 10mg/kg or 10mg/litre) 13. Lupin 14. Molluscs
For non-prepacked food — which includes most restaurant, hotel, and resort F&B service — information must be provided in writing or verbally, but written documentation must be available.
What 'In Writing' Actually Means
The regulation requires that allergen information is available in writing. This means a documented source — not just 'ask the chef.' A restaurant can still choose to communicate allergen information verbally, but they must be able to point to a written document that supports that verbal communication.
For resort properties with high staff turnover, this creates a specific risk: the person responding to a guest's allergen query may not know the answer, and may not have an authoritative document to consult. That's the gap the regulation was designed to close.
Civil and Criminal Liability
Non-compliance with Regulation 1169/2011 exposes operators to both civil liability (guest injury claims) and regulatory enforcement action. In serious cases — particularly where a guest suffers a severe allergic reaction due to undisclosed allergens — criminal liability can attach to the individual responsible for food safety management at the property.
In the UK, Natasha's Law (2021) extended labelling requirements to pre-packed-for-direct-sale food. Ireland, France, Germany, and the Netherlands have all brought enforcement action against hospitality operators in the past three years.
The trend is not toward more lenience.
The Practical Standard of Care
What does appropriate due diligence look like in practice? Based on our work across hospitality groups, we recommend:
1. Written recipe cards with allergen declarations for every dish — not just flagged items 2. Auto-verification whenever a recipe changes — manual checks have human error rates 3. Version control — you need to be able to show that the card on the wall matches the current recipe 4. Staff access at point of service — a guest query at the table should be answerable from a device, not from memory
ExeChef is built specifically to meet this standard. If you're not currently there, the free Kitchen Audit will show you exactly where the gaps are.
Free Kitchen Audit
See where your kitchen stands right now
8 questions. 60 seconds. Instant results. No email required to see your score.
Take the Free Audit →