Allergens at the counter, on the QR menu and at the kiosk

It is the second week of December. A party of twenty-eight has the back room, the buffet is out, and a guest holds up a plate and asks whether the dressing has nuts in it. The cook who made it has gone home, and the person on the floor does not know. Somebody guesses. That guess is the moment the rules on allergen information were written for.

The rules are short. One EU regulation lists what must be declared, and one Finnish decree says how a restaurant declares it for food that is not in a package. Here is what they ask, read from the current texts on Finlex and EUR-Lex and from Ruokavirasto’s guidance.

The fourteen

Regulation (EU) No 1169/2011 makes it mandatory to declare any ingredient or processing aid listed in its Annex II, or derived from one, that is used to make a food and is still present in the finished product, “even if in an altered form”.¹ Annex II has fourteen entries:¹

• cereals containing gluten: wheat (such as spelt and khorasan wheat), rye, barley and oats;
• crustaceans;
• eggs;
• fish;
• peanuts;
• soybeans;
• milk, including lactose;
• nuts, meaning eight named tree nuts: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamia nuts;
• celery;
• mustard;
• sesame seeds;
• sulphur dioxide and sulphites at more than 10 mg/kg or 10 mg/litre, as total SO2;
• lupin;
• molluscs.

Each entry also covers products made from it, and several carry narrow exceptions, such as fully refined soybean oil or wheat-based glucose syrups.¹ Peanuts are their own entry, separate from nuts, and “nuts” means only the eight listed.

Unpacked food: in writing, or a sign that says ask

For food sold without prepackaging, the regulation makes allergen information the one particular that is always mandatory, and lets each member state decide how it is given (Article 44).¹ Finland’s answer is decree 834/2014 of the Ministry of Agriculture and Forestry. Its definition of unpacked food includes food packed at the customer’s request, food prepacked on the premises for direct sale and food served on the premises ready to eat.² A plate in the dining room, a portion from the buffet and a sandwich wrapped at the counter are all covered.

Section 6 says the customer must be told of every Annex II ingredient used in making the food and still present in it, named so that the Annex II substance is clear. There is one exception: if the name of the food already shows the substance, it need not be repeated.²

Section 8 says how. The main rule is in writing, at the premises, near the food, in a clearly visible brochure, on a board or in a similarly clear way. The information may instead be given orally, but only when both of these hold:²

• a clearly visible notice near the food says the information is available from staff on request, or that the customer can get it in writing or electronically before the purchase decision at no extra cost;
• the information exists in writing or electronically at the premises, easily available to staff and to the food control authorities.

“Ask staff” is allowed. Staff with no list to check is not.

The answer has to exist before the question

The second condition is the one owners skip. The oral route is not permission to answer from memory: the decree requires the written or electronic information to be on the premises and easy for staff to reach.² Ruokavirasto’s page for consumers puts the rule in two sentences: the information is given in writing at the place of sale, and orally only if that option is clearly announced near the food.³

In practice the weak point is change, not ignorance. A wholesaler swaps a bread, a sauce is thickened with something else, a dessert gets a crumble on top for the party season. The dish keeps its name and its place on the menu while what is in it moves. Whatever the written list is, it has to move with the recipe. A simple way to make sure it does is to put the check into your own-check routine, omavalvonta: a new product from a supplier is read for allergens before it reaches a plate.

Buffets and pikkujoulu parties

A buffet is unpacked food served ready to eat, so section 8 applies as it stands. The plain way to meet it is a card at each dish naming its allergens, which is the “in writing, near the food” of the main rule. A notice at the start of the line saying that staff can tell guests about allergens also works, as long as the written information behind it is at hand for whoever is on the floor that evening.²

Party bookings have a third route. Section 8 drops the separate notice when the guests’ allergies and special dietary needs were found out in advance and written down, and the food is served to each guest on that basis.² A booking form that asks about diets and a list the kitchen cooks from is that situation.

Note what is dropped: the notice about how the information can be had, not the duty to know what is in the food. A guest who never filled in the form still eats from the same buffet, and the plus-one who arrives at nine was on nobody’s list.

Online, QR and kiosk: before the order is placed

Food ordered without the seller present is distance selling. The regulation defines a means of distance communication as any means that can be used to conclude a contract without the simultaneous physical presence of the supplier and the consumer.¹ For unpacked food sold that way, Article 14 applies its distance selling rule: the allergen information must be available before the purchase is concluded, in the material supporting the sale or by other appropriate means the business clearly identifies, at no extra cost, and it must also be available at the moment of delivery.¹

Ruokavirasto applies this to food sold through web shops and mobile apps: the mandatory information is given in the distance selling material or in another suitable way, and the business doing the distance selling is responsible for it.⁴ For a delivery or take-away order from your own web shop, the order page is where the guest reads it, and the bag that arrives should not contradict it.

The QR menu at a table and the kiosk by the door sit in between. The guest orders from a screen, but in premises where staff are very much present. We found nothing in the regulation, the decree or Ruokavirasto’s pages that settles whether that counts as distance selling, so we will not guess. The practical answer is the same either way. Section 8 of the decree already accepts information that is available electronically before the purchase decision,² and at a kiosk there is nobody standing next to the guest to be asked. If the screen takes the order, the screen should carry the allergens.

Who checks

Allergen information is part of ordinary food control. In Ruokavirasto’s words, the competent control authority is most often a municipal official, and Ruokavirasto directs and develops food control across Finland.⁵ For a restaurant that means the municipal food control inspector who visits the kitchen. The decree’s requirement that the written information be easily available to the control authorities means it is something the inspector can ask to see.²

One list, many menus

A restaurant that sells over the counter, from a printed menu, a QR menu, a kiosk and a web shop has five places where a dish’s allergens can be written. Typed by hand into each, they drift, and the copy that is wrong is found by the guest it makes ill. The law does not ask for a single source. It asks every channel to tell the truth, and one list per dish, read by every channel, is the cheapest way to make that true on a Friday night.

Hand-made menus lose a second distinction as well. A dish with no allergens and a dish nobody has checked look the same when the field is empty. They are different claims, and only the first can be shown to a guest as safe.

A one-minute check before service

• Every dish has its Annex II allergens written down, and the list is where staff can reach it during service.Section 8 asks for this even when you answer orally.
• If you rely on “ask staff”, a clearly visible notice near the food says so.Near the food and easy to notice, not on the back of the door.
• Recipe and supplier changes are read for allergens before the dish goes out.The name stays the same. The contents do not.
• Each buffet dish has a card, or the line has a notice and staff know where the list is.Party season is when temporary staff work the buffet.
• Party bookings ask about allergies and diets in advance, and the kitchen works from that list.That removes the separate notice for those guests, not the duty to know.
• Your web shop shows allergens before the order is placed.And the information is available at delivery too.
• The kiosk and the QR menu say the same as the list behind the counter.If they are read from one source, they cannot disagree.

What this means for your till

The rules ask for little at the moment of the question and a lot over time: every dish declared, every change caught, every channel saying the same thing. That is a job for the product data, not for whoever happens to be on shift.

In Fizzy a dish’s allergens are entered once, on the product: the fourteen from Annex II, a separate “may contain traces of” list and a free note. A dish nobody has declared is stored as not stated, never as none, and is shown that way. The kiosk and the QR table menu show the declaration on each dish and let the guest hide what they cannot eat, and anything undeclared is hidden by that filter too. A kiosk’s setup lists every undeclared dish as a blocker. The web shop shows what a dish contains, or says the allergens are not declared and to ask staff; it does not yet show the traces list.

At the counter, the till’s part is table service: staff record a guest’s allergies against their seat, the dishes that conflict are flagged, and the allergy prints on the kitchen ticket. For “is there nut in this?” over the counter, keep the written list behind the bar, which you need in any case.

Sources

1. Regulation (EU) No 1169/2011 on the provision of food information to consumers, consolidated text of 01.01.2018: Article 2(2)(u), Article 9(1)(c), Article 14(1) and (2), Article 44 and Annex II as amended by Delegated Regulation (EU) No 78/2014. · eur-lex.europa.eu
2. Maa- ja metsätalousministeriön asetus elintarviketietojen antamisesta kuluttajille 834/2014, as amended by 1042/2016 and 154/2019: section 3 (definition of unpacked food), section 6 (allergens in unpacked food) and section 8 (in writing, or orally with a notice; information available to staff and control authorities; advance dietary information). Quoted in our translation. · finlex.fi (in Finnish)
3. Ruokavirasto, Pakkaamattomat elintarvikkeet (allergens in unpacked food, page for consumers), last updated 13.09.2023. · ruokavirasto.fi (in Finnish)
4. Ruokavirasto, Elintarvikkeesta annettavat tiedot etämyynnissä (food information in distance selling), section on unpacked food sold through web shops and mobile apps, and responsibility of the business doing the distance selling. Last updated 18.03.2026. · ruokavirasto.fi (in Finnish)
5. Ruokavirasto, Valvonta (food control for food businesses): the competent control authority is most often a municipal official; Ruokavirasto directs and develops food control nationwide. Last updated 02.01.2026. Quoted in our translation. · ruokavirasto.fi (in Finnish)
6. Decree 154/2019 amending 834/2014: new sections 7, 7 a and 8, in force from 01.05.2019 for a fixed period; the period was extended by decrees 179/2021 and 197/2023, and by decree 41/2025 to 30.04.2029. · finlex.fi (in Finnish) · finlex.fi (in Finnish)