EU FIC Update 2026: What Changes in Allergen Labelling on Restaurant Menus

Regulation 1169/2011 (known as EU FIC, Food Information to Consumers) has governed how we label allergens on menus for over a decade. An update entered into force in March 2026, changing several things in practice for small restaurants. Most owners still do not know - until the first inspection, the first allergic reaction in a guest, the first complaint on social media.

This post shows what exactly has changed, who it affects, and what you have to do in your restaurant in the next 60 days to sleep at night.

What FIC 2026 changed in 3 points

1. Sesame and sesame products as a separate category. Previously, sesame was "hidden" inside the group of 14 allergens as an ingredient. Now it needs separate labelling, due to rising allergy cases in the European population (mainly children under 10 years old).

2. Obligation to provide written allergen information on request. If a customer asks the waiter about allergens in a specific dish, the restaurant must have a system that allows giving the answer in writing (on customer request). Verbal "yes, it has" or "no, it does not" is enough by default. But if a customer says "please provide it in writing", you must deliver in a reasonable time.

3. Cross-contamination communication must be visible. If the kitchen uses a product from the 14-allergen list but the dish itself does not contain it, you must flag this (typically: "may contain traces of X"). This is not new, but from 2026 the EU expects that this information is available BEFORE ordering, not after.

14 allergens: what exactly this covers

The list of 14 mandatory allergens to label (reminder + changes):

1. Gluten (wheat, rye, barley, oats, spelt, kamut)
2. Crustaceans
3. Eggs
4. Fish
5. Peanuts
6. Soy
7. Milk (lactose)
8. Tree nuts (almond, hazelnut, walnut, cashew, pecan, brazil, pistachio, macadamia)
9. Celery
10. Mustard
11. Sesame and sesame products (from 2026, separate labelling required, not only as an ingredient)
12. Sulfur dioxide (sulphites) above 10 mg/kg
13. Lupin
14. Molluscs

Restaurants, food trucks, catering, cafes - everyone has the same obligation. Venue size does not exempt from FIC. Even a food truck at an outdoor event must have an allergen card available to the customer.

How to show allergens in the menu (3 accepted formats)

Format A: icons next to the dish. Each allergen has its own graphic marker (typically: G, M, J, R, Sk, So, Sl, S, Or). Under each menu position you list which allergens apply to this dish. Most readable for the customer, simplest to maintain.

Format B: separate allergen card. The menu has no markings, but next to it you have a separate card with a list of dishes and an allergen table (columns: dish name, allergen icon). Good for restaurants with seasonal or frequently changing menus.

Format C: QR code to a page. The menu contains a QR code leading to a page on your restaurant's site where you publish current allergen data. This format is accepted, but must be clearly communicated (typically: "Scan the code to see allergens in our dishes"). Important: the page must work. The sanitary inspector may ask to see it on the spot.

What sanitary inspectors check in 2026

The FIC update means inspectors pay more attention to allergens than in previous years. Most common audit points:

1. Does the menu have any allergen information? Missing this means a fine of 500 to 5000 PLN, depending on scale.
2. Is the information current? A 2023 version that does not reflect a recipe change from 2026 is also a problem. The restaurant must update allergen information with every recipe change.
3. Do waiters know how to answer? The inspector may ask a random waiter "what is in this dish, does it contain gluten". If the team has no idea = the system does not work in practice.
4. Does the kitchen have a cross-contamination management system? Separate boards/knives/containers for allergen products? Are cleaning procedures consistent with menu claims (e.g. "gluten-free" in the menu vs. a shared oven with bread)?

What to do in the next week

A realistic FIC 2026 implementation checklist for a small restaurant:

1. Go through the menu position by position. For each, mark allergens from the list of 14. Pay special attention to sesame (newly required category).
2. Pick one of 3 formats (icons in menu, separate card, QR code). Stick to one, do not mix.
3. Create an allergen table (Excel or Google Sheets): rows are dishes, columns are 14 allergens, mark "X" where allergen occurs. This is your master document from which you generate menu and card.
4. Update cross-contamination information. If you use wheat flour in the kitchen, add a note for "gluten-free" menu items that "may contain traces of gluten".
5. Run a short team training (15 minutes, once every 6 months): what are allergens, how to answer the customer, when "I do not know" is the correct answer ("let me ask the chef"), when always to offer an alternative dish.

Frequently asked questions

What if I have a seasonal menu that changes monthly?

Update allergen information with each menu change. Simplest approach: master document (allergen table) as Excel, from which you generate menu and allergen card together. That is 30 minutes of work each time instead of hours.

Can a customer sue me over an allergic reaction?

Yes, if the reaction resulted from incorrect menu information (you marked "gluten-free" and the dish contained gluten). That is why documentation is a shield, not an ornament. Master allergen document plus kitchen procedures means you can prove due diligence.

Is a QR code to a page a good idea for a small restaurant?

Only if the page is actually maintained. In practice: most small venues do not update their site monthly, so the QR code leads to outdated data. Better: icons directly in the paper menu or an allergen card.

Should my supplier provide allergens?

Yes. Food suppliers have an obligation to declare composition and allergens on the label or product card. If you buy in bulk and have no written allergen information from the supplier, you have the right (and should) demand it. This is part of batch traceability in HACCP.

What about foreign-language cooks?

The allergen list must be available in a language the team understands. If you have a mixed PL/UA/EN team, the master document should exist in three language versions, plus universal pictograms. The sanitary inspector may check this in the context of kitchen procedures.