Allergen course for hospitality in Spain free, with a certificate

• Allergen information is always required, including for food served unpackaged: dishes, tapas, bread, pastries, canteen and catering food. The EU Regulation requires it always, packaged or not (Regulation (EU) No 1169/2011, Article 44(1)(a)).
• In Spain it is governed by Royal Decree 126/2015. It applies to food sold unpackaged, food packed at the customer's request, food the business itself packs to sell in its own shop, and all of these when sold at a distance (Article 2.2).
• Each allergen is given with a clear reference to its name in Annex II of Regulation 1169/2011. This is not needed if the name of the dish already makes it clear, as in «egg omelette» (Royal Decree 126/2015, Article 4.1.b).

In writing or verbally

The information can be on labels or on notices next to the food (Article 6.2). It can also be given verbally, but only on two conditions (Article 6.5.a):

1. Staff can give it easily when the customer asks and before the purchase is completed, at no cost to them.
2. It is recorded in writing or electronically on the premises, available to staff, inspectors and customers who ask for it.

Source: Regulation (EU) No 1169/2011 on the provision of food information to consumers, Articles 9(1)(c) and 44 · Real Decreto 126/2015, food information for non-prepacked foods (consolidated text, in Spanish), Articles 2, 4.1.b and 6.5

What you tell customers about a dish depends on what is in its ingredients. That is why the kitchen starts by reading the labels of what it buys.

• In the list of ingredients, allergens are emphasised with a different font, style or background colour (Regulation (EU) No 1169/2011, Article 21(1)(b)).
• If the product has no list of ingredients, the label says «contains» followed by the allergen.
• If several ingredients come from the same allergen, it is shown for each one.
• Watch out for what does not look like an allergen: a stock, a sauce, a seasoning or breadcrumbs may contain celery, mustard, soya, milk, egg, gluten or sulphites.

When the brand or recipe changes

The same sauce from two different brands can contain different allergens. If you change an ingredient, a supplier or a brand, read the label again and update the dish sheet before serving it.

Source: Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 21 and Annex II · AESAN: labelling of substances causing allergies and intolerances (in Spanish)

The written information required by Royal Decree 126/2015 (Article 6.5.a, 2nd) is usually kept as a sheet per dish or a table of dishes against the 14 allergens. The law does not impose a template: what follows is a practical way to do it.

What it must include

• The name of the dish and all its components: base, sauce, garnish, batter or coating, oil, decoration.
• The 14 allergens in Annex II, ticked one by one: present or not present.
• The date of the last review and who did it.

Where it is kept and who uses it

• Within reach of floor and kitchen staff, inspectors and customers who ask for it.
• It can be on paper or electronic: what matters is that it exists and is easy to check.
• If a dish changes, the sheet changes the same day. An out-of-date sheet gives false information.

Source: Real Decreto 126/2015, food information for non-prepacked foods (consolidated text, in Spanish), Article 6.5.a, 2nd · Regulation (EU) No 1169/2011 on the provision of food information to consumers, Annex II

• If you give the information in writing, it can be on labels stuck to the food or on notices next to it, where it is sold (Royal Decree 126/2015, Article 6.2).
• If you give it verbally, the area where food is sold must have a visible, legible and accessible notice saying where the information is or that customers can ask staff (Article 6.5.b).
• If the premises have several sections (bar, display counter, terrace), that notice must be in each one.
• The notice is not needed if the allergens are already on labels or notices next to the food that can be read before buying (Article 6.5.c).
• Mandatory information goes in a prominent, visible and legible place and cannot be hidden by any other information or image (Regulation (EU) No 1169/2011, Article 13(1), and Royal Decree 126/2015, Article 7).

Icons on the menu?

Neither Royal Decree 126/2015 nor Regulation 1169/2011 requires icons. If you use them, they must match what the dish sheet says and be explained, and the dish of the day must have its information too.

Source: Real Decreto 126/2015, food information for non-prepacked foods (consolidated text, in Spanish), Articles 6.2, 6.5.b and c and 7 · Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 13(1)

The law requires the information to exist and to be given when the customer asks, before the purchase is completed (Royal Decree 126/2015, Article 6.5.a). This is a good-practice protocol for doing it without mistakes.

1. Listen and write down which allergen it is. «Lactose-free» and «milk allergy» are not the same: ask.
2. Check the sheet, not your memory. Never say «I don't think it has any».
3. If the sheet is not clear, say so and ask the kitchen before confirming anything.
4. Mark the order with the allergen, so that the kitchen cannot miss it.
5. Tell the person cooking and the person plating out loud.
6. Carry the dish yourself and separately, not on a tray with other dishes, and confirm to the customer that it is theirs.

What not to do

• Remove the allergen from a dish that is already made (picking the walnuts out of a salad): traces remain. Make it again.
• Promise «zero risk» if the kitchen works with that allergen. Explain what you do to avoid cross-contact.

Source: Real Decreto 126/2015, food information for non-prepacked foods (consolidated text, in Spanish), Article 6.5.a · Regulation (EU) 2021/382 amending Regulation (EC) No 852/2004 (allergens and food safety culture)

Since 2021, Regulation (EC) No 852/2004 says that equipment and containers used for an allergen are not used for food that does not contain it, unless they have been cleaned and checked, at least, for the absence of visible debris (Annex II, Chapter IX, point 9, added by Regulation (EU) 2021/382). The rule covers processing, handling, transport and storage.

The risk points in a kitchen

The law does not give a list of steps. These are good practices for complying with it:

• The fryer: oil used for battered food or fish passes gluten and fish on to the next thing. For an allergic customer, clean oil or a separate fryer.
• Griddles and pans: cleaned before cooking the allergen-free dish.
• Chopping boards, knives, tongs, ladles: clean or dedicated. A ladle that goes from one sauce to another takes the allergen with it.
• Flour in the air when kneading or flouring: the gluten-free dish is prepared away from it or beforehand.
• Storage: closed, labelled containers; anything with allergens at the bottom, so it cannot drip onto other food.
• Hands and gloves: wash your hands or change gloves before preparing the dish.

Source: Regulation (EU) 2021/382 amending Regulation (EC) No 852/2004 (allergens and food safety culture), Annex, point 2(c)

«May contain traces of…»

• It is voluntary information. When given, it must not mislead, must not be ambiguous and must be based on data (Regulation (EU) No 1169/2011, Article 36(2)).
• It does not replace avoiding cross-contact. Putting it on every dish «just in case» does not protect the customer and leaves them with no options.
• Use it only when there is a real risk you cannot avoid, and explain to the customer what it is.

«Gluten-free» and «very low gluten»

• «Gluten-free»: only if the food, as sold, contains no more than 20 mg/kg of gluten (Implementing Regulation (EU) No 828/2014, Annex).
• «Very low gluten»: only for foods made from gluten-containing cereals processed to reduce it, with no more than 100 mg/kg.
• Oats: to be called «gluten-free», they must be produced to avoid contamination by wheat, rye or barley and not exceed 20 mg/kg.
• You may add «suitable for people with coeliac disease» or «suitable for people intolerant to gluten» (Article 3(2)).
• It applies to packaged food and to food served unpackaged (AESAN).
• Do not use it for something that never contains gluten, such as a juice: AESAN considers that misleading, because it implies the product is special.

If you write «gluten-free» on the menu, you must be able to guarantee it: gluten-free ingredients, separate preparation and no cross-contact. If you cannot, do not use any gluten statement: the absence of gluten can only be communicated with these statements and on their conditions (Article 3(1)). Give the allergen information and explain the cross-contact risk.

Source: Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 36 · Commission Implementing Regulation (EU) No 828/2014 on the absence or reduced presence of gluten, Article 3 and Annex · AESAN: labelling of substances causing allergies and intolerances (in Spanish)

Distance selling (website, app, phone)

• Allergen information must be available before the customer buys, on the website or app or by another clear means, at no cost to them (Regulation (EU) No 1169/2011, Article 14(1)(a) and 14(2)).
• It must also be available at the moment of delivery (Article 14(1)(b)).
• Royal Decree 126/2015 also applies to food sold at a distance (Article 2.2.d).

What you pack yourself to sell on your premises

Salads, sandwiches or meal boxes that you pack to sell in your own shop carry a fuller label, with the list of ingredients and the allergens emphasised (Royal Decree 126/2015, Article 5.1). It goes on the pack or on a label attached to it. If it is sold over the counter by staff, everything except the use-by or best-before date can go on a notice where it is sold (Article 6.3).

On delivery

• The allergic customer's order goes sealed and marked, so it cannot be mixed up with another.
• Check that any sauce or extra added at the end does not contain the allergen.

Source: Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 14 · Real Decreto 126/2015, food information for non-prepacked foods (consolidated text, in Spanish), Articles 2.2.d, 5.1 and 6.3