Allergens and olive oil labelling in restaurants: what regulations require

The management of olive oil-related allergens in restaurants is governed by European Regulation INCO (EU) No 1169/2011. While pure extra virgin olive oil is not among the 14 major allergens that must be declared, flavored oils used in the kitchen or dining room may contain them. Here's what you need to know to comply.

What the regulations say about allergens in restaurants

Regulation (EU) No 1169/2011, known as the INCO Regulation, is the reference text for consumer information on food products. It applies to products sold in supermarkets as well as to dishes served in commercial catering establishments. It lists 14 major allergens whose presence must be indicated, whether on a label, a menu, or any other information medium.

These 14 allergens are as follows:

1. Cereals containing gluten
2. Crustaceans
3. Eggs
4. Fish
5. Peanuts
6. Soybeans
7. Milk
8. Nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts)
9. Celery
10. Mustard
11. Sesame seeds
12. Sulphur dioxide and sulphites (at concentrations of more than 10 mg/kg or 10 mg/L)
13. Lupin
14. Molluscs

In restaurants, the declaration obligation applies to dishes offered for sale. Since October 1, 2021, in France, amended Decree No. 2015-447 requires that allergen information be available in writing upon customer request, in the form of a document consultable in the dining room or kitchen. Oral mention is no longer sufficient.

To manage all your olive oil and Italian product supplies under this obligation, the space dedicated to HORECA professionals allows you to obtain the technical sheets and supplier information necessary for your allergen file.

Olive oil allergens in restaurants: what you must declare

Pure extra virgin olive oil

Extra virgin olive oil, in its pure form, does not contain any of the 14 major allergens listed by the INCO regulation. It comes exclusively from the fruit of the olive tree, with no added third-party ingredients. As such, it does not require any specific allergen declaration in your technical sheets or on your menu.

This does not exempt you from checking the technical sheets of each lot received. A reputable supplier systematically provides a certificate of analysis specifying the origin, grade, and absence of cross-contamination. If you use a 5-liter organic Italian olive oil container for your cooking and seasoning stations, keep the label or product sheet in your allergen binder: this is the documentary proof you can present in case of an inspection.

Flavored and infused oils

The situation is different for flavored or infused oils. An olive oil with garlic and chili may contain sulfites if the added ingredients contain them. A herb oil may contain celery depending on the composition of the aromatic blend. A mustard oil is, by definition, a declarable allergen.

The distinction between an infused oil and a flavored oil is important here for traceability. An infused oil is obtained by co-milling the olives with the fruit or aromatic herb at the time of crushing: the ingredients are integrated from production. A flavored oil is obtained by adding natural or synthetic flavors after extraction: the composition may vary depending on the lots. In both cases, the supplier's technical sheet must specify the complete list of ingredients and the allergens present or likely to be present through cross-contamination.

If you offer a pure organic green fruity olive oil in the dining room, no allergen declaration is required. If you offer a flavored oil, always check the technical sheet before integrating it into your menu or preparations.

Labeling and traceability of olive oil in professional kitchens

Retaining supplier information

Traceability is the cornerstone of your allergen compliance. For each olive oil reference used in your establishment, you must be able to provide the following elements:

1. The commercial name and legal designation of the product
2. The list of ingredients with allergens highlighted
3. The name and contact details of the supplier
4. The lot number
5. The minimum durability date

This information is on the original packaging label. For a 5-liter container used in the kitchen, keep the label or photograph it before discarding the packaging. For a large serving format such as a jeroboam of organic extra virgin olive oil used in the dining room or at events, the same principle applies: the original label must remain accessible.

An up-to-date allergen binder, with a sheet for each reference used, is the simplest solution to respond to an inspection by the Departmental Directorate for Population Protection or a request from an allergic customer.

The bottle in the dining room: a specific labeling obligation

When you place a bottle of olive oil on the table, regulations require it to be labeled and fitted with a tamper-proof, non-refillable stopper. This obligation has been in force in Italy, Spain, and Portugal for several years. In France, no equivalent obligation currently exists for restaurants, but the practice of refilling oil cruets from a bulk container poses a traceability risk: if a customer reports a reaction, you cannot prove the exact origin of the product served.

A sealed bottle with your name, a complete label, and a visible lot number is the safest solution. It meets both the traceability obligation and customers' growing expectation for transparency. For establishments that wish to go further, personalizing olive oil bottles with your brand allows you to combine regulatory compliance and the establishment's visual identity, starting from 24 bottles.

Summary: allergens and declaration obligations by oil type

Here are the four situations you will encounter in practice:

1. Pure extra virgin olive oil: no major allergens, no declaration required (unless cross-contamination reported by the supplier).
2. Pure virgin olive oil: same situation, no major allergens, no declaration required.
3. Infused oil by co-milling (garlic, chili, herbs): sulfites possible depending on the ingredients used. Mandatory declaration if an allergen is present. Check the technical sheet for each lot.
4. Flavored oil by adding aromas after extraction: celery, mustard, or sulfites possible depending on the composition. Mandatory declaration if an allergen is present.

In all cases, the supplier's technical sheet is the reference document. Lucangeli makes product sheets for its entire range available to professionals via its commercial service dedicated to establishments.

Frequently asked questions

Is olive oil an allergen to declare in a restaurant?

Pure extra virgin olive oil is not among the 14 major allergens defined by Regulation (EU) No 1169/2011. Therefore, it does not require any mandatory declaration as an allergen. However, flavored or infused oils may contain allergenic ingredients depending on their composition: the supplier's technical sheet is essential to verify this.

Do I have to display allergens on my menu if I use olive oil?

If you use pure extra virgin olive oil, no specific allergen mention is required on the menu. If you use a flavored oil containing one or more of the 14 major allergens, you must inform your customers. Since October 1, 2021, this information must be available in writing upon request, in accordance with amended Decree No. 2015-447.

What should I do if a customer asks me for the list of allergens in the olive oil used in the kitchen?

You must be able to provide them with the information in writing. Keep the technical sheets and labels for each reference used in an allergen binder accessible in the kitchen and dining room. For pure extra virgin olive oil, the answer is simple: no major allergens. For flavored oil, refer to the technical sheet for the current batch.