Is it enough to state allergens verbally at the table?

Verbal information is permitted, but it does not remove the documentation duty. The LMIDV requires a written or electronic record of the ingredients used, directly and easily accessible to the authority and, on request, to the guest. The option of asking has to be signposted. A well-kept online menu covers the documentation requirement and the guest information in one step.

Does the menu have to be a PDF or a web page of its own?

The ordinance prescribes no format, only an outcome: the information has to be clearly visible, distinct and legible, and it has to reach the guest before the purchase is concluded. A PDF can meet that, but on narrow screens it often fails on legibility because it does not reflow. An HTML page adapts to the width, is read out by screen readers and can be found on its own. The sensible arrangement is the HTML menu as the primary route with the PDF as an additional download.

Which allergens have to be named?

Annex II of the LMIV lists the groups exhaustively: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk including lactose, nuts, celery, mustard, sesame seeds, sulphur dioxide and sulphites, lupin and molluscs. That is fourteen groups, each including products derived from them. Other ingredients may be added, but they replace none of the fourteen.

How often should the online menu be updated?

Whenever something changes that affects the guest: new dishes, changed prices, changed recipes. What works in practice is maintaining the online menu in the same step as the printed one, so no second task is created. A visible change date is the simplest self-test: if it shows last year, the internal process is not yet running.

Does the German accessibility act apply to a restaurant?

The BFSG has applied since 28 June 2025, but it addresses specific products and services and exempts micro-enterprises. Under section 2 no. 17 BFSG, a micro-enterprise employs fewer than ten people and has an annual turnover of at most 2 million euros. Most hospitality businesses therefore fall outside the duty. The technical criteria - contrast, font size, operability - still overlap closely with what the LMIDV means by legibility.

What does a well-kept menu on the website cost?

The effort depends on three things: the size of the menu, the number of languages, and whether the business is meant to edit it itself. Setting up a code system, a key and an editing screen once is manageable; it becomes expensive only when every price change has to be commissioned externally. We usually handle this as a fixed price for the setup plus optional support. An orientation is on our [pricing](/en/pricing/) page.

Menus online: current, readable and with allergen labels

The menu is the most-read page on a restaurant website and often the worst-kept one. It sits there as a photographed sheet, dated the summer before last, and anyone wondering whether the creamy pork contains celery finds no answer. Guest expectations are unambiguous: 53 percent (Bitkom) look at the menu online before entering a restaurant they do not know. The legal position is as clear: for non-prepacked food, meaning every plate from your own kitchen, information on the 14 allergen groups is mandatory (LMIV). This article shows what such a menu looks like - current, readable on a phone, allergens labelled. The wider context is on our page about web design for hospitality businesses.

Key takeaways

Annex II of the EU Food Information Regulation lists 14 allergen groups exhaustively; Article 44(1)(a) makes the information mandatory for non-prepacked dishes as well (LMIV).
The German implementing ordinance names electronic information offerings explicitly as a permitted route (LMIDV) - a well-kept website carries the mandatory information, but it also needs a notice on the premises saying where to find it.
53 percent of guests read the menu online first (Bitkom), 65 percent among 16- to 29-year-olds; 50.89 percent of page views in Germany come from phones (StatCounter).
A menu published as a PDF or photo is neither searchable nor readable aloud: 13 to 14 percent of web images carry no alt attribute (Web Almanac 2025).
Maintenance beats effort: change prices, ingredients and codes in one place, put a date underneath, and the menu stays dependable.

What the law asks of a menu

The basis is European. The Food Information Regulation (LMIV) states in Article 44(1)(a) that for non-prepacked food the declaration of allergenic ingredients remains mandatory, even where the other mandatory particulars fall away. A plate from your kitchen needs no nutrition table, but it does need its allergens. How that information has to be provided in Germany is set out in the implementing ordinance on food information (LMIDV). Its section 4(3) lists the permitted routes and names, word for word, the option of stating them on menus and price lists. The menu is not one possible place among many; it is the place the legislator had in mind.

The same provision is equally explicit about "other written or electronic information offerings provided by the food business operator" (LMIDV). A website is not a second-class substitute, then, but a route foreseen by the rules. An operator who keeps the menu clean online discharges a duty that would otherwise run through notices, folders and shouted answers. Two requirements come attached, and both are design questions. The information has to be provided in a way that is clearly visible, distinct and legible, and the guest has to be able to take note of it before the purchase is concluded and before the food is handed over. A menu that appears only after ordering fails that, and grey type on a beige ground very likely does too. One requirement comes on top: anyone choosing the electronic route has to state, on the food itself or by notice in the premises, how the information is provided - section 4(3) sentence 5 LMIDV, so the website on its own is not enough. And the electronic route applies only as long as the information stays directly and easily accessible for consumers and mass caterers.

Which substances are meant is not a matter of interpretation. Annex II of the LMIV lists the groups exhaustively, numbered 1 to 14; the final entry reads "Molluscs and products thereof". These 14 allergen groups are the complete scope of the duty:

Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut) and products thereof
Crustaceans and products thereof
Eggs and products thereof
Fish and products thereof
Peanuts and products thereof
Soybeans and products thereof
Milk and products thereof, including lactose
Nuts, meaning almonds, hazelnuts, walnuts, cashews, pecans, brazil nuts, pistachios, macadamias
Celery and products thereof
Mustard and products thereof
Sesame seeds and products thereof
Sulphur dioxide and sulphites above a defined concentration
Lupin and products thereof
Molluscs and products thereof

Verbal information does not replace the record

An operator who only names allergens verbally at the table still needs, under the LMIDV, a written or electronic record of the ingredients used in preparing the dish in question. That record also has to be directly and easily accessible - to the competent authority and, on request, to your guests as well (LMIDV). A well-kept online menu takes on both roles: information for the guest, evidence for the business, in a document updated anyway.

Who reads the menu before arriving

The idea that the menu gets opened at the table stopped being accurate some time ago. 53 percent of people in Germany say they usually look at the menu online before visiting a restaurant that is new to them (Bitkom); among 16- to 29-year-olds the figure is 65 percent. The numbers come from a telephone survey of 1,005 people aged 16 and over (Bitkom), not from a poll among newsletter subscribers. That moves the moment of decision: not at the door, but twenty minutes earlier on a sofa - and it goes against anyone whose menu is not findable or not readable then.

A second expectation sits alongside it. 42 percent of respondents would like to call up the menu digitally in every venue, for example via a QR code at the table (Bitkom). Point that code at a PDF the guest has to pinch-zoom across and you meet the expectation technically while missing it in practice. For 30 percent, online reviews are the most important criterion when choosing (Bitkom) - and reviews often turn on the very points a menu could have settled beforehand: price level, choice for vegetarians, handling of intolerances.

The device is settled too. 50.89 percent of page views in Germany came from mobile devices in August 2026 (StatCounter), against 47.38 percent from desktop machines. The menu is read mostly on a surface narrower than the sheet it was typeset for. What follows from that in design terms is set out in our article on mobile-first web design.

Before the visit

The guest checks price level, choice and intolerances. The menu has to be readable without a login, without a download and without zooming.

At the table

The QR code leads to the same page. Serve a PDF here and you push the guest into a separate viewer with its own controls.

After a change

The weekly switch or the spring menu is in place within minutes - otherwise it tends not to happen, and the menu quietly goes stale.

PDF, photo or HTML

The most common solution is the weakest: the menu is set in a word processor, exported as a PDF and linked, or photographed and embedded as an image. Both look tidy on a desktop screen and fall apart on a phone. A PDF does not reflow, it scales; the guest sees a page the size of a postage stamp and starts swiping. A photo does not exist at all for screen readers - and 13 to 14 percent of all images on the web carry no alt attribute, with a further 30 percent using an empty one (Web Almanac 2025).

Weight argues against it as well. The median mobile home page now comes to 2,362 KB, against 845 KB back in July 2015 (Web Almanac 2025). The largest share of that is images, at a median of 911 KB. Inner pages - and that is where the menu lives - have grown by 27.8 percent to 1.8 MB. A menu embedded as an image adds to exactly that category, on every request and for every guest not on wifi. The levers are in our article on improving loading speed.

Aspect	Menu as PDF or photo	Menu as an HTML page
Readability on a phone	Fixed page width, zooming and swiping	Text reflows to the available width
Screen readers	Photos without alt text carry no content	Headings, lists and codes are read out
Findability	Individual dishes barely surface in results	Every dish is indexable text of its own
Allergens	Footnote inside an image, not searchable	Codes with explanations, filterable if wanted
Changing a price	Re-typeset, export, upload	Edit one field, save, done
Data volume	Frequently several megabytes per request	A few kilobytes of text plus styling

The objection from practice usually runs: the PDF looks like the printed menu. True, but that is not the goal. The printed sheet is set for paper and read calmly from top to bottom; the online menu gets skimmed in passing, usually in search of one piece of information. The two may differ as long as the content is identical. What works is the print PDF as an additional download and the HTML menu as the primary route - not the other way around.

Legible means measurable

"Clearly visible, distinct and legible" is wording from the ordinance, not a matter of taste. For contrast there is a standard with hard numbers: under WCAG 2.2, normal text needs a contrast ratio of at least 4.5:1 (W3C) and large text at least 3:1, with large starting at 18 point or 14 point bold. This is where many menus fail: delicate greys on a cream ground look refined on a designer's screen and are unreadable on a phone in midday sun. Only 31 percent of mobile sites meet the minimum contrast requirement at all (Web Almanac 2025).

The second variable is the type itself. A menu carries many short lines, tightly set, often with codes and prices in their own column. What works at 9 point on paper needs 16 pixels on a phone and enough leading to keep the lines apart. The third variable is touch targets: if allergens sit behind a tappable code, that target has to be big enough for a thumb. A superscript four pixels across is decorative, not operable. We have collected the measurable criteria in our article on the German accessibility act.

The accessibility act does not apply directly to most restaurants

The German Accessibility Strengthening Act came into force on 28 June 2025 (Bundesfachstelle Barrierefreiheit). Under section 2 no. 17 BFSG, a micro-enterprise is one with fewer than ten employees and a turnover of at most 2 million euros; the exemption for services follows from that. Most restaurants and cafes fall outside the duty. The criteria stay useful, because they measure what the LMIDV means by "legible" - with numbers instead of adjectives.

Contrast of menu text against its background at least 4.5:1, including over background images and gradients
Base font size 16 pixels, prices and codes no smaller than 14 pixels
Codes marked up as abbr elements with the spelled-out meaning, not as a bare superscript
Touch targets for expandable explanations at least 24 by 24 pixels
Menu readable without zooming at a viewport width of 360 pixels
Date of the last change visible at the foot of the menu

Labelling allergens properly

Three patterns have proven themselves, and they do not exclude one another. The first is the code column: each dish carries a short row of letters on the right, the key underneath. That is the printed sheet carried across, and it works online as long as the key sits on the same page. The second is a spelled-out line under the dish: "Contains milk, eggs, cereals containing gluten." It costs space, needs no cross-referencing and is read out in full by screen readers. The third is the filter: the guest picks an intolerance and the menu hides what does not fit.

Technically the code column is the least intrusive and the cleanest foundation. What matters is that the code stays connected to its meaning in the markup - then a screen reader says "cereals containing gluten" instead of "A", and any later filter has dependable data to work with.

menu.html

<li class="dish">
  <h3>Cheese spaetzle with fried onions</h3>
  <p class="price">14.50 euros</p>
  <p class="allergens">
    Allergens:
    <abbr title="Cereals containing gluten">A</abbr>,
    <abbr title="Eggs">C</abbr>,
    <abbr title="Milk including lactose">G</abbr>
  </p>
</li>

The filter is the optional extra, not the duty. It starts to pay off from around thirty items and assumes that allergens exist per dish as data rather than as typed text. Set it up that way from the start and you can later filter, sort and publish the menu as structured data without rebuilding - which improves how it appears in search results. What that looks like technically is covered in our article on structured data and rich snippets.

A word on diligence: labelling is not a formality. Undeclared allergens are among the most frequent grounds for recalls in Germany - roughly one in nine of 2,743 recalls since the national warning portal began (BVL), with 30 recall notices of this kind in the first half of 2025 alone. Official inspection is no rare event either: in Berlin in 2024, breaches were recorded at 4,530 of 15,664 inspected businesses (Senatsverwaltung für Justiz und Verbraucherschutz Berlin), although that statistic does not break the breaches down by type.

The number of people affected explains why the rule is drawn tightly. More than 23 million people in Germany live with an allergic condition (Deutscher Bundestag 2022); lifetime prevalence of medically diagnosed food allergy among adults is 4.7 percent (Robert Koch-Institut 2016). For these guests the menu is not a service element but the basis of a decision. Keep it clean and you win guests who would not have ordered anywhere else.

Upkeep: who changes what, and how often

Even the best-built menu goes stale when nobody owns it. The most common reason for a 2023 menu on a website is not carelessness but a gap in responsibility: the business updates the printed sheet, the website sits with a service provider, and the route there runs through an email nobody enjoys writing. The fix is organisational, not technical. The menu belongs somewhere the kitchen can edit it, with a process that takes five minutes.

One person owns it - usually the head chef, because that is where the recipes live.
Every recipe change goes into the ingredient list first; the allergen codes follow from it, not the reverse.
Price and menu changes are entered online in the same working step as in print.
The menu carries a visible date of last change, the simplest self-test for upkeep.
Once a quarter the key is read back against the ingredient list so that no code is left orphaned.
Seasonal menus keep the address of the main menu so existing links and QR codes stay valid.

That last point gets underestimated regularly. A QR code on the table, a notice in the window, an entry in the business profile: each points at an address that still has to be correct after the next menu change. Create a new address every season and you spread visibility across half-dead pages while printing codes that lead nowhere. The same logic applies when the domain itself changes; how such a move runs without downtime is described in our article on moving domain and email.

A menu is not a document but a state. It stays correct exactly as long as somebody picks it up again at the next changeover.

Internetagentur Hildesheim

Making sure the menu gets found

A menu nobody finds satisfies the information duty but brings in no guests. Three things decide findability. First the address: the menu belongs on its own descriptive page, not in an accordion on the home page. Second the description: the line that appears under the title in search results is set on only 67.2 percent of mobile pages - almost one page in three is missing it (Web Almanac 2025), even though titles are set almost everywhere. Third the speed: 62 percent of websites deliver their largest content on phones in good time (Web Almanac 2025), and the rest lose visitors before the menu even appears.

Then the local part. The menu belongs in the business profile as a link, reachable straight from the map view; how that profile is maintained is covered in our article on the business profile. Whether the page is found can be measured rather than assumed - which figures are worth reading and which mislead is set out in our article on reading Search Console data.

On loading time a menu is a rewarding case: it is almost entirely text. An HTML menu with thirty items and a key comes to a few kilobytes; the same thing as an image quickly costs a megabyte. For the technical thresholds behind that, our article on the Core Web Vitals has them.

What it costs - and what it saves

Economic conditions in hospitality leave no room for unexplained spending. Germany last counted 202,110 VAT-registered hospitality businesses, 9.1 percent fewer than in 2019 (DEHOGA), and real turnover in 2025 was still 14.8 percent below the pre-crisis year (DEHOGA). Against that background, a menu an agency has to touch for every change is a recurring cost nobody needs. That is why maintainability matters more than appearance: what the business can change itself costs once and nothing thereafter.

On the credit side sit three effects that are hard to price individually but noticeable in daily operation. Service is relieved, because questions about ingredients get rarer and can be looked up in doubt. The evidential position improves, because the record of ingredients has to be kept anyway and the online menu gives you a maintained document. And reach grows, because every dish becomes findable text instead of disappearing inside an image. If you want to gauge what that means for your business, the service overview is at web design, ongoing support at maintenance and the commercial framework at pricing.

For businesses in and around Hildesheim there is a regional angle: anyone searching for a restaurant here with an intolerance in mind decides on the strength of the menu. How local visibility is built up systematically is in our article on local visibility. For an outside assessment of your current menu, get in touch through the contact form or see our page on web design for hospitality businesses.

Sources and studies

This article draws on: Regulation (EU) 1169/2011 (LMIV), Annex II and Article 44; the German implementing ordinance on food information (LMIDV), section 4; Bitkom, press release on restaurants and cafes (2024, 1,005 respondents aged 16 and over); StatCounter, platform market share Germany (August 2026); Web Almanac 2025, chapters on Page Weight, Accessibility, Performance and SEO; W3C, WCAG 2.2 success criterion 1.4.3; the German Federal Office of Consumer Protection and Food Safety (BVL), press release of 18 June 2025; Senatsverwaltung für Justiz und Verbraucherschutz Berlin, annual report 2024; Robert Koch-Institut, position paper on the prevalence of allergies; Deutscher Bundestag, hib 436/2022; DEHOGA Zahlenspiegel IV/2025; Bundesfachstelle Barrierefreiheit and section 2 BFSG.