Food Truck Allergen Requirements: Why You Cannot Ignore Them
In France and across the EU, allergen labeling is not optional — it is a legal obligation governed by EU Regulation INCO No. 1169/2011, which came into full effect on 13 December 2014. As a food truck operator, you are directly covered by this law, on the same basis as a traditional restaurant or sandwich shop.
Each year in France, between 70,000 and 80,000 cases of serious allergic reactions are recorded, including dozens of fatal anaphylaxis cases. A poorly informed customer can hold you civilly and criminally liable. Here is everything you need to know to stay compliant.
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The 14 Major Allergens You Must Know
EU Regulation INCO classifies 14 substances or products as allergens that must be declared when selling non-prepacked food (which includes all dishes prepared and served at your food truck):
- Cereals containing gluten: wheat, rye, barley, oats, spelt, Khorasan wheat…
- Crustaceans: shrimp, lobster, crab, langoustine…
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk (including lactose)
- Tree nuts: almonds, hazelnuts, walnuts, cashews, pecans, pistachios, Brazil nuts, macadamia nuts
- Celery (including seeds and root)
- Mustard (including seeds and leaves)
- Sesame seeds
- Sulphur dioxide and sulphites (at concentrations above 10 mg/kg or 10 mg/litre)
- Lupin (including lupin flour)
- Molluscs: mussels, clams, oysters, squid…
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The INCO Regulation and Its Practical Requirements for Food Trucks
What the Law Says
EU Regulation No. 1169/2011 — known as the INCO Regulation (Food Information to Consumers) — requires all catering professionals selling non-prepacked foods (such as dishes served at a food truck) to communicate allergen information to customers before the purchase.
Unlike prepacked foods (which must list allergens in bold on the label), non-prepacked foods have flexibility on the medium of communication — but the information must be accessible and verifiable.
What This Means in Practice
In practice, three approaches are accepted in France:
- Written information directly on the menu or board: each dish lists the allergens present (e.g., "Classic Burger: Gluten, Eggs, Milk"). This is the clearest and most recommended method.
- General notice with verbal referral: you display a notice such as "For allergen information, please ask our team" and train your staff to respond precisely and reliably. This is legal but carries risk — your team must know every dish's composition by heart.
- Allergen folder or sheet available at the counter: you maintain a summary document (folder or poster) accessible at the counter, listing all 14 allergens for each dish in a grid format. This works particularly well for complex menus.
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How to Display Allergens on Your Food Truck: 3 Practical Solutions
Solution 1 — Menu with Allergen Codes
Number the 14 allergens from 1 to 14 and write the corresponding numbers after each dish on your menu. Example:
| Dish | Allergens | |------|-----------| | Classic Burger | 1, 3, 7 | | Chicken Wrap | 1, 11 | | Caesar Salad | 4, 3, 7 |
This method is compact, easy to print and laminate. Include a legend at the bottom of your menu.
Solution 2 — Large-Format Poster at the Counter
An A3 or A2 laminated poster, displayed at eye level, with a complete allergen × dish grid. It must be readable without glasses from the ordering point. Cost: under €10 when printed through an online printer.
Solution 3 — QR Code Linking to a Digital Sheet
More and more food truck operators use a QR code on their counter or menu linking to a web page that lists all allergens. This is legal as long as a fallback exists for customers without smartphones. With FoodTracks, you can generate and update your digital allergen sheet directly from your dashboard, without reprinting your menu every time a recipe changes.
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Penalties for Non-Compliance: What You Actually Risk
Failing to meet allergen labeling requirements exposes you to serious administrative and criminal penalties.
DDPP Inspections
The DDPP (Departmental Directorate for Population Protection) carries out unannounced inspections at markets, festivals, and fixed pitches. If a violation is found:
- Warning and formal notice for first offences
- Administrative fine of up to €1,500 per offence (5th-class contravention)
- Temporary administrative closure for repeat offences or proven endangerment
- Criminal penalties if a customer suffers physical harm due to missing or incorrect allergen information: up to 2 years' imprisonment and a €30,000 fine for endangering human life
Civil Liability
In the event of an allergic incident at your food truck, your professional civil liability will be engaged. If you cannot prove that information was displayed and accessible, your insurer may refuse to cover you. This is why it is essential to keep written records of your allergen sheets (with update dates).
> Tip: photograph your allergen display regularly during service. This timestamped photographic evidence can protect you in a dispute.
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Common Practical Situations on Food Trucks
"I don't know whether my supplier uses a given allergen"
This is your responsibility to verify. Always ask your suppliers for product technical data sheets and food safety data sheets. Without certain information, you must list the allergen as "may contain traces of…".
"My menu changes every week"
This is precisely where digital management proves its worth. With a tool like FoodTracks, every recipe change automatically updates your allergen grid. You avoid the human error of a display that no longer matches your actual dishes.
"I'm alone on the truck — impossible to memorise everything"
Permanent written display is exactly for you. A laminated grid at the counter requires no memorisation — simply show it to the customer. Also consider basic first-aid training for allergic reactions (knowing how to use an adrenaline auto-injector if a customer signals a severe allergy, and knowing to call 15/112).
"My food truck is a franchise — the brand handles allergens"
Even if your franchisor provides standardised allergen sheets, you remain personally responsible for displaying them at your point of sale. Check that the documents provided are up to date and reflect your actual menu.
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Building a Reliable System: 5 Steps
- List all your ingredients and check each supplier's technical data sheet for all 14 allergens.
- Create an allergen × dish matrix: a simple cross-reference table (rows = dishes, columns = allergens) with ✓ or ✗.
- Choose your display medium: coded menu, counter poster, or digital QR code (or a combination).
- Train your team: every member of staff must know how to answer allergen questions and direct customers to the written source.
- Update with every recipe change: a supplier switch or ingredient modification requires an immediate update. With FoodTracks, this update is centralised and logged.
Conclusion: Allergen Compliance Is an Investment, Not a Burden
Setting up a robust allergen information system for your food truck takes a few hours upfront — but protects you for years. It is also a commercial asset: more and more customers with allergies or intolerances choose establishments where they feel safe.
With FoodTracks, allergen management is built into your recipe cards. Every ingredient is tagged, every dish automatically generates its allergen list, and your display is always up to date. Less risk, less stress, more confident customers.
Try FoodTracks for free and secure your allergen management today.
Read next: Food Truck Regulations in France · Hygiene and HACCP for Food Trucks · How to Price Your Menu
Frequently Asked Questions
- Does the allergen labeling requirement apply to daily specials not listed on the menu?
- Yes. Even a verbally announced daily special must have accessible allergen information — ideally via a blackboard or a sheet at the counter. Verbal information alone has not been sufficient since the DGCCRF guidance issued in 2021.
- What penalties does a food truck operator face for failing to meet allergen labeling obligations?
- Failing to display allergen information can result in an administrative fine of up to €1,500 per offence issued by the DDPP, temporary closure for repeat violations, and criminal prosecution for endangering human life (up to 2 years' imprisonment and a €30,000 fine) if a customer suffers physical harm.
- How should cross-contamination be handled on a food truck?
- If you cannot guarantee the absence of cross-contamination (shared work surface, common utensils, mixed frying oil), you must indicate this with the phrase 'may contain traces of…'. Be honest: a coeliac or severely allergic customer needs to be able to assess the real health risk.
- Is a QR code linking to a digital allergen sheet sufficient for legal compliance?
- A QR code is legal if it links to complete, up-to-date information. However, you must provide a fallback option (paper poster or folder) for customers without smartphones or in cases of connectivity issues. A QR code alone is not sufficient.
- My menu changes frequently. How do I keep my allergen display up to date without spending hours on it?
- The most efficient solution is to use a management tool like FoodTracks, where every ingredient is tagged with its allergens. Any recipe change automatically updates the allergen list for the corresponding dish. You can then print or digitally display the updated grid in one click.
