QR menus in Italy: allergens, duties and fines in 2026

A QR code menu is legal, but on its own it is not enough. Two things have to hold at once: allergens must be declared by law, with fines from 3,000 to 24,000 euros if they are missing, and a version readable without a smartphone still has to be available in the room. The QR code sits next to the paper menu, it does not retire it.

These are two separate rules and they get mixed up constantly. Keep them apart.

Allergens: here the law is blunt

EU regulation 1169/2011 requires the 14 allergens to be declared. It is not a recommendation and it does not apply only to restaurants: bars, pizzerias, takeaways, catering, canteens and pastry shops are all covered. Italy implemented it through legislative decree 231/2017, and that is where the penalties sit: 3,000 to 24,000 euros for failing to declare. Where the missing information causes a serious allergic reaction, criminal liability is added.

Two details decide how an inspection goes. The information has to be available before the customer orders, not once the plate is on the table. And it has to be tied to the individual dish: a general sign saying "our dishes may contain allergens" makes nobody compliant.

The channel, on the other hand, is free. A written menu, a sign, a separate sheet, a QR code, or spoken word. Verbal information is allowed, but it has to be backed by a written register staff can produce on request. Anyone relying on what a waiter remembers on a Saturday night is running a five-figure risk.

The paper menu: a different law entirely

The second point is not governed by food law but by TULPS, the Italian public security consolidated act, which requires prices to be displayed somewhere visible to the public. A QR code is not visible: reading it takes a smartphone, a data connection and the confidence to use them, and not every customer has all three.

On that basis the lawyer Paolo Martinello, who teaches consumer protection at IULM, treats refusing a paper menu as an unfair commercial practice, which the Antitrust Authority can sanction. Worth stating precisely, because the difference matters: this is an authoritative reading of the rule, not a court ruling and not a figure written into a decree. The allergen case is the opposite, there the amount is in black and white.

In practice very little is needed. A copy readable without a phone: a few printed menus kept aside, or a chalkboard. It is for the person who has no phone, the one whose battery died, and the eighty-year-old who came to eat rather than to scan codes.

The 14 allergens to declare

1. Cereals containing gluten
2. Crustaceans
3. Eggs
4. Fish
5. Peanuts
6. Soy
7. Milk and dairy
8. Tree nuts
9. Celery
10. Mustard
11. Sesame seeds
12. Sulphur dioxide and sulphites above 10 mg/kg
13. Lupin
14. Molluscs

Frozen ingredients have to be declared too. That is the line people skip most often, because nobody thinks about the fish bought frozen back in November.

Who inspects, and when

Inspections come from the local health authority and the NAS carabinieri. They increased after Covid and concentrate where the trade is: tourist areas, summer season. For a place on the Calabrian coast that means the check, if it comes, lands in July or August, in the week nobody has time to tidy up a menu.

The moment to fix it is now, not when somebody walks in with a badge.

What a good QR menu looks like

• Allergens dish by dish, not one general list at the bottom of the page
• A web page, not a PDF. More on that in a moment
• Changeable without calling anyone: if swapping the fish of the day takes three days, the digital menu has gone back to being paper
• Readable on the slow connection of a beach club in mid August
• In several languages if you work with tourists, with the allergens genuinely translated rather than left in Italian
• One copy readable in the room without a phone

The most common mistake: the PDF

Nine times out of ten the "digital menu" we find is a PDF sitting behind a link. It is the worst available choice, and not for aesthetic reasons.

A PDF opens full page on a six-inch screen, so the customer pinches and drags to read the prices. It weighs a few megabytes, and on a weak line it never finishes downloading. The allergens, where they exist, live in a legend of small numbers nobody actually cross-references. And every change goes through whoever holds the original file: swap a dish, then wait.

A web page does the opposite. It opens in a second, it reads without zooming, the allergens sit under each dish, and the text changes in five minutes.

How we handle it

The QR menu is included in both our plans, together with the site: 99 euros every three months on the Start plan, 299 a year on Anno, which adds the seasonal menu swap. Changes are requested over WhatsApp, without opening a ticket and without waiting for a quote on one line of text. What drives the cost of a site is covered in detail in what a restaurant website costs; the full plans are on the pricing page.

What we always ask for before publishing is the allergen list, dish by dish. It is the boring part, we know. It is also the only part that is worth three thousand euros minimum in an inspection, and we print it anyway in a version to keep in the room. How we put the site and the menu together is described on the page about restaurant websites.

Frequently asked questions

Is a QR menu mandatory? No. No rule requires a digital menu. What is required is the content: allergens, frozen ingredients, displayed prices. The QR code is one accepted way of delivering it, not an obligation.

Can I drop the paper menu entirely? Better not to. Prices have to be displayed somewhere publicly visible, and a QR code needs a smartphone, a connection and the confidence to use both. A few printed copies or a chalkboard cost almost nothing and head off the complaint.

What do I risk if allergens are missing? Between 3,000 and 24,000 euros under Italian legislative decree 231/2017. If the missing information causes a serious allergic reaction, criminal liability is added on top.

Is writing "may contain allergens" on the menu enough? No. The information has to be tied to the individual dish and available before the order is placed. The blanket phrase covers nothing.

Can staff give the information verbally? Yes, that is allowed, but it has to be backed by a written register staff can show on request. A waiter's memory is not a document.