In what order do you build allergen management?

From scope to contamination, not backwards from the menu. First the question of whether and how the rules apply to you. Then which ingredients the fourteen categories actually cover. Then the internal document that records what is in which dish. Then the information given to guests. And last, contamination, because it sits on top of a declaration that is already clean.

Allergens in food service: the complete guide for Switzerland

Q: What does Swiss law require on allergens?

Anyone who supplies food must be able to give information about fourteen categories of ingredients that can trigger allergies or other undesirable reactions, and must be able to do so before the guest orders. That applies to loose goods too. Behind it sit five different questions: whether the rules apply to you, which ingredients are meant, where you record it, how the guest finds out, and what happens to whatever gets in by accident.

Q: Which "exemption" is actually meant?

There are five, and they act on five different levels: one takes individual products off the list, one releases you from the notice of unintentional mixing in loose sale, one releases you from notifying the canton, one applies to non-profit tax-exempt organisations, and one concerns the nutrition declaration and so an entirely different duty. They get mixed up constantly, and the mix-up always runs in the same direction: towards believing you are exempt.

Q: Where do you start if you have nothing today?

With one dish, not with the menu. Take your best seller, check its ingredients, including sub-recipes and bought-in convenience products, against the labels, and write the result on one sheet. Once you know, for a single dish, which categories are in it and how you know, you have understood the method. The rest is repetition.

Q: What can you safely leave out when it comes to allergens?

The idea that small businesses are exempt from the declaration; no such threshold exists. The worry of having to indicate every possible trace in loose sale. The hope that a blanket "may contain traces" settles the matter; it makes the information worthless. And confusing the exemption from the nutrition declaration with an exemption from the allergen information.

Anyone who supplies food in Switzerland must be able to give information about fourteen categories of ingredients before the guest orders. That is the whole principle, and it fits in one sentence.

It gets complicated after that. Behind this one duty sit five different questions, they depend on each other, and the answers are spread across three instruments. This guide puts them in order: which question comes first, which builds on which, and which of the exemptions that all sound alike is actually meant.

It quotes as little as it can. The details are in the five articles it points to.

On the legal texts referred to in this article. Swiss food law is published in German, French and Italian. There is no official English version of the ordinances referred to here, and the instrument names are kept in their German abbreviations. The binding wording is the German text linked in the sources at the end.

What does Swiss law require on allergens?

Information about fourteen categories of ingredients, available before the guest orders, and that includes loose goods.

Behind it sit five different questions:

The question	The topic	Covered in
Do the rules apply to me?	Scope	Selling homemade food
Which ingredients are actually meant?	The fourteen categories	List of the 14 allergens
Where do I record what is in which dish?	The internal document	Allergen matrix
How does the guest find out?	The information given to guests	Allergen declaration in restaurants
And what about whatever gets in by accident?	Contamination	Cross-contamination

Five questions, five answers, and none of them is difficult on its own. What is difficult is that they get muddled, and most often where exemptions are concerned.

Does this even apply to my business?

Almost always yes, and earlier than most people think.

The Foodstuffs Act does not apply to domestic manufacture of food for private domestic use. The condition is the purpose: the moment you supply, sell or give food to outsiders, you are in. The law sets no minimum quantity, turnover limit or business size at which the allergen duty starts.

Keep that apart from an entirely different question: whether you have to notify the cantonal enforcement authority of your activity. It has its own legal basis and its own exception, and the answer to it is yes for a business and no for occasional supply on a small scale, while the answer to the allergen question stays yes in both cases. Anyone unsure how these two questions play out for them will find the reasoning in the article on selling homemade food.

For everyone else the question is answered, and the next one is: which of the exemptions do you actually mean?

Which “exemption” is actually meant?

There are five, they act on five completely different levels, and they are constantly confused with one another.

The “exemption”	Acts on the level of	Does not release you from
Annex 6 LIV takes individual products off the list	the substance: it is no longer subject to mandatory declaration	everything that stays on the list
No notice of unintentional mixing in loose sale (art. 5 para. 1 let. f LIV)	the communication	the duty to be able to prove the measures taken
Occasional supply on a small scale (art. 20 para. 2 LGV)	notifying the canton	any allergen duty whatsoever
Non-profit tax-exempt organisations, baked goods (art. 39 para. 1bis LGV)	the person supplying	the allergen information, as soon as one of the conditions is missing
Artisanal direct supply, nutrition declaration (Annex 9 no. 19 LIV)	a different duty	the list of ingredients and the allergen information

Read the middle column straight down: five levels, and no two of them are the same. The first acts on the substance, the second on the communication, the third on the notification, the fourth on the person, and the fifth concerns a duty that has nothing to do with allergens.

That is exactly why lumping these five together leads to conclusions that every single one of the five linked articles refutes. And the confusion always runs in the same direction: towards believing you are exempt. None of these five releases you from the allergen information owed to the guest, except the fourth. That one attaches to the person supplying, not to the baking, and it applies only when all of its conditions are met at once.

Where the reasoning for each of the five is set out: the first in the list of the 14 allergens, the second in the article on cross-contamination, the third, fourth and fifth in the article on homemade food.

In what order do you build this?

From scope to contamination. Not backwards from the menu.

First the question of whether and how it applies to you. It comes first because it decides which of the other four concern you at all, and because it is the only one some readers can answer with a clear no.

Then which ingredients the fourteen categories cover. That sounds like the easiest step and is the one where the most goes wrong, because every category also covers the products derived from it. Skip this step and you fill the next document with gaps.

Then the internal document. It records which dish contains which category, across all ingredients and sub-recipes. It comes before the information given to guests because any information, on the menu or at the table, is only as correct as what is recorded internally.

Then the information given to the guest. Menu, notice or oral information subject to conditions: that is a question of format, and questions of format can only be answered once the content is in place.

And last, contamination. It comes at the end because it sits on top of a declaration that is already clean. Anyone who does not know what is in the dish by recipe cannot sensibly judge what gets in by accident either.

The reason almost nobody works in this order: the urgent question is always the menu. It is going to print, the guest is asking today. So you start at the end and work backwards, and then the foundation is missing underneath.

Where do you start if you have nothing today?

With one dish. Not with the menu.

Take your best-selling dish. Not the most complicated one and not the first on the menu.
Check its ingredients against the labels, including sub-recipes such as stocks, sauces and marinades, and including every bought-in convenience product. Not from memory: what counts is what the package says.
Write the result on one sheet, with the date and your name underneath.

Nothing more. Once you know, for a single dish, which of the fourteen categories are in it and how you know, you have understood the method. Everything else is repetition, and repetition can be planned.

The categories themselves are in the list of the 14 allergens; the document that ends up holding every dish is available as a free template in the article on the allergen matrix. The next stage is the same exercise for the rest of the menu, and after that a fixed rule for when the document gets updated.

What can you safely leave out?

Four common assumptions that fall apart once you read up on them.

The idea that small businesses are exempt. Allergen declaration has no threshold based on business size, and the claim to that effect circulating online is false. Refuted in the article Allergen declaration in restaurants and in the article on cross-contamination.

The worry of having to indicate every possible trace in loose sale. Unintentional mixing does not have to be indicated there; what remains is the duty to be able to prove the measures taken (cross-contamination).

The hope that a blanket “may contain traces” settles the matter. It settles nothing; why it devalues the information is set out in the article on the allergen matrix and in the article on cross-contamination.

Confusing the nutrition exemption with an allergen exemption. Artisanally produced food supplied directly is exempt from the nutrition declaration. From nothing else. This one confusion is probably the source of the story that small producers have to declare “nothing at all” (reasoning).

The allergen information itself is not up for negotiation in any of these four cases.

How do you keep this under control when recipes and suppliers change?

This is the point where allergen management fails in everyday practice. A document is correct on the day it is created. Then the supplier changes, the new bouillon contains celery, and the bouillon is in three sauces and twelve dishes.

That is exactly what we are building Trolevo for: recipes with nested sub-recipes whose allergens roll up automatically from all ingredients, including those in sub-recipes, into one allergen label per dish. Change the allergen data of an ingredient and every dish it is in changes with it, everywhere at once.

What it does not do, plainly: it does not decide whether you fall within the scope, it prints neither a menu nor a label for prepacked food, it does not record contamination risks, and it does not check the legal position. This helps you meet the labelling duty; responsibility for correct information stays with the business.

Trolevo is in development – get early access.

Sources

The instruments below are binding in German, French and Italian only; the German text is linked.

LMG – Foodstuffs Act, SR 817.0 (German, as of 1 October 2024)
LGV – Foodstuffs and Utility Articles Ordinance, SR 817.02 (German, as of 1 July 2025)
LIV – FDHA Ordinance on Food Information, SR 817.022.16 (German, as of 1 July 2025)

This article is general information, not legal advice. The binding texts are the statutes (LMG, LGV, LIV) and the information provided by the cantonal enforcement authorities.