Food Additives on the Menu: How to Label Correctly

Additive Labeling Requirements — food additives E-numbers | ChinaYung solution
Additive Labeling Requirements — food additives E-numbers | ChinaYung solution
Correctly labeling food additives on the menu is mandatory for every restaurant operator. EU and national regulations require that certain additives must be identifiable for guests. In practice, the footnote system has proven most effective — with numbered references for each dish and a legend at the bottom of the menu. This guide walks you through the implementation step by step. For general additive information, see our food additives overview page.

The 14 Declarable Additive Classes

EU and national legislation specifies which additive classes must be disclosed on the menu. The declaration is made using the functional class name, not the E-number. The list below gives you the correct wording for each class along with a typical example from gastronomy practice.

  1. „with colouring“ — e.g. dessert sauces, soft drinks → Food Colourings Guide
  2. „with preservative“ — e.g. packaged cold cuts, fruit juices → Preservatives Guide
  3. „with antioxidant“ — e.g. frying oil, ready-made soups → Antioxidants Guide
  4. „with flavour enhancer“ — e.g. ready-made sauces, stock cubes → Flavour Enhancers Guide
  5. „sulphured“ — e.g. dried fruit mixes, certain wines
  6. „blackened“ — e.g. canned black olives
  7. „waxed“ — e.g. citrus fruits, apples with surface treatment
  8. „with phosphate“ — e.g. cooked ham, processed cheese, sausage products
  9. „with sweetener(s)“ — e.g. diet drinks, reduced-sugar desserts
  10. „contains a source of phenylalanine“ — relevant for aspartame in sweeteners
  11. „may have a laxative effect if consumed in excess“ — e.g. products containing sorbitol or mannitol
  12. „contains caffeine“ — energy drinks: mandatory with quantity (e.g. „contains caffeine, 32 mg/100 ml“)
  13. „contains quinine“ — e.g. tonic water, bitter lemon
  14. „contains taurine“ — e.g. energy drinks

Note: you may voluntarily add the E-number or specific name, but only the functional class designation is required.


The Footnote System — Step by Step

The footnote system is the most widely used and legally reliable method in gastronomy. Follow these five steps systematically.

Step 1: Check ingredient lists for all products

Request up-to-date ingredient lists from every supplier. Check each list against all 14 declarable additive classes. Record your findings in writing for every product.

Step 2: Assign additive classes to each dish

Determine which additive classes are present in the ingredients used for each dish on your menu. Pay particular attention to compound ingredients such as ready-made sauces or marinades.

Step 3: Define your numbering system

Establish a consistent number or symbol legend. Example: 1 = with colouring, 2 = with preservative, 3 = with antioxidant, 4 = with flavour enhancer, 5 = sulphured, and so on.

Step 4: Place numbers on the menu

Add the relevant numbers after each dish name. Example: „Wiener Schnitzel with Fries (2, 8)“ indicates that the dish contains a preservative and phosphate.

Step 5: Add a legend at the end of the menu

Place the complete legend clearly at the bottom of the menu or on a dedicated page. Example legend: „1 = with colouring | 2 = with preservative | 8 = with phosphate | 9 = with sweetener.“


Three Methods Compared

Method 1: Footnotes with numbers (recommended)

Additive Labeling Requirements: What Must Appear on Menus — practical example | ChinaYung
Additive Labeling Requirements: What Must Appear on Menus — practical example | ChinaYung

The most common approach in the restaurant industry. Numbers follow the dish name, legend appears at the bottom. Advantages: space-efficient, legally reliable, easy to update. Disadvantage: guests must actively refer to the legend.

Method 2: Symbols and icons

Visually appealing and potentially recognisable across languages. Each additive class receives its own symbol. Advantages: intuitive, attractive design. Disadvantages: higher design effort, a legend is still required, and confusion can arise when many symbols are used.

Method 3: Text note directly on the dish

Practical for menus with few dishes and few additives. Example: „House lemonade (with colouring, with sweetener).“ Advantage: maximum transparency. Disadvantage: quickly becomes cluttered on extensive menus.

Recommendation: combine the footnote system with allergen labeling in a single unified legend — this saves space and creates clarity for your guests. Further details: Allergen labeling on the menu.

Additives vs. Allergen Labeling

Both systems are mandatory but rest on different legal foundations. The 14 additive classes are declared under national rules derived from EU legislation (ZZulV in Germany). The 14 EU allergens — including gluten, milk, peanuts, and sesame — fall under Article 44 of the EU Food Information Regulation (LMIV) and must also be disclosed on the menu.

There is one area of overlap: sulphur dioxide and sulphites must be declared both as an additive („sulphured“) and as an allergen („contains sulphites“). This double declaration is required by law and is not an error.

The practical recommendation is to integrate both systems into a shared legend. Use footnote numbers for additives and bold text or letter codes for allergens. This reduces space on the menu and simplifies ongoing maintenance. Common mistakes when combining both systems: Common labeling mistakes.

Do Not Forget Beverages

The labeling requirement applies not only to the food menu but also to the drinks menu. Additives in beverages are frequently overlooked in practice. Check all beverages as systematically as your food items.

Typical additives in beverages: soft drinks and syrup-based drinks often contain colourings and sweeteners. Fruit juices from concentrate may contain preservatives. Energy drinks typically contain both caffeine and taurine — both are subject to mandatory disclosure. Tonic water and bitter lemon contain quinine.

Wine is a special case: the notice „contains sulphites“ is required as an allergen declaration and simultaneously satisfies the additive labeling requirement. Non-alcoholic wines and certain sparkling wines are subject to the same rules. Remember to also check the ingredient lists of bar mixes, ready-made cocktail mixers, and syrups.


Documentation and Updates

Menu labeling is not a one-time effort — it must be maintained continuously. Every time you change a supplier, modify a recipe, or introduce a new product, you must re-check the additive assignment and update the menu accordingly.

Maintain a central document listing all products and ingredients together with their relevant additive classes. This forms the basis for your menu labeling and makes updates significantly easier. Keep archived copies of your suppliers‘ ingredient lists as well — this ensures you can provide full documentation at any time during an inspection by food safety authorities.

For further guidance on recipe changes and supplier transitions: Ingredient changes. A complete checklist for regular review: Allergen labeling checklist.

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Frequently Asked Questions

Which additives must appear on the menu?

Fourteen classes of food additives must be declared on the menu. These include colourings, preservatives, antioxidants, flavour enhancers, sulphured and blackened products, waxed fruits, phosphates, sweeteners, phenylalanine sources, substances with laxative effects, caffeine, quinine, and taurine. The declaration is typically made as a footnote or note — not with E-numbers but with the functional class designation. The legal basis is the EU Food Information Regulation (LMIV) together with national implementing rules. Restaurant operators must systematically review their suppliers‘ ingredient lists.

Is „with colouring“ sufficient, or must the specific name appear?

For menu labeling in gastronomy, stating the functional class is sufficient — so „with colouring“ rather than „with Tartrazine (E102).“ You may voluntarily add the specific name or E-number, but it is not required. This differs from retail packaging labeling, where the specific additive must be listed by name or E-number. In practice, the simpler footnote system with functional classes is recommended, as it is clearer and meets the legal requirements fully.

Must additives also appear on the drinks menu?

Yes, the labeling requirement applies to the entire food and drinks menu. Additives in beverages are frequently overlooked. Typical examples: soft drinks often contain colourings and sweeteners, fruit juices may contain preservatives, energy drinks contain caffeine and taurine, tonic water contains quinine. Wine must carry the note „contains sulphites“ — this falls under allergen declaration. Check the ingredient lists of all beverages just as carefully as those of your food items.

What is the difference between additive and allergen labeling?

Additive and allergen labeling are based on different legal foundations and cover different substance lists. The 14 additive classes (e.g., colouring, preservative) are declared under national rules implementing EU legislation, while the 14 EU allergens (e.g., gluten, milk, peanuts) fall under Article 44 of the LMIV. There is one overlap: sulphur dioxide and sulphites must be declared both as an additive and as an allergen. In practice, integrating both systems on the menu is recommended — for example, footnote numbers for additives and bold text or symbols for allergens. Details on allergen labeling: Allergens on the menu.

Food Additives Overview Food Colourings Preservatives Flavour Enhancers Antioxidants Allergen Labeling Menu Ingredient Changes Allergen Labeling Checklist Common Labeling Mistakes ChinaYung Platform

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