Allergens at hotel breakfast and buffets: what you must disclose in Spain, Portugal, Italy and Greece (2026)

Updated: 9 November 2026

A guest with coeliac disease or an egg allergy checks your website and asks an AI before booking. Then, at the buffet, they need to know what is in each dish. EU law requires allergen information for unpackaged food too, and each country decides how. This is what we checked in official gazettes and government websites (links at the end). This is not legal or medical advice: where we could not confirm something we say so.

What the EU requires in all four countries

Regulation (EU) 1169/2011 applies the same way across the EU:

Art. 9(1)(c): you must indicate every Annex II ingredient that causes allergies or intolerances and is still present in the dish.
Art. 44: for unpackaged food (including food served by a hotel or a canteen) allergen information is mandatory. Each Member State decides how it is presented.
The 14 in Annex II: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphur dioxide and sulphites, lupin and molluscs.
At breakfast it is easy to miss one: milk in sliced bread, sesame on rolls, sulphites in cured meats or dried fruit, nuts in granola.

Spain: in writing, or orally with a record and a notice

Royal Decree 126/2015 sets the details:

In writing: labels or signs on or next to the food, visible and legible (art. 6.2 and 7). At a buffet, a card next to each tray is the clearest option.
Orally: allowed if staff give it on request, before serving and free of charge, and the information is kept in writing or electronically at the hotel, available to staff, guests and inspectors (art. 6.5 a).
If you inform orally, a notice must say where the information is or that guests can ask staff (art. 6.5 b). Not needed if every food already has a label or sign next to it (art. 6.5 c).
Language: at least Spanish (art. 10).
The decree does not set fines; we do not quote any.

Portugal: on any easy-to-understand medium

Decree-Law 26/2016 (art. 4) requires collective catering to indicate Annex II allergens 'on any information medium that allows the consumer to understand it easily'.
The text does not mention oral information: the safe choice is to have it in writing, on display.
DGAV is the competent authority and ASAE inspects. Fines: EUR 100 to 3,740 (individuals) and EUR 250 to 44,890 (companies) (art. 11).
We have not checked later amendments; ask your adviser.

Italy: before serving, backed by written records

Legislative Decree 231/2017 (art. 19(8)) requires the information before serving, on a menu, register, sign or equivalent system, including digital.
Two options: allergens shown for each dish, or a notice referring guests to staff, who must have the information in writing.
In Italian, visible and legible (art. 19(10)).
Fine for omitting allergen information: EUR 3,000 to 24,000 (art. 23(2)). For giving it in a different form than required: EUR 1,000 to 8,000.
We could not open the Health Ministry's 2015 circular on an official site; we do not quote it.

Greece: on display; orally only under three conditions

The EFET circular (22-12-2014) requires the information to be available where food is offered, legible and given before sale, in Greek (other languages optional).
Orally only if all three are met: a notice saying where the information is or to ask staff; the information in writing or electronically on site; trained staff or an electronic means, free of charge.
We have not confirmed the fine amounts; we do not quote any.

'Gluten-free', 'safe for coeliacs' and 'vegan'

This is where hotels overpromise:

'Gluten-free' may only be used if the food, as served, contains no more than 20 mg/kg of gluten (Implementing Regulation (EU) 828/2014). 'Very low gluten': no more than 100 mg/kg.
The regulation does not distinguish between packaged and unpackaged food. At a shared buffet (tongs, crumbs, a shared toaster) this is hard to guarantee.
The honest approach: offer packaged products labelled gluten-free or separate preparation on request, and explain how you serve them. Avoid 'safe for coeliacs' if you cannot control cross-contamination.
'Vegan' or 'vegetarian': we have not checked an EU legal definition. Use it only if the dish has no animal ingredients, and still list allergens.
A promise you cannot keep can end in a complaint, a bad review or a sick guest. It is not worth the risk.

How to publish it for Google and AI without exaggerating

AI assistants repeat what they read on your website and listings. Keep it accurate:

On your website: a breakfast page with hours, type (buffet or à la carte), what options exist and how to request a special diet. Say 'allergen information available: please ask our staff' and link your list if you have one.
Google: the hotel profile has attributes for breakfast available, buffet and free breakfast. We saw no diet attributes: say it in the text.
Booking.com: breakfast types include Vegetarian, Vegan, Gluten free, Halal, Kosher, Buffet and others. Tick 'Gluten free' only if you really offer it every day.
schema.org: suitableForDiet (GlutenFreeDiet, VeganDiet, VegetarianDiet…) applies to MenuItem or Recipe, not to the hotel. Use it only on specific dishes that comply.
Write checkable sentences: 'Packaged gluten-free bread on request' beats 'coeliac-friendly breakfast'.

10-minute check

Make a table: each breakfast item and which of the 14 allergens it contains. Ask suppliers for their spec sheets.
Put a card next to each tray or a notice saying where the information is.
Show floor staff where the table is and what to say.
Check your website, Google and Booking.com: remove 'gluten-free' or 'safe for coeliacs' if you cannot guarantee it.
Update the table whenever you change a product or supplier.

How iQuota helps

iQuota does not give legal or medical advice. We publish your property in AI assistants with direct booking and payment at the property, using the details you confirm. If your breakfast is described accurately, AI will not promise what you do not offer.

Want an official booking page AI can read and a connector with your real prices, commission-free? The first 30 hotels join free until 30 June 2027.

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Frequently asked questions

Do I have to disclose allergens at the breakfast buffet?

Yes. Art. 44 of Regulation (EU) 1169/2011 requires it for unpackaged food too. Each country sets the form: in Spain, in writing next to the food, or orally with a written record and a notice (Royal Decree 126/2015).

Can I label a buffet item 'gluten-free'?

Only if, as served, it contains no more than 20 mg/kg of gluten (Regulation (EU) 828/2014). At a shared buffet this is hard to guarantee.

What are the 14 allergens?

Cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphites, lupin and molluscs (Annex II).

Sources

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