Allergens in food you serve guests in BiH: the 14 allergens and how to inform guests

This article concerns restaurants, rural guesthouses, taverns and other places that serve prepared food to guests. The main rule is the Rulebook on providing food information to consumers (Pravilnik o pružanju informacija potrošačima o hrani), which applies across Bosnia and Herzegovina.

In short

• The rulebook applies to all food intended for the final consumer, including food supplied by catering establishments (Art. 1(3)). A catering establishment includes a restaurant or hospitality venue where food is prepared for the consumer (Art. 2).
• You must declare every ingredient or processing aid listed in Annex II that is present in the finished product, even in altered form (Art. 9(1)(c)).
• Annex II lists 14 allergen groups.
• Mandatory food information must be available and easily accessible for all types of food, including non-packaged food (Art. 12(1)), and visible, clear and legible (Art. 13(1)).
• Art. 8(6) speaks of mandatory information on non-packaged food being given to the consumer on request, and the brochure of the Food Safety Agency recommends that allergens be clearly highlighted in a visible place. The rulebook does not say outright whether oral information is enough, so a written list is safer.

Who it applies to

All food businesses that serve or sell food to final consumers: restaurants, taverns, rural tourism households, canteens and similar venues.

For products you sell packaged (honey, cheese, jam, spirits in bottles), the mandatory particulars, including allergens, go on the label (Arts. 9 and 12). An allergen need not be singled out if the name of the food clearly names it, for example "cheese" (Art. 21(4)). Drinks above 1.2% alcohol by volume need no ingredient list (Art. 16(4)), so for a spirit containing an allergen the word "contains" plus the allergen name is used (Art. 21(2)).

The 14 allergens

According to Annex II of the rulebook:

1. cereals containing gluten (wheat, rye, barley, oats, spelt, kamut or their hybrids) and products
2. crustaceans and products
3. eggs and products
4. fish and fish products
5. peanuts and products
6. soybeans and products
7. milk and milk products (including lactose)
8. tree nuts (almond, hazelnut, walnut, cashew, pecan, Brazil nut, pistachio, macadamia) and products
9. celery and products
10. mustard and products
11. sesame seeds and products
12. sulphur dioxide and sulphites above 10 mg/kg or 10 mg/l (as total SO2), counted for the product as ready for consumption, common in wine and dried fruit
13. lupin and products
14. molluscs and products

Annex II gives exceptions for some products (for example fully refined soybean oil), so check the full text if unsure.

What to do

1. Write down the ingredients of every dish and drink and check each one, including ready-made additions: spice mixes, stock cubes, sauces, flour, vinegar, wine. Ask suppliers for their labels.
2. Mark which of the 14 allergens each dish contains. Include ingredients used as a processing aid (for example egg or milk in a coating, wine in a sauce).
3. Make the information available and easy to access, for example on the menu or on a separate sheet with it, and keep it legible (Arts. 12 and 13). On packaged products, allergens appear in the ingredient list and are emphasised (bold, different typeface or background colour). With no ingredient list, use the word "contains" followed by the allergen name (Art. 21).
4. Write in a language guests understand. The rulebook requires one of the languages in official use in BiH, in Latin or Cyrillic script, and allows several languages (Art. 15). Add English for foreign guests.
5. Train staff so they can answer a guest's question accurately, and update your list whenever you change a recipe or supplier.
6. If you supply non-packaged food to another business (for example a restaurant), pass on the allergen information (Art. 8(6)).

Where to go

• The food inspection within the Inspektorat Republike Srpske (Inspectorate of Republika Srpska) supervises compliance. Ask it whether oral information or a written list is sufficient in your venue.
• The Agencija za sigurnost hrane Bosne i Hercegovine (Food Safety Agency of BiH) publishes rules and guides, including a brochure on applying the rulebook. The brochure is not legally binding.

Laws and sources

• Pravilnik o pružanju informacija potrošačima o hrani (Službeni glasnik BiH, broj 68/13), Arts. 1, 2, 8, 9, 12, 13, 15, 16, 21 and Annex II. Applies from 13 December 2014.
• Brochure on implementing the Rulebook, Food Safety Agency of BiH