The following article explores what the future could look like for Precautionary Allergen Labelling (PAL) in food production. Plus, why might there be change ahead?

Whether you’re refining your current approach or preparing for future changes, understanding Precautionary Allergen Labelling (PAL) is an essential part of maintaining both consumer safety and operational credibility.

With this in mind, we have put together a guide that addresses the most important areas of PAL, with a particular focus on the recent efforts of the Food Standards Agency and The Codex Committee on Food Labelling to examine the reliability of current practices.

If you are already well-versed in the principles of Precautionary Allergen Labelling, click here to jump ahead to our rundown of the potential changes.

What is Precautionary Allergen Labelling? 

If it is possible that a food product contains an allergen that has not been listed as an ingredient, sites will try to remove or adequately reduce this risk to an acceptable level.  

However, if an internal risk assessment suggests the dangers of cross-contamination are still too great, Precautionary Allergen Labelling can be used to alert consumers to the potential presence of an allergen.  

This helps to keep consumers safe, especially individuals who have severe allergies and would be negatively impacted by even trace amounts of certain allergens. Precautionary Allergen Labelling can also help to protect food production businesses from customer complaints, extensive product recalls, bad publicity, and legal action. 

Is PAL voluntary?  

Precautionary Allergen Labelling is currently voluntary. There are no thresholds within UK law covering when PAL should be applied or the correct use of wording. 

However, it is a requirement that Precautionary Allergen Labelling does not mislead or confuse consumers. It should be accurate and easy to understand. Otherwise, local authorities have the power to instruct businesses to remove misapplied PAL. The problem is, demonstrating non-compliance in this area often proves challenging, as processes vary from site to site and there are no legal thresholds. 

What are the concerns surrounding Precautionary Allergen Labelling? 

Consumer awareness and assumptions  

Consumer research carried out by the Food Standards Agency found that “whilst most consumers were aware of PAL, understanding of what it is meant to communicate is low” to the extent that “some consumers disregard PAL information when deciding whether to consume a product.”   

The report suggests that this is the result of consumers viewing PAL as a way for food production businesses to provide “legal cover”. They believe it is used even when there is almost no risk of the allergen being present because it is easier than applying for Free-From status and safer than being vulnerable to questions and complaints.  

The FSA reasons that it is because of this mindset that a concerning number of people are ignoring Precautionary Allergen Labelling and risking their health. 

The role of local authorities  

Every site will have its own approach to carrying out the risk assessments that determine whether or not PAL is required.  

Further variations stem from the fact that there isn’t a standard phrasing for Precautionary Allergen Labelling. Examples include: 

  • May contain egg 
  • May contain traces of egg 
  • This product has been manufactured in a facility that also processes egg 
  • Not suitable for those with an egg allergy  

As a result of this subjective approach, demonstrating non-compliance around PAL can pose a challenge for local authorities. 

The future of Free From food 

There is also a concern that the over-use of Precautionary Allergen Labelling could be making it harder for consumers with food allergies to enjoy a wide range of products.  

Whilst some consumers may ignore PAL and assume it is just a “legal cover”, others will be following it diligently and ruling out all food products with this warning.  

However, if thresholds for Precautionary Allergen Labelling were introduced, it is likely that a significant number of products would sit below the recommended limits and wouldn’t require the PAL warning. This would mean more product options for people with allergens. 

What is next for Precautionary Allergen Labelling in Food Production? 

The Codex Alimentarius, often referred to as the Food Code, is a compilation of international standards, guidelines, and codes of practice that address food safety, quality, and trade.  

Developed by the Food and Agriculture Organisation (FAO) of the United Nations, its primary goal is to safeguard consumer health and ensure fair practice within the global food industry. 

Although Codex standards are voluntary, they are recognised by the World Trade Organisation. That is why countries will often align their own rules with the Codex. 

Since May 2019, the Codex Committee on Food Labelling has been working on guidance for “precautionary allergen or advisory labelling” (PAL).

In the interest of providing the committee with scientific evidence, an Expert Consultation of the Food and Agriculture Organisation (FAO) and the World Health Organisation (WHO) reviewed potential allergen threshold levels related to PAL (EH01 and EH05). These thresholds could help food businesses decide when precautionary allergen labelling is necessary.

In January 2024, the Netherlands adopted a threshold-based approach. Over time, it is possible that more European countries will follow, including the UK.

Allergen Thresholds and PAL

Although it is uncertain whether thresholds will eventually become a requirement for the use of PAL in the UK, many food production sites are already using them.

Thresholds indicate acceptable levels of unintentional allergen presence. To establish if a product falls above or below a threshold, you need to compare the estimated contamination levels of your product to a reference dose. According to the FSA, reference doses are based on the likelihood of “objective allergic reactions”:

  • EDO5: 5% of the population are predicted to have an allergic reaction when the dose of an allergenic protein reaches this level.
  • EDO1: 1% of the population are predicted to have an allergic reaction when the dose of an allergenic protein reaches this level.

How can I prepare my site for potential changes to PAL?

One of the most straightforward ways to prepare for potential changes to the guidelines or legislation surrounding PAL is to introduce thresholds to your risk assessment process. Not only will this ensure standardisation – reassuring auditors and customers alike – it will also give your team the opportunity to get used to this approach to PAL while it is still voluntary. You may even find that working with thresholds gives your site the confidence it needs to open up more products to people with allergies and even apply for Free-From status, driving sales and commercial success. Other ideas include:

  • Look for opportunities to enhance your site’s approach to cleaning validation, as this will help to reduce the risk of cross-contamination. A practical approach starts with tools like the A3 system. Although it doesn’t test for allergens and shouldn’t be used for this purpose, the A3 system does detect all forms of organic residue in a matter of seconds – providing a quick indication of overall cleanliness. You can then follow up with allergen-specific swab tests.
  • Ensure your team is well-trained and aware of the ‘Why?’ behind the actions you are taking. You need to emphasise the fact that the work you are doing around allergen management is truly life-saving. You can then follow up this training with the introduction of visual management solutions – signage and boards placed at key points can help to reinforce correct procedures and prevent common mistakes.
Access our guide to Allergen Cleaning Validation

We hope this article has provided a helpful overview of Precautionary Allergen Labelling, along with the potential for upcoming changes to PAL practices.

Whatever those changes may be, the best way for your food production site to prepare is to reinforce your current approach to allergen management and documentation – embracing every opportunity for continuous improvement.

If you would like to learn more about how Klipspringer can provide support in this area, contact us directly on 01473461800 or sales@klipspringer.com. Alternatively, you can complete the form below and a member of our team will be in touch.

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