The following article explores the future of Precautionary Allergen Labelling (PAL), offering a closer look at what this means for the Hospitality and Food Service Industry.

The food manufacturers supplying your Commercial Kitchen with products and ingredients use Precautionary Allergen Labelling (PAL) to protect consumers from unintended allergen exposure.

However, in recent years, industry bodies such as the Food Standards Agency and The Codex Committee on Food Labelling have started to examine the reliability of current PAL practices.

With research suggesting PAL information is frequently disregarded by consumers and is difficult to regulate, it is possible that the UK will follow in the footsteps of the Netherlands and will introduce official PAL guidelines – driving standards of transparency and consistency.

What are the implications for the food service industry? From updated allergen information to a rise in free-from products, we’ll outline the potential challenges and opportunities that lie ahead.

What is Precautionary Allergen Labelling?

Cross-contamination can cause allergens that aren’t listed as ingredients to end up in food products. Although manufacturers have a responsibility to defend against this, it may be that the measures they take do not remove or adequately reduce the potential risks. In this instance, they have the option to use Precautionary Allergen Labelling (PAL) to alert consumers to the potential presence of allergens (e.g. this product may contain traces of wheat, milk, egg). There are currently no thresholds or standards within UK law covering when PAL should be applied or the correct use of wording. It is also up to manufacturers to decide when it is necessary.

Are we heading towards a re-evaluation of Precautionary Allergen Labelling practices?

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 FSA has also expressed concerns that Local Authorities are finding it challenging to demonstrate non-compliance in relation to PAL, due to the level of inconsistency between manufacturers. What’s more, there is widespread concern that the unnecessary use of PAL is limiting the food options available to consumers with allergies.

So, what does this mean for the UK food industry?

In May 2019, the Codex Committee on Food Labelling started to develop guidance on “precautionary allergen or advisory labelling”. Although Codex standards are voluntary, they are recognised by the World Trade Organisation. As a result, countries will often align their own rules with the guidance provided by this international body.

With the purpose of providing scientific evidence to the Codex Committee, an Expert Consultation of the Food and Agriculture Organisation and the World Health Organisation has reviewed the potential allergen thresholds that relate to PAL (EH01 and EH05). These thresholds could be used by food businesses to determine whether or not PAL should be in place.

The Netherlands has already embraced this approach and has been using allergen threshold doses since January, 2024. It is possible that with time and research, more European countries will follow suit. This would primarily impact food manufacturers, but could also have a secondary impact on the food service and hospitality industry. 

How does Precautionary Allergen Labelling relate to Commercial Kitchens?

Working in a Commercial Kitchen, you will already be familiar with the process of documenting the allergens that are present in your food. This goes beyond the individual dishes, extending to the ingredients themselves. In collaboration with your supplier, you will need to keep an up-to-date record of any allergens. It is important that this record includes products with Precautionary Allergen Labelling. If your Commercial Kitchen doesn’t enforce the segregation of allergen-free ingredients and equipment, customers should also be aware of the high potential for cross-contamination.

What are the common mistakes to avoid?

  1. Failing to account for different types of packaging: When delivering to Commercial Kitchens, some manufacturers will include their ingredient list and allergen information on the main box that their products or ingredients arrive in. If your team immediately unpacks the items and disposes of the packaging, this essential information could be missed.
  2. Failing to update your allergen records: Say your kitchen switches from regular mayonnaise to low-fat mayonnaise, a new team member or a team member who hasn’t received the proper training, may not see the need to update your allergen record. However, the risks associated with each ingredient could be vastly different e.g. the regular mayonnaise might only contain egg, whereas the low-fat mayonnaise might also contain milk and mustard.
  3. Failing to maintain a clear line of communication with your supplier: The manufacturers that supply your products and ingredients need to inform you of any updates to their processes or the risks associated with their products. Even if an ingredient has always been free from a certain allergen, there is no guarantee that this won’t change. Supply chains can also be compromised, take the recent incident where mustard powder was contaminated with peanut.
  4. Failing to prevent customers from making assumptions: As mentioned above, research provided by the FSA points to consumers misunderstanding and even ignoring PAL. If your business relays any ‘may contain’ warnings, it’s important that consumers aren’t overlooking this too. For example, a consumer who follows a milk free diet could assume vegan products are suitable for people with dairy allergies, even though the food safety requirements are vastly different. Or, a consumer with a nut allergy could assume that ‘may contain nuts’ is just an establishment covering itself against legal action, rather than a genuine warning against cross-contamination.

And what if PAL practices change?

First, you may notice a difference in the product labelling and allergen information provided by your suppliers. It is possible that these details will become more specific, referencing allergen threshold doses. As PAL evolves into a more reliable system, you may also notice an increase in customer questions, with consumers moving away from assumptions and towards the expectation that ‘may contain’ is a valuable tool for making informed decisions. The good news is that changes to PAL could also help your business to appeal to customers living with allergies, as it will likely result in a rise in free-from products.

How should I prepare for potential changes?

The best way to prepare for potential changes to PAL practices is to strengthen your existing approach to allergen management. This starts with carrying out an internal inspection of your Commercial Kitchen, with a specific focus on allergen control. Important questions include:

  • Are your ingredient lists and allergen records comprehensive and up to date?
  • How close are your allergen-free utensils to utensils that handle allergens?
  • Do team members change gloves or wash their hands for allergen-free applications?
  • Are your ingredient dispensers clearly labelled or Indelimarked?

Validating your cleaning practices

Another important step is to make sure your cleaning processes are working effectively to reduce the risk of cross-contamination. This could be managed using a two-pronged approach:

First, you could use the A3 system to detect the presence of organic residue on surfaces before and after cleaning. Although this system can’t detect specific allergens, it does detect all forms of organic residue, so provides an indication of whether a surface is clean or requires further attention. It can also be used to check the cleanliness of hands before and after washing – helping you to establish best practice. You can then follow up your A3 checks with allergen specific swab tests and ELISA tests.

Training your team and reinforcing key messages

You need to ensure your kitchen team has been sufficiently trained to manage the increasing expectations surrounding allergen control. Here, Visual Management will play an important role, with signs and instruction boards ideal for reinforcing key messages, helping your workers to avoid some of the common mistakes mentioned earlier in this article.

Making the switch to a Digital Quality Management System could also help to drive standards of accountability, as allergen control measures will be automatically recorded and accessible to you at any time and from any location. This will allow you to act fast if any key checks or measures are missed. It will also allow you to prove compliance in the face of a food safety inspection or a customer complaint.

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 Commercial Kitchen to prepare is to reinforce your current approach to allergen management and documentation – ensuring customers have the information they need to make informed decisions.

If you would like to learn more about how Klipspringer can support you with the challenges and opportunities that lie ahead, contact us directly on 01473 461800 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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    Libby Loughnan, Content Manager at Klipspringer

    About the Author

    Libby Loughnan is Content Manager at Klipspringer, specialising in food safety and compliance. She writes extensively on helping commercial kitchens improve food safety, cut costs, and work more efficiently, covering everything from equipment storage to food oil management.