Precautionary Allergen Labelling (PAL): The ‘may contain’ Consultation

Related research:

Risk analysis and Precautionary Allergen Labelling research report | Food Standards Agency

Precautionary Allergen Labelling Report and Non-Gluten Containing Ingredients Labelling Report | Food Standards Agency

This consultation will be of most interest to: 

• food businesses
• institutions, e.g., hospitals, schools
• primary producers
• transport companies
• trade bodies
• local authority food safety teams
• healthcare professionals
• scientists and academics
• organisations that support people with a food hypersensitivity
• consumers with a food hypersensitivity and those that care for someone with a food hypersensitivity
• consumers without a food hypersensitivity 
• wider stakeholders

Consultation subject

This consultation is to obtain information and views relating to the provision of precautionary allergen labelling and precautionary allergen information. 

Current labelling legislation requires that food products should indicate the presence of any of the 14 main allergens used as an ingredient or processing aid. However, in cases where there is a risk of unintentional allergen cross-contamination (for example where multiple foods are prepared in the same kitchen), and the food business has established the risk cannot be sufficiently controlled, it is best practice for a precautionary allergen label statement to be used to communicate this risk.

This information can be communicated in a number of different ways:

• on prepacked foods including chocolate bars, biscuits and other products that are sold in supermarkets
• on non-prepacked foods, which include loose foods such as meals made to order in a restaurant, or vegetables and fruit sold individually on a market stall
• and those provided prepacked for direct sale (PPDS) which is food that is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected

Although there are a number of labelling terms used, the most common phrase to denote the possibility of unintentional allergen cross-contamination is ‘may contain’, and the information can also be provided verbally, on signs, and on menus.

Purpose of the consultation

We are seeking feedback and comment on the issues faced by interested parties, which will assist us in considering potential approaches for precautionary allergen labelling for prepacked foods and precautionary allergen information for non-prepacked foods, so that the information is:

• communicated more clearly and consistently, in an understandable and meaningful way to consumers, in terms of the form and content of the information
• based on a proportionate and standardised processes for assessing, managing, and communicating the risk of allergen cross-contamination by food businesses 

Any solution has to be workable for food businesses and keep consumers safe without unnecessarily limiting their food choice. 

Consultation pack

This consultation pack provides the background information and details you will need to know in order to respond to the questions in this consultation.

How to respond

The consultation is now closed and a summary of responses can be found at the top of this page.

We would strongly advise that you respond to the consultation via the online survey. However, if this is not possible, you can email a response. Further details are provided within the consultation pack.

Related Precautionary Allergen Labelling (PAL) content

• Safer food better business
• Precautionary allergen labelling
• Precautionary allergen labelling checklist