Accurate labelling is critical to food safety.

Up to 10% of children and adults experience allergies and food hypersensitivities. But while mandatory allergen labelling sets clear guidelines for packaged food products, precautionary allergen labelling (PAL) is less transparent.

If your brand is wondering whether to include PAL statements on your product packaging, it’s worth reading this introductory guide to precautionary allergen labelling. Keep reading to discover:

• The difference between mandatory and precautionary allergen labelling
• The issues with current precautionary allergen labelling ambiguity
• How precautionary allergen labelling laws could change

What’s the difference between mandatory and precautionary allergen labelling?

Food and beverage brands should consider two types of allergens when developing and selling products. The first type is mandatory allergens: ingredients that must be listed on packaging and labelling so that consumers with an allergy can avoid those items.

While mandatory allergens vary from country to country, some common ingredients include nuts, milk, wheat and shellfish. Our compulsory food allergen labelling guide contains a longer list, along with guidance on how to list them on your product packing.

Precautionary allergen labelling (PAL) is a different challenge. In the EU and UK, food and beverage brands have the option to include statements such as “may contain traces of” or “not suitable for those with [X] allergy” on product packaging. Voluntary notifications can warn consumers with allergies or hypersensitivities who wish to avoid these products.

Are current PAL labelling guidelines too ambiguous?

Currently, precautionary allergen labelling is not regulated in the same way as mandatory allergen labelling. As a result, most countries have no strict guidelines regarding which allergens should be included in advisory warnings, when these warnings apply, or how these warnings should be worded.

Precautionary allergen labelling is significant for consumers with severe allergies. Even brands that practice the highest food safety standards can experience cross-contamination incidents; common contamination points include within the supply chain due and during manufacturing.

Food and beverage brands have no legal obligation to report any contamination risks on their product packaging. However, even trace amounts can be devastating to someone with a severe allergy – as we’ve sadly discovered from recent high-profile legal cases.

In October 2021, the UK introduced Natasha’s Law following the death of teenager Natasha Ednan-Laperouse in 2016 after eating a baguette that contained sesame. In 2017, dental nurse Celia Marsh died after eating a ‘vegan’ wrap made in the same facility as milk products; cross-contamination triggered her severe milk allergy.

Read more on the challenges associated with vegan and vegetarian labelling.

Even in non-fatal cases, trace amounts of common allergens can cause a significant physical reaction. Without clear labelling, people who suffer from allergies can feel anxious about the foods they buy, avoiding particular products or complete categories to protect their health.

Plans to standardise precautionary allergen labelling

Some food regulatory bodies have recognised the issues with ambiguous voluntary allergen labelling and are developing plans to tighten industry legislation.

For example, the UK’s Food Standards Agency launched the Food Hypersensitivity (FHS) Programme in 2019, which wants to improve allergen information management across both the pre-packaged and non-prepacked food sectors.

Some food and beverage brands have complained that current PAL labelling is confusing, applied inconsistently, and limits consumers’ food choices. To combat this issue, the FHS plans to set allergen thresholds for the UK’s 14 regulated allergens.

The FHS also wants to standardise the wording of precautionary allergen labels. A research study revealed that most food companies and the general public prefer “not suitable for those with an allergy to X” as the PAL statement on product packaging.

How to approach precautionary allergen labelling

Some brands fear that additional warnings around potential allergens could lead to loss of sales, but in reality, the opposite is true. For example, if one family member is allergic to a specific ingredient, the whole family will ‘go without’ to protect their loved one.

If you can build trust and transparency among consumers with food allergies and hypersensitivities, there’s a huge opportunity to nurture brand loyalty. 66% of allergy sufferers say they are likely to buy the same brands repeatedly as they know their products are safe to eat.

Going the extra mile with your allergen labelling will also help to avoid incidents and near misses that could damage your brand’s reputation. And if UK and EU PAL labelling legislation does become tighter in the future, you already have best practices to minimise changes to your product packaging.

Selling in UK/EU markets and need help with your allergen labelling? Hooley Brown can develop compliant wording for your product packaging. Drop us a line to find out more.

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This blog post was written in September 2022. Facts were correct at the time of writing.