Foodlaw-Reading Dr David Jukes, The University of Reading, UK
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Food Law News - UK - 2021

FSA Consultation, 6 December 2021

LABELLING / ALLERGENS - Precautionary Allergen Labelling (PAL): The ‘may contain’ Consultation

Consultation Document: Precautionary Allergen Labelling (PAL): The ‘may contain’ Consultation A copy of the consultation document is available on this site (click on image) Provided under the Open Government Licence. The original document was accessed from:

The consultation runs until 14 March 2022. For more details, see the FSA page: Precautionary Allergen Labelling (PAL): The ‘may contain’ Consultation. Responses should be submitted to the dedicated website: https://eu.research.net/r/PAL-consultation.

Consultation on the provision of precautionary allergen labelling and precautionary allergen information, such as 'may contain' on many types of food sold in England, Northern Ireland, and Wales.

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 a 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 limited their food choice.