But will the UK follow suit? Whatever the Food Standards Agency (FSA) decides, the core challenge for every food business remains to ensure food labelling and allergen labels are accurate, compliant, and safe - while avoiding the reputational and legal risks that come with getting it wrong.

What is the “May Contain” UK legislation?

Currently, the decision to use a "May Contain" warning is voluntary and based on your business risk assessment. Before updating their guidance, the FSA recognised there were issues with this system:

• Often, consumers with allergies don't understand what PAL truly means, forcing them to either severely restrict their diet or take a risk with their health.
• Without clear thresholds, businesses face ongoing uncertainty regarding what constitutes "adequate" allergen management, even when using a PAL statement.
• Using a PAL statement doesn't absolve you of responsibility for proper allergen management. If cross-contamination occurs and you haven't followed robust procedures, you could still face enforcement action.

The FSA updated their guidance in 2023 to support food businesses when applying allergen labelling and also keep consumers safe. Allergen label (PAL) should only be applied to food where there is an unavoidable risk of cross-contamination. PAL must be based on a risk assessment, be specific (e.g., "may contain peanuts"), and never be used alongside a "free-from" claim. 

What could be the solution to Precautionary Allergen Labelling (PAL)?

The most significant movement toward true standardisation comes from Codex (the Codex Alimentarius Commission), an international body that sets global food standards. They propose basing PAL on scientific thresholds, specifically, the Eliciting Dose (ED) of 5% (ED05).

This threshold represents the dose of an allergen protein at which 5% of the allergic population is predicted to have an objective reaction.

If an unintentional allergen is below ED05, no PAL is needed. This move would fundamentally restore trust by ensuring that "May Contain" truly signals a calculable risk, not just a manufacturer's uncertainty. 

The Netherlands has already incorporated ED05 into national policy, with Belgium and Germany expected to follow. However, the FSA is pulling on the brakes, but with good reasoning.

What about PAL legislation in the UK? 

When the FSA asked its Committee on Toxicity to review the Codex proposals, the experts raised two significant red flags. 

1. If the UK adopts thresholds it is more likely to be ED01 (where only 1% of allergic consumers might react). This would be safer than ED05, but also more difficult for businesses to achieve.

2. On the practical side of things, do we have the testing capability to make any threshold work? As Foodservice Footprint reports, a 2022 FSA review found that reliable testing methods don't even exist for all 14 priority allergens yet. If labs can't consistently and accurately measure trace allergen levels, setting legal thresholds becomes meaningless. This could also create a false sense of security, therefore not improving the PAL situation. 

So where does this leave UK food businesses? The FSA won't move without better testing standardisation, which won’t happen without investment and harmonisation. 

While regulators debate the perfect threshold, you're still responsible for getting allergen management right - PAL or no PAL.

How Planglow’s allergen labelling software can help

You can't wait for regulatory standardisation to get your allergen management right. Whether the future brings ED05, ED01, or a hybrid model, your business needs to be ready. 

The burden of accurate risk assessment falls on your business and with Natasha’s Law, clear, compliant labelling is essential. Given this complexity, manual processes are no longer viable. Businesses of all sizes need labelling software designed for compliance.

We’ll keep our ears to the ground to share the latest updates on PAL and allergen labelling, but with LabelLogic Live, our label software, you can have reassurance that you’re meeting labelling standards today and in the future. 

Why choose our label software, LabelLogic Live:

• Map ingredients and cross-contamination risks across your entire offering.
• Stay compliant no matter what legislative changes are introduced.
• Eliminate human error by translating complex data into clear, legally compliant labels.

Ready to future-proof your allergen management?

Get a free trial of LabelLogic Live, our labelling software today.