The Food Standards Agency has just launched new guidance on when to add precautionary allergen labels (PAL). PAL or “may contain” labels were confusing for consumers and caterers alike and so the FSA’s consultation in 2022 was a welcome move. Now the new guidance is in, and in summary, a precautionary allergen label (PAL) should only be applied to food where there is an unavoidable risk of cross-contamination. Read on to find out more.

FSA PAL Allergen Labelling Advice

The FSA’s best practice technical guidance aims to support food businesses when applying allergen labelling and also keep consumers safe.

Natasha Smith, Deputy Director of Policy at the FSA said:

“While the use of PAL is voluntary, it is important that it should be as accurate and helpful to consumers as possible when it is applied. The updates to this guidance will help businesses to effectively manage allergens, and ensure those living with food allergies and intolerances get the greatest possible benefit from PAL.”

The overuse of PAL can devalue it, forcing those with allergies to take risks or put up with limited consumer choice. At the same time, businesses reported finding the guidance confusing and added a PAL to be on the safe side.

One of the key recommendations is that a PAL should only be used if there is an unavoidable risk of allergen cross-contamination which cannot be sufficiently controlled by taking measures such as segregation and cleaning.

The precautionary allergen label should specify which of the 14 major allergens it refers to. Therefore the catering business should add “may contain peanuts” rather than a generic statement such as “may contain nuts”.

The overuse of PAL can devalue it, forcing those with allergies to take risks or put up with limited consumer choice. At the same time, businesses reported finding the guidance confusing and added a PAL to be on the safe side.

Vegan and Free-from labelling

There is also guidance on “vegan” and “free-from” claims on labelling making a distinction between both. It says a ‘free-from’ allergen claim should guarantee that the specified allergen is absent and to use it, a food business must have implemented strict controls to eliminate any risk of cross-contamination. 

Claims around an ofering being “vegan” are not about food safety. The FSA recommends that a PAL can be used in combination with a ‘vegan’ label where a risk of cross-contamination with an allergen has been identified.

Natasha Smith, Deputy Director of Policy at the FSA continues:

“A vegan claim is not about food safety, and our new guidance highlights that a PAL statement for any or all of molluscs, eggs, fish, milk and crustacea (foods that are both regulated allergens and animal products) can be used to communicate a risk of their unintended presence, where this has been identified by a food business’ risk assessment.”

Calls for legislation and mandatory guidelines

This month marks the two-year anniversary of Natasha’s Law, named after Natasha Ednan-Laperouse, who died after an allergic reaction. Her mother, Tanya Ednan-Laperouse is calling for further changes to allergen labelling laws including the usage of PAL:

“We are asking for legislation and mandatory guidelines so that PAL is only applied where a risk of cross-contamination with an allergen has been identified.” (Guardian, October 2023)

This is in line with the FSA’s new guidance but strengthened by making it law. We’ll keep you updated on the latest legislation and developments.

How can we help?

Our software, LabelLogic Live takes the stress out of adding labelling information to ensure that your business and your customers are safe. From Natasha’s Law to PAL, our software ensures that you are always legally compliant no matter the changes to the labelling laws. For any food labelling questions or requirements, get in touch.