Food Law News - UK - 2022
FSA Consultation Response, 6 June 2022
LABELLING - Precautionary Allergen Labelling (PAL) & Precautionary Allergen Information: the ‘may contain’ consultation. Report on findings and summary of stakeholder responses
 | FSA Report: Precautionary Allergen Labelling (PAL) & Precautionary Allergen Information: the ‘may contain’ consultation. Report on findings and summary of stakeholder responses This report is available on the FSA website (click on image). |
The following is the Introduction from the report:
Introduction
Between 6th December 2021 and 14th March 2022, the Food Standards Agency (FSA) undertook a consultation with stakeholders across England, Wales, and Northern Ireland, to gather views on the use of precautionary allergen information and labels, often written as “may contain” on food packaging. In this report, the term PAL is used to describe both precautionary allergen labels and 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-contact (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 statement to be used to communicate this risk to both the consumer and other businesses in the supply chain.
This information can be communicated in several ways:
- Precautionary allergen labels are found on prepacked foods including chocolate bars, biscuits, and other products that are sold in supermarkets, as well as 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.
- Precautionary allergen information concerns 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. Such information can appear on menus and signs, and also includes verbal information.
Recent FSA studies have found that consumers with food hypersensitivities – people who live with food allergies, intolerances, or coeliac disease - appreciate precautionary allergen information or labelling when it clearly tells them about an unavoidable risk of allergen cross-contact.
But consumers can also be confused by the range of precautionary statements, given the wording can differ between products, and it may not be clear precisely what the risk is. The studies found that many food businesses are using these labels to try to protect consumers but are confused about when and how they need to do so. There is evidence that businesses need clarity on the measures they need to take to control the risk of allergen cross-contact, which then informs their labelling decision.
To help develop future guidance on the use of precautionary allergen information and labels, the consultation canvassed the views of food businesses, local authority food teams, healthcare professionals, allergy charities, consumers and other interested parties through an online survey and a series of online workshops.
For the news item related to the consultation, see:
- 6 December 2021 LABELLING / ALLERGENS - Precautionary Allergen Labelling (PAL): The ‘may contain’ Consultation