Understanding Precautionary Allergen Labelling (PAL)
Precautionary Allergen Labelling (PAL), often seen as “may contain” or “not suitable for [allergen] allergy sufferers,” is a voluntary statement used to inform consumers of the unavoidable risk of allergen cross-contamination despite reasonable precautions. This differs from the mandatory declaration of allergens used as deliberate ingredients. A product with a PAL statement has a risk of cross-contact determined by a risk assessment because an allergen is handled in the facility.
The 14 Mandatory Allergens in the EU and UK
EU and UK food law requires declaring 14 specific allergens used as ingredients, additives, or processing aids. This list forms the basis for PAL statements. For the list of the 14 mandatory allergens {Link: Food Standards Agency https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses}.
Comparing Mandatory Allergen Lists: EU vs. US Regulations
The EU and UK regulate 14 allergens, while the US FDA, under FALCPA, regulates a slightly different list of major food allergens, now including sesame. Differences are important for consumers, especially with imported goods. The table below highlights key comparisons.
| Allergen Category | EU/UK Mandatory Allergens | US Mandatory Allergens | Key Differences |
|---|---|---|---|
| Cereals with Gluten | Declares wheat, rye, barley, and oats individually and as a group. | Wheat is the only cereal listed. | US law requires wheat declaration but not other gluten-containing cereals like barley or rye. |
| Celery | Included as a mandatory allergen. | Not considered a major allergen and not required. | Celery ingredients must be stated, but without a specific allergen warning. |
| Mustard | Included as a mandatory allergen. | Not considered a major allergen and not required. | Similar to celery, mustard may be hidden in terms like “spices” on US labels. |
| Lupin | Included as a mandatory allergen. | Not included on the US list. | Lupin flour could be present in US products without a specific warning. |
| Molluscs | Included as a mandatory allergen. | Not included on the US list. | Molluscs are treated as an ingredient, not a major allergen, in the US. |
| Tree Nuts | Specifies a list of eight nuts, which must be individually named. | Includes a broader range of nuts and seeds, including coconut and pine nuts. | EU labels must name the specific nut (e.g., “almond”), whereas US labels can use the broader term “tree nuts”. |
| Sesame | Included as a mandatory allergen. | Now included as a major allergen, but newer requirement. | Recent change in US law harmonizes with EU/UK on sesame declaration. |
| Sulphites | Included if concentration is over 10 ppm. | Also requires declaration above 10 ppm. | Generally consistent, but implementation details vary. |
The Importance of Interpreting PAL Correctly
Interpreting PAL is crucial for safety, especially for those with severe allergies. PAL indicates an unavoidable risk despite best efforts to prevent cross-contact. However, excessive PAL use can restrict choice and potentially lead to risk-taking. PAL decisions should be based on thorough risk assessment, using specific wording like “may contain peanuts” rather than generic statements. A product should not have both a “free-from” claim and PAL for the same allergen.
Conclusion
Precautionary Allergen Labelling (PAL) is a voluntary communication tool for the risk of cross-contamination, distinct from mandatory ingredient labelling. It is based on the 14 mandatory allergens in the EU and UK. Consumers must be aware of regional differences in mandatory lists and interpret PAL correctly for safety. Specific warnings based on risk assessment are vital. The UK Food Standards Agency offers resources for businesses on allergen controls.
Additional Considerations for Allergen Management
- Risk Assessment: Manufacturers must perform risk assessments to identify cross-contact points and assess control measure effectiveness.
- No Substitute for Good Practice: PAL does not replace good manufacturing practice (GMP), which requires minimizing cross-contamination through hygiene, segregation, and scheduling.
- Communicating Changes: Businesses need a process to inform consumers of changes in allergen status or PAL statements.
Consumer Best Practices
- Read Carefully: Always read the full ingredients list and advisory statements, as recipes and processes can change.
- Don't Assume: Never assume a product is safe based on brand history; check the label every time.
- Verify for Imports: Be cautious with imported foods, as mandatory allergen lists differ regionally. The US does not mandate labelling for celery or mustard, for example.
