Which of the following are examples of precautionary allergen labelling?

December 10, 2025 •

2 min read

According to the Food Standards Agency, excessive or unjustified use of precautionary allergen labelling (PAL) can unnecessarily limit consumer choice and devalue the warning for those with serious allergies. Examples of precautionary allergen labelling are voluntary statements used to communicate the risk of unintentional allergen presence due to cross-contact.

Quick Summary

Precautionary allergen labelling includes voluntary statements, such as 'may contain [allergen]' or 'manufactured on shared equipment', to warn consumers about potential allergen cross-contact risks. It is not a substitute for strict hygiene but rather a final step after all risk management actions are taken.

Key Points

Common Examples: Phrases like “May contain [allergen],” “Not suitable for those with [allergen] allergy,” and “Made on shared equipment” are key examples of precautionary allergen labelling.
Voluntary, Not Mandatory: Precautionary allergen labels are voluntary warnings used by manufacturers, not a legal requirement like ingredient-based allergen declarations.
Used After Risk Assessment: These warnings are only applied after a thorough risk assessment shows an unavoidable risk of cross-contamination despite best efforts to prevent it.
Different from Ingredient Labels: Unlike bolded allergens in an ingredient list, PAL indicates the potential presence of an allergen, not its intentional inclusion.
Protects Against Cross-Contact: The primary purpose of PAL is to inform allergic consumers about risks from accidental transfer of an allergen during processing or manufacturing.
Requires Consumer Vigilance: Reading the entire label for PAL statements is crucial for allergic individuals, as their placement isn't always standardized.

Understanding Precautionary Allergen Labelling

Precautionary allergen labelling (PAL) is a voluntary warning that food manufacturers use to alert consumers to the possible unintended presence of allergens. Unlike mandatory allergen declarations for ingredients, PAL is used only when, despite rigorous control measures, a risk of cross-contact with an allergen remains. This helps protect allergic individuals who could otherwise face serious, even life-threatening, reactions from trace amounts of an allergen.

Common Examples of Precautionary Allergen Labelling Statements

Food labels use various phrases to convey the message of potential cross-contact. These statements are crucial for allergic consumers navigating food products. Examples of PAL statements include “May contain [allergen],” “Not suitable for those with [allergen] allergy,” and “Made on shared equipment”. For a more detailed list of common PAL statements, please see {Link: Food Standards Agency https://www.food.gov.uk/business-guidance/precautionary-allergen-labelling}.

The Role of Risk Assessment in Allergen Labelling

Food businesses must conduct a risk assessment before using PAL to ensure it's justified. This prevents overuse, which can lead to consumers ignoring warnings. Proper risk assessment is essential for justified use of these labels, and consumers must read labels carefully to make safe food choices.

Steps in a Proper Risk Assessment:

Identify Potential Sources: Evaluate all possible cross-contact points.
Minimize Risk: Implement control measures like dedicated equipment and cleaning.
Assess Unavoidable Risk: Apply PAL if cross-contact risk remains despite measures.
Communicate Clearly: Use clear, non-misleading PAL based on the assessment.

Comparison of Precautionary vs. Mandatory Allergen Labels

Understanding the difference between voluntary PAL and legally required ingredient declarations is important.


Feature	Precautionary Allergen Labelling (PAL)	Mandatory Allergen Labelling (Ingredients)
Regulation Status	Voluntary	Legal requirement
Purpose	Warns of possible, unintentional presence from cross-contact	States allergens intentionally added
Placement	Can vary on the label	Must be clearly in the ingredient list
Trigger	Unavoidable cross-contamination risk	Allergen present in the final product
Example	“May contain milk”	Milk in ingredients

Global Perspectives and Harmonization Efforts

Inconsistent PAL use has caused confusion. Organizations like the WHO and FAO recommend a standardized, risk-based approach. The UK and EU provide guidance emphasizing risk assessment. Australia and New Zealand are implementing Plain English Allergen Labelling (PEAL) for clearer information, including PAL.

Conclusion

Examples of precautionary allergen labelling include phrases like “may contain [allergen]” and “processed on shared equipment”. These voluntary labels are vital for individuals with severe food allergies as they communicate the risk of unavoidable cross-contact. Proper risk assessment is essential for justified use of these labels, and consumers must read labels carefully to make safe food choices.

Frequently Asked Questions

PAL is a voluntary statement used by food manufacturers to communicate the risk of potential, unintentional allergen presence in a product due to cross-contact during manufacturing, processing, or handling.

Mandatory labelling declares allergens intentionally included as ingredients, while PAL warns of allergens that may be present unintentionally despite stringent precautions. PAL is voluntary, whereas mandatory labelling is legally required.

If you have a serious food allergy, it is generally recommended to avoid products with a 'may contain' warning for that specific allergen. This statement signifies an unavoidable risk that poses a danger to allergic individuals.

No, a product cannot carry both a 'free-from' statement and a 'may contain' warning for the same allergen. The two labels contradict each other and would be considered misleading to consumers.

A PAL is used when a food business has conducted a thorough risk assessment and identified an unavoidable risk of allergen cross-contact that cannot be eliminated through segregation, effective cleaning, or other control measures.

This label means the food was produced on the same machinery that also handles ingredients containing the specified allergen. This poses a risk of cross-contamination, as equipment cleaning may not remove all residual traces.

No, blanket or generic statements like 'may contain allergens' are not considered good practice. They can be misleading as they are unlikely to be based on a specific risk assessment for each potential allergen.