Allergen labelling. The cross contamination challenge

As part of our series on food allergens we hear more from our Strategic Advisor Sterling Crew. In this blog we look at allergens which are unintentionally added to food and Precautionary Allergen Labelling. (PAL).

Food allergy is recognised as an important food safety issue, which rightly commands a great deal of media, regulatory, industry and consumer attention. Recently reported deaths of UK teenagers with food allergies have highlighted the human impact of the condition and the importance of clear, accurate labelling and effective allergen management.

It is difficult enough for food businesses to label their food accurately with the 14 prescribed allergens which they know they have in their list of ingredients. But what about those that could be present unintentionally from cross-contact or cross-contamination?

When allergens are unintentionally present

Allergen management in most foodservice businesses can be demanding. Typically sites are handling multiple allergens with frequent change overs in busy foodservice environments. There is also an increased demand for complex free-from, vegetarian, vegan and allergen controlled products. These foods are often not made in dedicated areas with dedicated equipment.

Foodservice businesses have a legal responsibility to minimise the risks to allergen susceptible consumers from their products. As part of their allergen communication risk strategy a decision needs to be made on whether precautionary allergen labelling (PAL) is required. It should be based on an outcome of risk assessment and risk management steps.

Allergic individuals should be warned about allergens that may be present unintentionally in food. The aim is to enable consumers at risk to make an informed decision to protect themselves and those in their care. Allergic individuals must be informed about which allergens are present as ingredients and also those that could be present unintentionally from cross-contact or cross-contamination.

The value of allergen labelling other than for intended ingredients is controversial. In the UK, longstanding industry practice emphasises that the use of advisory “may contain” labelling should be the last resort of a series of assessments. It should not be used as an alternative to good allergen manufacturing practice and its relevant controls. In general, the principles referred to for product formulation and avoidance of unintended allergen presence by manufacturers apply equally to foodservice providers. They can be applied to any foodservice operation. No matter how big or how small.

Such “may contain” labels do not help allergic consumers cope with their condition and may mean their food choices become ever more restricted. If used extensively by a food business, customers who are allergic suffers may choose to take their business to those that offer a wider choice. Responsibly applied PAL should be seen as a last resort, following a thorough allergen risk assessment of each product on a case-by-case basis.

New allergen ingredient labelling requirements are coming into force from 1 October 2021 for food pre-packed for direct sale. This is a consequence of the tragic death of of 15-year old Natasha Ednan-Laperouse, who died of anaphylaxis after collapsing on board a flight to Nice in 2016. She had a severe allergic reaction after eating sesame seeds in an unlabelled artichoke, olive and tapenade Pret A Manger baguette bought at Heathrow.

In light of the new legislation and in response to the problems posed by accidental inclusion, the lack of resources and confidence to implement appropriate control systems, more foodservice operators may well implement PAL. Choosing to protect their businesses by adopting a defensive labelling approach.

It makes more sense than ever, for foodservice businesses to review the robustness of their approach to the management and labelling of allergens.

Top ten allergen management tips:

Whenever possible formulate foods to avoid inclusion of unnecessary major allergens as ingredients. Allergen ingredients information should be always be recorded on product specification sheets.
Understand how suppliers determine allergen status. Verify the allergen status of the material suppliers provide and understand their allergen risk and their allergen management practices.
Whenever possible, use dedicated premises and equipment for the storage, handling, processing and production of foods with a defined allergen.
Organise and validate raw material supplies, production schedules and cleaning procedures, to prevent unintended allergen presence.
Train all personnel in an understanding of the necessary allergen control measures and the reasons for them. So they know the procedures and policies when asked to provide allergen information. Provide training on handling allergy information requests and be able to guarantee that allergen-free foods are served to the right customers. Staff must know the risks.
Comply with the relevant labelling legislation, providing appropriate warnings, to potential purchasers, regarding the presence of a major allergen contained in a product. Complete a precautionary allergen labelling risk assessment.
Have an appropriate system in place for recall of any product found to contain a major allergen not indicated on the label warning.
Have an appropriate system to collect and collate information about complaints and possible allergic reactions to foods that are sold, and implement the lessons learned.
Create a positive food safety culture which drives and delivers safe food handler allergen behaviour.
Remember a cornerstone of any allergen management system is the organisations HACCP plan.


If you need advice or support with your allergen management please contact Shield Safety Group. With strategic services and operational software solutions to suit businesses of all sizes we can help you manage food safety compliance in your kitchen. Contact us today to find out more.

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