The Spanish Agency for Food Safety and Nutrition (AESAN) has recently published an interpretative note describing a voluntary procedure to justify the use of precautionary allergen labelling due to the unintended presence of allergens in prepacked foods. This document represents a relevant step towards a more consistent, objective and science-based application of “may contain” statements.
Precautionary Allergen Labelling (PAL) is a voluntary labelling statement indicating the possible unintended presence of one or more allergens as a result of cross-contact or other factors related to the production process. Its main objective is to protect allergic or intolerant consumers by providing clear and truthful information to support safe consumption decisions.
To date, PAL is not subject to harmonised regulation at European Union level, although Regulation (EU) No 1169/2011 foresees that the Commission may adopt implementing acts regarding the declaration of possible unintended allergens. In the absence of such regulation, responsibility lies with food business operators to manage and communicate this risk appropriately.
One of AESAN’s key messages is that PAL should not be used systematically or as a preventive measure, but only when, after correctly applying allergen control measures (HACCP, good manufacturing and cleaning practices), the risk cannot be completely eliminated. In such cases, the decision to include a precautionary statement should be supported by a risk assessment, taking into account potential consumer exposure and the reference doses established for different allergens.
The procedure also highlights the importance of having reliable analytical data, particularly quantitative allergen analyses, which allow detected levels to be compared with action levels and provide a sound technical basis for deciding whether or not to apply PAL. This approach helps to avoid the excessive use of precautionary statements that may cause confusion and unnecessarily limit food choices for allergic consumers.
YOUR PLUS: In this context, AGROLAB Group laboratories play a key role by providing accredited, sensitive and reliable allergen analyses, as well as technical support for result interpretation and risk management. Our aim is to support the food industry in making data-driven decisions, enhancing consumer safety and applying precautionary allergen labelling that is rigorous, justified and aligned with AESAN’s recommendations.
Author: Dra. Isabel Gómez, AGROLAB Iberica
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