Precautionary allergen labelling is moving towards a more consistent, risk-based international system. In July 2026, the Codex Alimentarius Commission adopted new guidelines covering statements such as “may contain”, supported by reference doses and action levels.
For UK food businesses, this is a significant development, but it does not automatically rewrite domestic labelling law overnight. Codex standards are international benchmarks. They are voluntary unless adopted through national or regional rules, although they can influence regulators, retailers, supply chains and international trade.
The immediate task is therefore not to print new labels. It is to make sure the allergen risk assessment behind every precautionary statement is documented, specific and capable of supporting future change.
What precautionary allergen labelling means
Mandatory allergen labelling tells consumers when one of the 14 regulated allergens is deliberately used as an ingredient. Precautionary allergen labelling, known as PAL, deals with a different issue: the possible unintended presence of an allergen because of cross-contact.
A product may be made without peanuts, for example, but peanuts could be handled on a shared line or enter through a raw material. Where that risk cannot be sufficiently controlled, a business may use a statement such as “may contain peanuts”.
The Food Standards Agency’s current best-practice position is that PAL should only be used when a genuine, unavoidable cross-contact risk has been identified through a thorough risk assessment and cannot be sufficiently controlled by measures such as segregation and cleaning. It should not be used as a routine disclaimer or as a substitute for effective allergen management.
What Codex adopted in July 2026
The new Codex guidance promotes a consistent process. Businesses should first apply appropriate controls to prevent or reduce allergen cross-contact. They should then assess the remaining risk. Precautionary labelling should be used only where the unintended presence is above the relevant action level.
The action levels are linked to reference doses. The Codex approach uses ED05 values. An eliciting dose describes the amount of allergen protein predicted to cause objective symptoms in a stated proportion of people with that allergy. ED05 refers to a dose at which five per cent of the relevant allergic population is predicted to react under controlled challenge conditions.
That definition needs careful handling. ED05 is not a permitted contamination target and should never be treated as an acceptable amount to work towards. Allergen cross-contact should still be reduced as far as reasonably possible. The threshold is intended to support a labelling decision after preventive controls have been applied, not to weaken those controls.
The Food Standards Agency supported greater standardisation and the risk-based principles behind the Codex work. Its June 2026 position also examined the balance between consumer protection, practical measurement and the risk that overused warnings can reduce choice or lose meaning.
What has not changed for UK businesses
UK businesses must still comply with the allergen information requirements that apply to their products and markets. The 14 regulated allergens must be identified when they are ingredients, and allergens in ingredients lists must be emphasised as required.
Current FSA best practice remains highly relevant. A precautionary statement should identify the allergen clearly. “May contain peanuts” is more useful than a vague “may contain nuts” statement, particularly because peanuts and tree nuts are separate allergen categories.
A business should not combine a “free from” claim with a precautionary warning for the same allergen. A free-from claim communicates that the specified allergen is absent under tightly controlled conditions. A warning that it may be present would contradict that message.
A vegan claim is also not the same as an allergen-free claim. A vegan product may still carry a precautionary statement for an animal-derived allergen where a genuine cross-contact risk exists.
Review the risk assessment, not just the wording
The strongest preparation for future PAL changes is a better evidence trail. The risk assessment should map where each allergen enters the site, where it is stored, how it moves through production, and where it could contact another product.
Raw materials are a common weak point. Supplier precautionary statements should be reviewed and passed through the supply chain where relevant, but they should not be copied mechanically without understanding the risk. A supplier change, reformulation or different manufacturing site can alter the exposure.
Production scheduling should also be examined. Running non-allergen products before allergen-containing products may reduce risk, but only if cleaning, handling and environmental controls are effective. Rework, utensils, dust, aerosols, shared oils and temporary storage can all create cross-contact routes.
Cleaning validation needs to show that the method is suitable for the specific allergen and equipment. A visually clean line is not automatically allergen-safe. Where testing is used, the method, detection capability and interpretation should be appropriate to the product and process.
Prepare data for portion-based action levels
The Codex framework links reference doses to action levels that consider the amount of food likely to be consumed. That means businesses may need dependable information about portion size, allergen concentration and variability.
This is more complex than applying a universal parts-per-million number to every product. A small serving and a large serving can produce different allergen exposures at the same concentration. Cross-contact may also be unevenly distributed, making a single sample difficult to interpret.
Businesses should therefore involve appropriately qualified food-safety, analytical and regulatory specialists before adopting threshold calculations. Retailer policies and destination-market requirements should also be checked.
Do not remove warnings without evidence
A more standardised system may eventually reduce unnecessary precautionary statements. That should improve choice and make warnings more meaningful. However, removing an existing label without a complete reassessment could expose consumers to an unmanaged risk.
Any label change should be supported by an updated risk assessment, verified controls, reliable supplier information and a managed change process. Old and new packaging should be controlled so that products are not released with inconsistent information.
Customer services and commercial teams should also understand why a statement has changed. Consumers with severe or multiple allergies may have questions, and a clear explanation of the assessment process can help maintain trust.
A practical preparation checklist
Food businesses should now confirm which products carry PAL, the exact reason for each statement, the allergens involved and the date of the last assessment. Supplier information, cleaning evidence, process maps and portion data should be brought together in one controlled record.
The business should then identify which warnings are strongly supported, which are based on incomplete evidence, and which may have been carried forward historically. That review should lead to better risk management, not immediate label removal.
The new Codex guidance marks an important change in the international direction of allergen labelling. The businesses best prepared for it will be those that can explain not only what their label says, but why it says it.
This article is general information and not legal or specialist food-safety advice. Businesses should follow current UK guidance, customer standards and destination-market requirements.
REFERENCES
1. World Health Organization, Forty-ninth session of the FAO/WHO Codex Alimentarius Commission adopts new standards, 6 July 2026:
2. Codex Alimentarius, Groundbreaking guidelines set to fundamentally change food allergen labelling, 7 July 2026:
https://www.fao.org/fao-who-codexalimentarius/news-and-events/news-details/en/c/1759963/
3. Food Standards Agency, Position on the Codex Precautionary Allergen Labelling Standard including Allergen Thresholds:
4. Food Standards Agency, Allergen guidance for food businesses:
https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses
5. Food Standards Agency, Updated best-practice guidance on food allergen labelling:
