Precautionary allergen labelling: Expert's view

The perceptions of Precautionary Allergen Labelling (also known as May Contain) amongst the public is not hugely positive, with allergic consumers seeing their choice of food products constrained by potentially unclear labelling.


Our Food Safety and Quality Consultants Barbara Hirst and Jessica Sage talk about the perceptions of precautionary allergen labelling in the industry and the issues that are faced by businesses, consumers and regulators. Find out more about our allergen services here.



Hello and welcome everyone to our video blog that we're doing today, my name is Barbara Hirst.

and I'm Jessica sage

and we both work for Reading Scientific Services in the area of food safety and quality specializing in allergen management and what we're going to try and talk a little bit about today is the challenges around Precautionary Allergen Labeling or you might know it more as may contain, and we're going to talk about some of the issues around businesses, food service, consumers and regulators. So Jess I think you're probably going to start here by where are we now with precautionary allergen labeling?  


I think it's fair to say that we're not in a particularly great place with the use of  Precautionary Allergen Labelling currently. I think consumers widely view it as being overused and in some cases the businesses are using it more to protect themselves rather than actually protecting their consumers and consumers may have this perception as well that businesses are using it and essentially so that they don't have to do as much themselves to prevent unintentional presence of allergens occurring in their products which of course you know the the perception of that is not great from a consumer perspective and what it results in is the fact that allergic consumers have a reduced choice of foods that they can buy because you know "may contain" warnings are on you know a lot of different products.


However, I think so as people working in the food industry I think it's it's fair that we may have a slightly different perception and actually we know that for the majority of businesses it's not a case that they are just protecting themselves um and it's much more that the use of Precautionary Allergen Labeling is challenging for these businesses and making these decisions about when it's appropriate or when it's not, it's difficult. So actually things like determining working out how much allergen is is too much, at what point a label is needed or not, you know those sorts of things is it's actually quite difficult for businesses to to you know grapple with.


And actually understanding, you know doing the risk assessment itself understanding what constitutes a real risk to the finished product in the first place. Even things like that are 
very challenging I think as well um information from suppliers interpreting what information from suppliers actually means, if they're supplying an ingredient with a Precautionary Label on it for businesses deciding whether or not to carry that warning forwards, that can often be quite a difficult thing um to actually determine whether they should be doing that or not.


We know we have more tools available to us now so things like allergen reference doses which I know I think you're going to talk about in a moment Barbara, those can help us to understand at what level a label should be used and when it's appropriate, but unfortunately currently reference doses aren't being consistently used within industry yet. But we are making progress so yes, Barbara, thinking about so I've talked a bit about where we are at the moment Where are we moving to? What What does the future look like?


Its a great question Jess, and of course our regulator the Food Standards Agency is looking at this and this is the second time around of them doing a consultation with the wider public and wider businesses both retailers, food manufacturers, food service and all of that.


So they did an exercise back in December 2021, I think that was published in the middle-ish of 2022 and they're going around again now, so if any of you are interested by the way, the consultation from the Food Standards Agency, it closes on the 22nd of May, and they're asking and in inviting people to make an opinion. They're looking at various things and they're trying to introduce some best practice I think it's probably not going to come in in regulation, so they're basically saying that Precautionary Label or "may contain" should only be used following a thorough risk assessment.


I think we can all agree that that's got to be the good basis for all of this right? They've also decided that, or asking opinion should I say, that the may contain "X", you shouldn't be putting things together so if you have a challenge with just peanuts you should say "may contain peanuts"

If you've got a challenge with just the tree nuts you should say "may contain tree nuts". You shouldn't use "may contain nuts" to cover that, both of those are the umbrella term that that's not good practice because obviously some people are allergic only just to one type of tree nut.


They're also I think being very clear that a "may contain" label shouldn't come with "free from" for the same allergen. So you can't call something milk free "may contain milk",  so you can't use those two terms together, and I think just setting that out is good practice. And also I think they're encouraging businesses that if if somebody does contact the business and say I want to know why you've used a "may contain" here,
or maybe why you haven't that actually do you know what you've got to have some information or some evidence behind that that you can then articulate to people as to why you might have done that. So just urge any of you out there if you are interested in helping with the consultation you've got till the 22nd of May.


You mentioned reference doses Jess and of course I guess the message here is that that we have them now available, and these of course are based on clinical feeding studies where we know a certain percentage of that allergic population will start to have probably a mild reaction, and it's about that choice about when "may contain" starts to become appropriate on a kind of a population type level and, I think for me there's there's a big debate that we all need to have here and a lot of consumer education, but I think you asked me about the future and I think that's where we all know we need to get to, but we've got a lot of questions to think about and answers and opinion to to scope out before I think we get to that point.


So obviously we've written an article, in fact you've written a lovely article Jess about using reference doses to help some of those choices around Precautionary Allergen Labelling so if any of you are out there interested in that go to our website and you'll be able to pick that up. And we've also designed an open course all around this about how you can use reference doses to help with those choices around Precautionary Allergen Labeling because we realize that this is not a very straightforward area and, you know in the words of the FSA they say you should use it if there's a significant and real risk. And I think the real risk is quite always quite straightforward to understand, it's the significant bit that's hard so hopefully we can help you navigate some of that.


Yes absolutely and as you say we know progress is being made in this area and changes are likely to come our way In terms of actually the use of reference doses and which reference doses will be using things like that, so we don't know exactly what what's going to be decided upon so yeah I guess the message is watch this space and we'll come back to you when we know more. Great. Excellent thanks very much everyone.

Thank you, bye!


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