In early October, we submitted insights from the #EFACommunity on food allergy to a dual consultation organised by the Codex Alimentarius Commission (CAC). This consultation covered two key food allergen-related areas: the revision to the allergen provisions of the General Standard for the Labelling of Prepacked Food (GSLPF) and the development of Guidelines for the Use of Precautionary Allergy Labelling (PAL).
This consultation phase was the latest of a series of negotiations before reaching the final standard. The GSLPF revision is now close to adoption, while the PAL Guidelines are still in earlier development. As an observer at Codex since 2019, EFA has brought our community perspectives to all consultative steps, working closely with our Food Allergy Working Group of Members.
Updating the GSLPF to protect food allergy patients
EFA’s recommendations for the GSLPF revision focused on two main aspects:
Clear and safe allergen exemptions: EFA advocates that any exemption from allergen labelling requirements must not jeopardise safety of food allergy patients. Overly restrictive choices can lead food allergy consumers to develop anxiety towards their food options, so having a clear, easy to understand list of exemptions is essential. For example, in Europe, the list cannot include beer, given its high wheat, barley and gluten content.
Standardise allergen statements: EFA reiterates its support for mandatory. separate allergen statements, recalling our proposal for a dedicated ‘Allergen Statement’ that would contain all information related to allergens, including PAL. This statement should have harmonised wording starting with ‘Contains…’, and be placed directly under the ingredient list. This setup would ensure consistency and transparency, benefiting all consumers by making allergen information readily visible.
Patients ask for a mandatory PAL
On the second component of the consultation (the development of PAL Guidelines), EFA emphasised several critical points that could enhance the use of PAL statements:
Mandatory PAL: Based on the FAO/WHO expert report on allergen risk assessment (2023), EFA supports making PAL mandatory. Voluntary PAL often leads consumers to mistakenly assume that the absence of PAL means there is no risk which is dangerous, even fatal, for those with food allergies.
Separate PAL for Gluten and Coeliac Disease: EFA pointed out that gluten allergy and coeliac disease are distinct conditions with differing risk thresholds and regulatory requirements. Coeliac disease already has a Codex-recognized threshold. And the use of PAL should not be restricted solely to meet the requirements for coeliac gluten-free claims. We recommend either removing coeliac disease from these PAL Guidelines or creating a separate PAL section specifically for gluten regarding coeliac disease.
Clear, consistent wording: PAL must be presented in a single statement and start with ‘May contain…’ to reduce confusion. Multiple wording options can create unnecessary interpretation, potentially leading to harmful assumptions about allergen content.
Quantitative vs. Qualitative Risk Assessments: While qualitative risk assessments are valuable, EFA prefers quantitative assessments to determine the need for a PAL statement. This approach ensures consistent safety practices, and consumer education should be a foundational element to increase understanding of PAL use.
Comprehensive education strategy: EFA stresses the importance of an appropriate education strategy to cater for all food allergy patients, but also food business operators and national food safety authorities, ensuring all parties understand the importance and implementation of PAL.
EFA continues following closely the process for the development of PAL Guidelines at Codex level. We thank our members of the EFA Food Allergy Working Group for their invaluable expertise and contributions to this response.
You can access the full EFA submission here. Previous EFA responses in the context of this consultation can be found here, here and here.