Consumer trust in food labels is not a matter of convenience – it’s a matter of health safety for people living with food allergy and their families. However, food labelling remains inconsistent across the world and precautionary allergen information (i.e. may contain) is often unreliable.
At the 48th Codex Committee on Food Labelling (CCFL) meeting, EFA, an observer to the committee since 2019, was represented by President Marcia Podestà and Sabine Schnadt from EFA Member DAAB (German Allergy and Asthma Association).
The CCFL, a specialised committee under the Codex Alimentarius Commission (CAC), brings together national food safety authorities, international organisations, industry and civil society organisations to discuss the setup and application of international food labelling standards.
The meeting, organised in Quebec (Canada) from 27 October to 1 November, had several critical topics in the agenda. These included the revision of allergen provisions in the General Standard for Labelling Prepacked Food (GSLPF), the Guidelines for Precautionary Allergen Labelling (PAL), labelling requirements for e-commerce, the use of technology in food labelling and allergen labelling in emergencies. Throughout the meeting, EFA advocated for science-based, clear allergen labelling standards to prevent life-threatening reactions, reflecting the priorities and needs that with our food allergy patient community we have brought to the Codex public consultations.
EFA’s key messages to CCFL: food allergy patients deserve better
The revision of allergen-related provisions of the GSLPF
Following our previous comments to the different GSLPF drafts proposed by CCFL since 2021, EFA targeted some specific aspects of the guideline:
- Defining ‘allergenic food’: EFA supported adding a definition to distinguish ‘food allergen’ (a substance, usually a protein triggering an allergic reaction) from ‘allergenic food’ (food that contains one or more food allergens).
- Adding gluten: we proposed the inclusion of ‘gluten’ in the list of priority allergens, highlighting the differences between food allergy and coeliac disease as two different, but equally serious medical conditions. Our proposal was supported also by the EU, and eventually taken on board by the Chair.
- Mandatory ‘Allergen Statement’: EFA called for all allergen-related information, including PAL, to be consolidated into one clear statement on food packaging.
Precautionary Allergen Labelling (PAL) guidelines
Including warnings like “may contain” have been voluntary and inconsistent for too long. As we have for EFA:
- PAL should be mandatory to ensure clear allergen risk communication.
- EFA supported, together with the EU, the CCFL decision to go for PAL reference doses based on eliciting dose 05 as recommended by FAO/WHO.. EFA explained its full rationale for this position in a dedicated PAL statement, including that it would provide protection for allergic consumers while giving opportunity to have food choices
- EFA’s suggestion for coeliac disease and gluten to be addressed within PAL guidelines, while ensuring clear distinctions between allergens like wheat (IgE-mediated) and gluten (non-IgE-mediated), was well-received by the Chair.
The use of e-commerce and how to protect consumers beyond physical labels
EFA emphasised that the growing e-commerce market must not leave food allergy patients behind:
- No labelling exemptions: small package units sold online must display full allergen information.
- Include PAL in e-commerce. Despite being voluntary, it must appear in online food listings to protect consumers.
Technology in food labelling.
While technological advancements such as QR codes are promising, EFA underlined the key principle: allergen information must always appear on the product itself. Relying solely on digital tools is not an option when patient safety is at stake.
Food labelling in emergencies
In crisis situations, food safety standards must not waver. EFA welcomed reassurances that allergens would remain a priority under food safety provisions. If allergenic foods were ever substituted in emergencies, proper labelling must be mandatory.
Finally, on potential future work and emerging issues, EFA raised the need to address ‘free from X allergen’ claims to protect the most vulnerable 5% of consumers with food allergies.
The human cost of poor labelling
Behind every policy recommendation is a child carrying an EpiPen, a parent triple-checking labels, or a teen hesitant to eat out with friends. Food allergies can cause life-threatening anaphylaxis in seconds.
By advocating for clear, mandatory labelling, EFA ensures food allergy is a priority in global food policy and gives a voice to those who need it most.
The work continues
The CCFL meeting was a milestone for #EFACommuity food allergy advocacy, reflecting the global patients’ growing concern over allergen labelling. Science-based solutions are critical to filling regulatory gaps and ensuring food safety for everyone.
EFA delegation left Canada delighted for the many goals achieved on behalf of the food allergy patient community, but also fully aware of the work that still needs to be done at all levels to ensure healthy and safe food for all.
Find more information in the official CCFL48 report here.