At first glance, a label like “may contain peanuts” might seem like a minor note on food packaging. But for people living with food allergies, it can mean the difference between enjoying a meal and going to the emergency room. That is why EFA and our food allergy community are calling for clear and harmonised rules on precautionary allergen labelling (PAL).
EFA has responded to the recent consultation launched by the Codex Alimentarius Commission, calling for stronger international guidelines on PAL. These guidelines set the international standard beyond Europe and will determine how allergen risks are communicated on food packaging and how confidently people with food allergies can choose what to eat.
PAL is a must for food allergy safety
We are asking for PAL to become mandatory and used only when there is reliable evidence that a product may contain unintended traces of allergens. We insist on the evidence because at the moment, PAL is applied too broadly in the food sector, often used when there is no proof of risk, and worded in many different ways. This practice might be seen as legally covering business in case of problems, but it limits food choices and creates uncertainty for patients.
What we need is a system where PAL is based on real risk, not assumptions. This means clear rules on when and how PAL is used, supported by scientific thresholds and a proper food quantitative and/or qualitative risk assessment, so that people with food allergies can better trust what they read on a label and the food industry as a whole.
We also recommend placing PAL directly under the ingredient list using one clear and consistent format. For example, “may contain [allergen]”. Our community sustains that offering multiple options or vague alternatives would weaken the guidelines and lead to inconsistent labelling across countries.
One standard for everyone, everywhere
As food is a global market, being produced and sold, PAL must work the same way in every European country. We do not support proposals that would allow national or regional authorities to set their own reference doses on allergen risk, as this would lead to differing thresholds across markets, different labelling, and confusion for patients.
A single, harmonised approach to allergen labelling is the only way to ensure that food allergy safety is not left to chance, no matter where a product is bought or consumed.
In addition, we welcome that the Codex Alimentarious Commission is open to hear novel ideas about how PAL should be presented, including EFA’s suggestions. EFA continues to strongly support the introduction of a mandatory Comprehensive Allergen Statement on packaging, bringing together all allergen-related information such as ingredients, PAL, “free-from” claims, and risk assessment in one place.
Education and training
To make PAL effective, it is important that everyone involved in the food chain understands how it works. We have called for education and training to be a central part of the guidelines, targeted at all involved stakeholders, including food business operators, health professionals, national authorities, and consumers.
Understanding how PAL is applied and why specific thresholds are used can help avoid miscommunication and ensure that food allergy risks are managed effectively.
#EFACommunity position on PAL
This consultation response was developed together with our Food Allergy Working Group, through close collaboration with our national members. We are grateful to Food Allergy Italia, the Dutch Food Allergies Foundation, the German Allergy and Asthma Association (DAAB), the Luxembourg Allergy Network, and the Spanish Association for People with Food and Latex Allergy (AEPNAA) for their time, input, and dedication.
We believe that everyone deserves to feel safe when choosing food. To make that possible, we need reliable and consistent labelling. EFA will continue working closely with our community to ensure precautionary allergen labelling that truly protects patients.
EFA is looking forward to contributing to the next steps in the development of the Codex PAL Guidelines.
You can find EFA submitted response here.