Precautionary allergen labelling (PAL), such as “may contain”, should only be used when there is a genuine and unavoidable risk of allergen cross-contact that cannot be removed through risk management. Overusing PAL can reduce food choices for people with allergies and lead to mistrust of allergen warnings—potentially putting lives at risk.
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This checklist is designed to help food businesses understand when and how to apply PAL appropriately.
Start by identifying all potential allergens in the foods and ingredients entering your premises. Review allergen information from suppliers and pass it on accurately. If in doubt—ask the supplier.
Can the allergen be removed or swapped for a safer alternative? For example, consider poppy seeds instead of sesame seeds.
Review your production process to identify where cross-contact might occur. This is part of your Hazard Analysis at Critical Control Points (HACCP) and will inform your food safety risk assessments.
Physically separate allergenic ingredients from others. Use designated storage areas, utensils, and production lines wherever possible.
If separation isn’t possible, reduce the risk through cleaning. Validate cleaning visually and use testing when appropriate to confirm allergens have been removed.
Only apply precautionary labelling if there is a real and unavoidable risk of allergen cross-contact that can’t be controlled through cleaning or separation.
Use clear and specific statements like “may contain peanuts” or “not suitable for people with milk allergy” on prepacked foods. For non-prepacked items, make sure this information is shared verbally or displayed clearly on site.
Regularly review PAL use—especially if you change suppliers, update recipes, or modify site practices.
Applying PAL indiscriminately can mislead consumers and put their health at risk. Responsible labelling supports people with food allergies to make informed choices—improving their safety, confidence, and quality of life.
