Blueprint: Navigating New 'May Contain' Allergen Labelling Guidelines

New International Guidance on 'May Contain' Allergen Labelling: What You Need to Know

The landscape of food safety is continually evolving, and staying ahead of changes is crucial for UK food businesses. A significant development in allergen management has emerged from the global food safety standards body, the Codex Alimentarius Commission. On July 7, 2026, during its 49th Session in Geneva, Switzerland, Codex adopted new international guidelines for precautionary allergen labelling (PAL), commonly known as 'may contain' statements. This new guidance aims to make these statements more meaningful, science-based, and consistent for consumers globally.

For food businesses, this matters immensely. While Codex texts are voluntary, they serve as internationally recognised benchmarks that often influence national legislation and best practices. These guidelines are designed to improve consumer confidence and provide greater clarity for food manufacturers and regulators alike regarding allergen communication. They complement existing Codex standards on allergen declaration and food allergen management, including the Code of Practice on Food Allergen Management for Food Business Operators (CXC 80-2020).

With food allergies affecting an estimated 4.3 percent of the global population, clear and accurate allergen information is not just a regulatory requirement but a moral imperative. UK food businesses, including restaurants, caterers, and manufacturers, must consider these international developments as they shape future national approaches from bodies like the Food Standards Agency (FSA). Proactive review and potential updating of your allergen communication strategies are essential to ensure you remain compliant and uphold the highest standards of food safety.

Your Action Blueprint: Steps to Proactive Allergen Management

This blueprint provides clear, actionable steps for UK food businesses to assess and adjust their current allergen labelling practices in light of the new Codex guidance. Implement these steps this week to ensure your business is prepared for future regulatory shifts and maintains exemplary food safety standards.

• Step 1: Understand the New Codex Guidance: Familiarise yourself with the core principles of the new Codex guidelines. While the full text may be extensive, focus on the key recommendations for when and how 'may contain' statements should be used. The emphasis is on risk-based assessment rather than blanket statements. This will inform a more precise approach to your own labelling decisions, moving away from generic disclaimers towards specific, justified warnings.
• Step 2: Review Your Allergen Risk Assessments: Conduct a thorough review of your existing allergen risk assessments. This involves re-evaluating your entire supply chain, production processes, and kitchen procedures to identify potential cross-contamination points. The new Codex guidance underscores the importance of a robust, science-based approach to determining the necessity of PAL. Ensure your assessments are documented and regularly updated. If you need assistance, our [risk assessment services](/risk-assessment) can provide expert support.
• Step 3: Assess Current Precautionary Allergen Labelling (PAL) Usage: Critically examine every instance where your business currently uses 'may contain' or similar precautionary statements. Are these statements based on a genuine, unavoidable risk of cross-contamination, or are they used out of caution without a clear scientific basis? The goal of the new guidance is to reduce unnecessary PAL, which can lead to 'allergen fatigue' among consumers. Only use PAL when all reasonable efforts to prevent cross-contamination have been exhausted, and a demonstrable risk remains.
• Step 4: Implement Robust Allergen Management Systems: Ensure your allergen management system is comprehensive and effective. This includes strict segregation of allergenic ingredients, dedicated equipment where possible, thorough cleaning protocols, and clear operational procedures. A strong HACCP-based system is fundamental to controlling allergens. For guidance on establishing or enhancing your system, explore our [HACCP services](/services/haccp).
• Step 5: Train Your Team on Updated Practices: Effective allergen management relies heavily on staff awareness and competence. Provide refresher training to all relevant staff – from kitchen porters to front-of-house staff – on the importance of accurate allergen communication, cross-contamination prevention, and the correct application of 'may contain' statements. Emphasise the shift towards risk-based assessment. Consider our [Allergens Level 2 course](/courses/allergens-level-2) to ensure your team is fully up-to-date with best practices.
• Step 6: Update Documentation and Records: Maintain meticulous records of your allergen management procedures, risk assessments, staff training, and labelling decisions. This documentation is vital for demonstrating due diligence to an Environmental Health Officer (EHO) during inspections. Ensure your allergen matrix and ingredient specifications are always current and reflect any changes in your supply chain or recipes.

What Good Looks Like: Your 'May Contain' Readiness Checklist

• Your 'may contain' (PAL) statements are scientifically justified and based on thorough, documented risk assessments.
• You have clear, consistent, and accurate allergen information available for all food products, both prepacked and non-prepacked.
• Your allergen management plan (HACCP-based) effectively controls cross-contamination, and all measures have been exhausted before considering PAL.
• All staff members are thoroughly trained and confident in allergen awareness, cross-contamination prevention, and the appropriate use of PAL.
• You regularly review your allergen controls, labelling, and supply chain information, updating records promptly.
• You are prepared to discuss your allergen strategy with your local EHO, demonstrating a proactive approach to food safety.
• Your business actively monitors FSA announcements and industry updates regarding allergen labelling to anticipate future UK regulatory changes.

Frequently Asked Questions

Frequently Asked Questions

Are these new Codex guidelines legally binding in the UK?

No, Codex Alimentarius texts are not legally binding in the UK. They serve as international benchmarks and best practices. However, they are highly influential and often form the basis for future national legislation and guidance from bodies like the Food Standards Agency (FSA). UK food businesses should view them as a strong indicator of future regulatory direction and align their practices proactively.

How do these new guidelines relate to Natasha's Law?

Natasha's Law (The Food Information (Amendment) (England) Regulations 2019) focuses on mandatory full ingredient and allergen labelling for prepacked for direct sale (PPDS) foods. The new Codex guidelines, conversely, address precautionary allergen labelling ('may contain'). While distinct, both aim to improve allergen communication. The Codex guidance encourages a more science-based, less generic approach to 'may contain' statements, which complements the clarity and precision required by Natasha's Law.

What should I do if I currently use 'may contain' statements extensively across my products?

An extensive use of 'may contain' statements without clear, risk-based justification should be reviewed immediately. The new Codex guidance advocates for a more targeted approach, where PAL is only used when significant, unavoidable cross-contamination risks remain after all reasonable control measures have been implemented. Conduct a thorough risk assessment for each product, identify specific cross-contamination points, and only apply PAL where genuinely necessary. Over-reliance on 'may contain' can dilute the message for allergic consumers and may not align with future best practice expectations.