Introduction
With food allergies affecting 6–8% of children and 3–4% of adults in the UK, accurate allergen labelling is critical for consumer safety and regulatory compliance. Precautionary allergen labelling, such as ‘may contain’ notices, informs consumers about the potential presence of allergens due to cross-contamination risks. Used correctly, these notices protect customers and align with Natasha’s Law and other UK regulations. Misuse, however, can lead to consumer confusion or legal issues. Skilltopia’s CPD-certified online courses, including Food Allergy Awareness and Food Hygiene Levels 1–3, equip food businesses and schools with the knowledge to implement effective precautionary labelling. This guide explores ‘may contain’ notices, their appropriate use, and how Skilltopia’s training ensures compliance. Enrol at skilltopia.co.uk/buy-courses to safeguard your operations.
What is Precautionary Allergen Labelling?
Precautionary allergen labelling (PAL), often seen as ‘may contain’ or ‘not suitable for’ statements, warns consumers of the potential presence of allergens not intentionally included in a product. These notices address risks from cross-contamination during production, such as shared equipment or facilities handling allergens like peanuts or milk. PAL is not a substitute for mandatory allergen declarations (e.g., the 14 allergens listed in UK law: peanuts, tree nuts, milk, eggs, fish, shellfish, wheat, soy, sesame, celery, mustard, lupin, molluscs, sulphites) but a supplementary measure to manage unavoidable risks. According to the Food Standards Agency (FSA), PAL should only be used when a genuine risk exists, ensuring clarity for consumers and compliance during Environmental Health Officer (EHO) inspections.
When to Use ‘May Contain’ Notices
‘May contain’ notices should only be applied after a thorough risk assessment confirms an unavoidable risk of allergen cross-contamination. Examples include:
- Shared Equipment: A bakery uses the same mixer for nut-free and nut-containing products, with a risk of trace contamination despite cleaning.
- Shared Facilities: A factory processes milk and non-milk products on the same line, where complete allergen removal is not guaranteed.
- Supply Chain Risks: An ingredient supplier cannot guarantee an allergen-free product due to shared storage or transport.
Overuse of ‘may contain’ notices can reduce consumer trust and limit choices for allergy sufferers, so they must be justified. The FSA advises against blanket labelling (e.g., ‘may contain nuts’ on all products) without evidence. Skilltopia’s Food Allergy Awareness course trains staff to assess when PAL is necessary.
Best Practices for Precautionary Labelling
To ensure effective and compliant precautionary allergen labelling, follow these best practices:
- Conduct a Risk Assessment: Evaluate production processes, equipment, and supply chains to identify cross-contamination risks. Document findings for EHO inspections.
- Use Clear Wording: Opt for specific phrases like ‘may contain peanuts’ or ‘not suitable for milk allergy sufferers’ rather than vague terms. Ensure notices are visible and near ingredient lists.
- Comply with Natasha’s Law: For pre-packed for direct sale (PPDS) foods, like sandwiches or cakes, list all ingredients and allergens on labels, with PAL added only if risks persist.
- Minimise Cross-Contamination: Use dedicated equipment, separate storage, or schedule allergen-free production first to reduce the need for PAL. Skilltopia’s HACCP courses guide these controls.
- Verify Supplier Information: Ensure suppliers provide accurate allergen data and PAL statements for ingredients. Maintain records for traceability.
- Train Staff: Educate staff on allergen risks, PAL application, and communication with customers. Skilltopia’s Food Allergy Awareness course covers these requirements.
- Review Regularly: Update PAL policies based on new risk assessments, supplier changes, or updated FSA guidance to ensure ongoing compliance.
- Communicate with Customers: Provide clear allergen information for non-prepacked foods (e.g., menus, verbal communication) to complement PAL on packaged items.
- Document Compliance: Keep records of risk assessments, supplier data, and staff training for EHO inspections and compliance with ISO 22000 or SALSA standards.
UK Legal Requirements for Allergen Labelling
UK food businesses must adhere to strict regulations for allergen labelling, including precautionary notices:
- Food Safety Act 1990: Requires food to be safe and free from harmful allergens.
- Regulation (EC) No 852/2004: Mandates food safety systems, including allergen controls, often via HACCP.
- EU Food Information for Consumers Regulation (No 1169/2011): Requires clear declaration of the 14 allergens in all foods, including non-prepacked items.
- Natasha’s Law (2021): Mandates full ingredient and allergen labelling for PPDS foods, with PAL used only for unavoidable risks.
Non-compliance can result in fines (up to £5,000), legal action, or reputational damage. Proper use of PAL demonstrates due diligence to EHOs.
How Skilltopia’s Courses Ensure Compliance
Skilltopia’s online courses, certified by The CPD Certification Service, equip staff to implement effective precautionary allergen labelling:
- Food Allergy Awareness: Teaches staff to identify the 14 allergens, assess cross-contamination risks, and apply PAL correctly (2-4 hours).
- Food Hygiene Level 1: Covers basic hygiene and allergen awareness for support staff (1-2 hours).
- Food Hygiene Level 2: Trains food handlers on allergen labelling, Natasha’s Law compliance, and cross-contamination prevention (4-6 hours).
- Food Hygiene Level 3: Equips managers with skills to develop allergen policies and HACCP systems, including PAL (10-12 hours).
- HACCP Level 2 and 3: Guides staff and managers in integrating allergen controls and PAL into safety systems.
Starting at £12.50, our courses are affordable, flexible, and provide instant downloadable certificates for compliance records. Contact hello@skilltopia.co.uk for bulk discounts or enrol at skilltopia.co.uk/buy-courses.
Frequently Asked Questions
What is precautionary allergen labelling?
Precautionary allergen labelling, like ‘may contain’ notices, warns of potential allergen cross-contamination risks not covered by mandatory declarations.
When should ‘may contain’ notices be used?
Use them only when a risk assessment confirms unavoidable cross-contamination risks, such as shared equipment or facilities.
Is precautionary labelling mandatory in the UK?
No, but it’s a best practice when risks exist, supporting compliance with Natasha’s Law and the Food Safety Act 1990.
How can Skilltopia’s courses help with allergen labelling?
Our CPD-certified courses train staff to assess risks, apply PAL correctly, and ensure compliance with UK allergen regulations.
Get Started with Skilltopia
Proper precautionary allergen labelling is essential for consumer safety and compliance in UK food businesses and schools. Skilltopia’s CPD-certified online courses provide the training needed to implement effective ‘may contain’ notices and meet regulatory standards. Enrol at skilltopia.co.uk/buy-courses or email hello@skilltopia.co.uk for tailored training solutions.
Skilltopia is your trusted provider of CPD-certified online food hygiene and allergy training for UK businesses and schools. Stay safe and compliant!
