Imagine standing in a grocery store, reading label after label, unsure whether the food in your hand is safe to eat. For millions of people living with one or several food allergies, this is a daily reality and a struggle. Precautionary Allergen Labelling (PAL) is meant to help, but too often it creates confusion, limits choices and increases risky behaviours.
In October, EFA submitted a statement to the chair of the 48th meeting of the Codex Committee on Food Labelling (CCFL), the international FAO/WHO organisation setting food standards. The statement, titled ‘Towards a Precautionary Allergen Labelling that empowers consumers and protects patients’ calls for a clear, evidence-based approach to Precautionary Allergen Labelling (PAL) at international level. The statement has been co-created with the members of EFA’s Food Allergy Working Group.
What is PAL and why does it urgently need to be improved?
Allergens can unintentionally find their way into food during manufacturing process, storage, or transportation. PAL statements such as ‘may contain…’, ‘may contain traces of…’ or ‘not suitable for people with X allergy’ are meant to alert consumers about this likely risk. However, in the European Union and the European region, PAL use is voluntary and its overuse has become a growing problem. Many food operators indiscriminately add PAL to their products without conducting a risk assessment. This results in PAL statements on prepackaged foods – no matter if the risk is real or not.
For patients with food allergies and their caregivers, this creates an impossible dilemma. Some avoid products with PAL statements altogether, narrowing their food choices even more. Others take a risk not knowing whether the label reflects the potential hazard. The lack of standardisation in PAL usage fosters distrust, confusion and even potential health risks. Without harmonised rules, patients are left guessing and their safety is compromised.
The food allergy patient case for ED05-based reference doses
Acknowledging that zero risk is impossible, EFA’s statement calls for a balanced approach to PAL that maximises safety of consumers with food allergy, while safeguarding their access to as many food choices as possible. Central to this discussion is whether allergen reference doses (RfDs) should be based on ED05 or ED01. ED05 protects 95% of allergic population from reactions, while ED01 aims to protect 99%.
In line with the FAO/WHO expert recommendation (2023), EFA strongly supports ED05-based reference doses. Here is why:
- A protective and practical approach. Research shows that ED01-based RfDs would not necessarily lead to significant health benefits at population level. In parallel, for consumers reacting at levels below ED05 threshold, tailored education and support must be provided to ensure safety. Moreover, relevant education is necessary for all stakeholders.
- Align with existing technology and methods. Analytical methods already exist for the detection of allergen presence at the level of ED05, making it viable for the implementation.
- Prevent confusion and ensure meaningful PAL statements. The use of ED01-derived RfDs for PAL would likely result in a flood of unnecessary PAL statements, as manufacturers seek to mitigate liability for even smallest risks. This proliferation would dilute the purpose of PAL, making it less meaningful and less trusted by consumers.
Our advocacy for clear and meaningful labels
EFA will continue to follow closely the work of the CCFL in the future steps of developing the PAL Guidelines, offering the food allergy patient perspective and expertise.
We are grateful to the members of the Food Allergy Working for their instrumental input to the process of developing EFA’s positioning on this key issue.
You can read the full EFA PAL statement here.