Has "May Contain" Labelling Lost Its Meaning? | Precautionary Allergen Labelling Explained | Allergy Companions

Food manufacturing 01.06.2026

By Liljia Polo-Richards

For people living with food allergies, a trip to the supermarket often involves far more than choosing what to eat. Every purchase requires an assessment of risk, with food labels playing a critical role in helping consumers make safe decisions.

One of the most common and, arguably, most misunderstood pieces of information on food packaging is precautionary allergen labelling (PAL). Whether it appears as “may contain nuts”, “made in a factory that handles milk” or “produced on equipment that also processes sesame”, these statements are intended to alert consumers to the possibility of unintended allergen presence resulting from cross-contamination during production.

Recent commentary in The Grocer described precautionary allergen labelling as the “wild west” of food labelling, highlighting concerns that many consumers, campaigners and industry professionals have raised for years. While precautionary warnings undoubtedly play an important role in consumer safety, questions remain about whether the current system provides the clarity and consistency that people living with food allergies need.

A System Built on Good Intentions

The principle behind precautionary allergen labelling is straightforward. Food manufacturers cannot eliminate every risk of cross-contamination, and where there is a genuine possibility that an allergen may be unintentionally present, consumers should be informed.

The Food Standards Agency (FSA) has consistently emphasised that precautionary allergen labelling should only be used following a thorough risk assessment and where the risk cannot be adequately controlled through manufacturing processes. In theory, this should ensure that warnings are meaningful and proportionate to the risk presented.

In practice, however, the situation is often less straightforward. Because businesses are responsible for carrying out their own risk assessments, similar products can carry very different allergen statements despite being produced under comparable conditions. This can leave consumers trying to interpret not only the warning itself, but also the level of risk that sits behind it.

The result is a system that relies heavily on individual judgement, both from manufacturers applying the warnings and from consumers attempting to understand them.

Lost in Translation

One of the biggest challenges facing consumers today is the lack of consistency in the language used.

Walk through any supermarket and it is common to see a range of statements including “may contain”, “may contain traces of”, “made in a factory handling”, “produced on shared equipment” or “not suitable for allergy sufferers”. To the average consumer, these statements appear to suggest different levels of risk. Yet there is often little information available to explain what those differences actually mean in practice.

For many families managing food allergies, this creates a difficult dilemma. Is a product labelled “made in a factory that handles nuts” safer than one labelled “may contain nuts”? Does shared equipment represent a greater risk than a shared production facility? Is one manufacturer simply being more cautious than another?

The reality is that consumers are often left to make these judgements themselves. Rather than providing certainty, the variety of wording can create confusion and undermine confidence in the information being provided. This is particularly concerning when the purpose of allergen labelling is to support informed decision-making.

A warning can only be effective if the person reading it understands what it means.

When Every Product Carries a Warning

The widespread use of precautionary allergen labelling has created another challenge.

For some consumers, allergen warnings have become so commonplace that they appear on a significant proportion of products within certain categories. While the intention is to provide protection, there is a risk that excessive or inconsistent use of precautionary statements may reduce their effectiveness over time.

Many people living with food allergies find themselves taking one of three approaches. Some avoid any product carrying a precautionary warning. Others contact manufacturers directly to seek clarification. A third group makes their own assessment of the wording and decides whether the perceived risk is acceptable.

None of these outcomes are ideal.

Avoiding products unnecessarily can significantly restrict food choice and quality of life. Contacting manufacturers requires time and effort that many consumers simply do not have. Relying on individual interpretation means consumers are effectively carrying out their own risk assessments, often without access to the information needed to make fully informed decisions.

This is why the current debate around precautionary allergen labelling extends beyond the wording on the pack. At its heart, it is a discussion about trust.

Could a More Evidence-Based Approach Help?

Recognising some of these challenges, the FSA and international regulators have been exploring whether precautionary allergen labelling could be applied more consistently through the use of allergen thresholds.

Central to this discussion is a concept known as ED05, or Eliciting Dose 05. In simple terms, ED05 represents the amount of an allergen expected to trigger a reaction in approximately 5% of people with a particular allergy. While the science behind allergen thresholds is complex, the objective is relatively simple: to provide a more consistent and evidence-based framework for determining when precautionary allergen warnings are necessary.

Supporters argue that threshold-based approaches could help address some of the inconsistencies seen within the current system. If businesses were working from the same scientific reference points, consumers might see fewer unnecessary warnings and greater consistency across products. Paradoxically, this could mean fewer precautionary allergen statements appearing on packaging while simultaneously increasing confidence in those that remain.

Of course, the discussion is not without controversy. Allergic reactions vary considerably between individuals, and there are understandable concerns about how any threshold-based system would be communicated to consumers. Scientific consistency alone will not solve the problem if consumers do not understand or trust the information being provided.

Nevertheless, the conversation signals an important shift in thinking. The debate is no longer centred on whether precautionary allergen labelling should exist, but on how it can be made more meaningful, more consistent and more useful to those who rely on it.

Building a System Consumers Can Trust

Ultimately, the purpose of allergen labelling is not simply to transfer information from manufacturer to consumer. It is to help people make safe and informed decisions about the food they eat.

People living with food allergies do not need more warnings for the sake of warnings. They need information that is clear, consistent and proportionate to the risk involved. They need confidence that the same statement means the same thing regardless of which product they are holding.

The concerns highlighted by The Grocer, alongside the ongoing work being undertaken by the FSA and international regulatory bodies, demonstrate that there is growing recognition that the current system can be improved. Greater consistency in both the application and wording of precautionary allergen labelling would benefit not only consumers, but also manufacturers and retailers striving to communicate risk responsibly.

The challenge now is to create a system that maintains consumer safety while improving understanding and trust. Because when someone picks up a product carrying a precautionary allergen warning, the question should not be “What does this label really mean?”

The label itself should provide the answer.

References and Further Reading