New Codex guidance on precautionary allergen labelling (PAL)

International development reinforces the risk-based approach of the Allergy Seal of Quality Standard
The Codex Alimentarius Commission has adopted new international guidelines on the use of precautionary allergen labelling (PAL). The aim is to ensure a science-based and consistent application of voluntary allergen warnings worldwide.

From now on, PAL should only be used if a relevant residual risk for people with allergies remains, following a systematic risk assessment and appropriate measures to prevent cross-contamination have been implemented. Therefore a ‘may contain' warning should therefore no longer be used purely as a precautionary measure or to protect against liability.

What does this mean for the Allergy Seal of Quality Standard?
There are no immediate changes to the certification requirements for the Allergy Seal of Quality Standard. The standard already requires documented allergen management in accordance with the principles of a HACCP system based on the Codex Alimentarius. Manufacturers must identify, assess and effectively control allergen-related risks. In addition, maximum levels are defined for certified claims, as are requirements for analyses, quality management and audits.

The new Codex guideline thus reinforces the risk-based approach that has been implemented in the Allergy Seal of Quality Standard for many years.

Implications for auditors
In the context of audits, the traceable assessment of unintentional mixtures is becoming increasingly important. Particular care must be taken to ensure that:

• allergen-related hazards are systematically considered in the HACCP or allergen management system,
• risks of cross-contamination are assessed, and appropriate preventive measures are implemented,
• precautionary labelling ('may contain') is justified in a traceable manner; and
• the requirements for certified claims are always met.

The Codex guideline thus underlines the importance of effective, documented and risk-based allergen management.

Outlook
The Codex Alimentarius serves as an important global reference for the further development and harmonisation of food law requirements. It is therefore to be expected that the new guidelines will influence national regulations and the practice of allergen labelling in future.

Service Allergie Suisse will continue to monitor international developments and assess whether they will result in future adjustments or clarifications to the Allergy Seal of Quality Standard.