“May contain”: what precautionary allergen labelling is actually for

“May contain traces of nuts” is one of the most common lines on a UK food label, and one of the least understood. Unlike the 14 allergens themselves, there’s no legal requirement to put it there at all, which is exactly why it’s worth understanding what it’s actually for before you add it to everything as insurance.

PAL is voluntary, and that’s the whole point

Precautionary allergen labelling (PAL), the “may contain” line, is not a legal requirement in the way declaring an actual ingredient is. It’s a judgement call a food business makes about the genuine risk that a trace of an allergen not in the recipe could end up in the finished product, through the kitchen, equipment, or storage rather than through the ingredients themselves.

The Food Standards Agency’s guidance is specific about when it belongs: only after a real risk assessment, and only where there’s an unavoidable cross-contamination risk that can’t be adequately controlled through cleaning and segregation. It is not meant to be added by default, “just in case”, across a whole range.

Why blanket “may contain” is actually a problem

It’s tempting to add a precautionary warning to everything; it feels like the safe choice. It isn’t, for a reason that matters to the people the label exists to protect: a warning that appears on everything stops meaning anything. Someone managing a genuine, serious allergy learns to read past a label that always says “may contain nuts”, because on your range it never actually tells them anything they didn’t already assume. The one product where the risk is real gets read with exactly the same shrug as the one where it isn’t.

Overuse of PAL doesn’t just look sloppy; it actively erodes the safety the warning exists to provide, for the exact customers it’s supposed to protect.

Getting the risk assessment right, in practice

A genuine assessment asks concrete questions, not a general feeling of caution:

• Is the same equipment used for a product containing the allergen and one that doesn’t, without a full clean between?
• Is airborne contamination realistic (flour dust in a bakery handling nut-based products nearby, for instance)?
• Can the risk actually be controlled through cleaning, separate equipment, timing, or storage? If it genuinely can, controlling it is the better answer than warning about it.
• Is the warning specific? FSA guidance is clear that a precautionary label should name which of the 14 allergens it refers to; a generic “may contain nuts” is exactly the vague wording our allergens guide flags as easy for automated and manual checks alike to miss, and it’s less useful to the reader than “may contain hazelnuts” when your risk is specifically hazelnuts from a shared prep surface.
• Does it contradict a “free from” claim? FSA guidance discourages labelling a product both “dairy free” and “may contain milk” for the same allergen: if the risk is real enough to warrant the warning, the free-from claim is the one that needs to go.

Who decides (and it isn’t the software)

This is your judgement to make, informed by your own kitchen, your own suppliers, and your own processes, not a rule a piece of software can apply on your behalf. ProvenBatch will never decide “may contain” for you, or infer it automatically from an ingredient list. What it does is carry your supplier’s own precautionary wording through faithfully wherever it appears on a declaration, so you’re working from an accurate picture of what your suppliers themselves have flagged as you make the actual risk-assessment decision. The label is a claim, and on precautionary wording specifically, it’s a claim you’re the only one qualified to make.

If you’re unsure where your own products sit, that’s a genuinely good question to put to your local Environmental Health team. See our guide on what an EHO wants to see for how to make that conversation count.

Sources

• Food Standards Agency: precautionary allergen labelling
• Food Standards Agency: Allergen labelling for food manufacturers