You will find the warning "May contain [allergen]" less and less often on food labels. "May contain traces of [allergen]" is a thing of the past. This is due to the new allergen policy that applies in the Netherlands since January 1, 2024. 

The majority of consumers read over the text "May contain peanuts" on a package of chocolate cookies, but this precautionary allergen labeling (PAL) is intended to help allergic consumers assess whether they will eat the cookies or not. 

In practice, manufacturers often use the PAL to cover themselves because they cannot completely rule out cross-contamination. Or simply "to be on the safe side." The problem is that the allergic consumer will no longer take the PAL seriously and, by consuming the foods in question, increase the risk of a serious allergic reaction. 

To end the ever growing number of PAL, companies must now take three steps to determine whether a PAL is allowed on the label:

1. Risk reduction: companies must take preventive measures to prevent or reduce cross-contamination. For example: separate products/ingredients, clean production lines, select suppliers, adjust recipes, make technical changes to production equipment.

2. Companies must conduct a risk assessment to determine the actual risk of cross-contamination that remains after preventive measures are in place.

3. Risk communication: only in case of a real risk of cross-contamination (exceeding reference values) a PAL may be put on the label. This way, consumers know that despite preventive measures, there is a risk that a particular allergen is present.

Another important policy change lies in the higher reference doses for allergens (values at which allergic consumers will have a mild reaction). For a long time, the Netherlands applied strict, low values, but now the WHO's recommendations have been followed. The manufacturer may choose between "May contain [allergen]" or "not suitable for xxx”. Both are given the status of official authorized PAL wording. "May contain traces of [allergen]" is no longer allowed.

Producers need to scrutinize their allergen policies. From January 1, 2026, labels must be in line with the new allergen policy. It is expected that many PAL warnings will (have to) disappear due to the preventive measures and the higher reference values. From January 1, 2026, the label may only contain a PAL in case of a real risk of cross-contamination, which the producer must be able to substantiate. This is going to cause quite some waves.