Precautionary allergen labelling (PAL) — Food Safety Glossary

Voluntary statements such as may be present that warn of possible unintended allergen cross-contact, used separately from the mandatory Contains declaration.

Frequently asked questions

Is precautionary allergen labelling required by law?

No. Precautionary statements such as may be present are voluntary and are not mandated by the Food Standards Code. However, if used they must not be false or misleading and must be kept separate from the mandatory Contains statement under Plain English Allergen Labelling.

What is the difference between Contains and may be present?

A Contains statement declares allergens that are deliberately in the food and is mandatory. A may be present statement is voluntary and warns of possible unintended traces from cross-contact. The two must be shown separately so consumers can distinguish them.

Why is over-using may contain a problem?

If businesses apply precautionary warnings without a real basis, allergic consumers face so many warnings that the statements become meaningless and some may start ignoring them. This erodes trust and can reduce, rather than increase, consumer safety.

How should a business decide when to use PAL?

A precautionary statement should follow a genuine risk assessment of cross-contact after cleaning and segregation controls. Many Australian businesses use the Allergen Bureau's VITAL programme to make that decision consistently and proportionately.

Does a may be present statement replace good manufacturing controls?

No. Precautionary labelling does not excuse a business from minimising cross-contact. Cleaning, scheduling, segregation and validated controls come first; a precautionary statement only addresses the residual risk that remains after those measures.

VITAL (Voluntary Incidental Trace Allergen Labelling) Allergen cross-contact Declared allergens Allergen Plain English Allergen Labelling (PEAL) Food safety glossary Food safety guides
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