Precautionary labelling of foods for allergen content: are we ready for a global framework?

Table 2 Presence and regulation of additional/precautionary allergen labelling on prepacked foods

	Precautionary allergen labelling			“Contains…” labelling permitted	Legislation on allergen disclosure implemented
	In use?	Is use regulated?	Risk-based approach, using thresholds?	“Contains…” labelling permitted	Legislation on allergen disclosure implemented
Argentina [11]	NO	USE IS PROHIBITED	NO	YES and may be used as an alternative to precautionary labelling to indicate potential cross-contamination	2010
Australia/New Zealand[12]	✓	No	Voluntary. Thresholds vary with allergen	✓	2002
Canada [14]	✓ (specific phrasing recommended)	No	No	✓	1994
Chile [28]	✓	No	No	YES and can be used to indicate risk from cross-contamination. NB free-from labels prohibited	2010
China [15]	✓	No	No	✓	2012
European Union [16, 26]	✓	No*	No	No longer permitted from Dec 2014	2003
Hong Kong [17]	✓	No	No	✓	2004
Japan [18]	NO	USE IS PROHIBITED	>10 ppm requires mandatory disclosure for all allergens	YES, only for allergen present in >10 ppm	2002
Kuwait/Gulf [19]	✓	No	No	✓	2008
Malaysia [20]	✓	No	No	✓	2009
Mexico [21]	✓	No	No	✓	2010
Singapore [22]	✓	No	No	✓	2011
South Africa [23]	✓	Yes**	No	✓	2012
South Korea [24]	✓	No	No		2004
Switzerland [29]	✓	Precautionary statements can only be use for non-ingredients above 1 g/kg	Any allergen (whether ‘ingredient’ or not) above 1000 ppm requires disclosure	✓	2002
USA [25]	✓	No	No	✓	2006

*Indiscriminate use of PAL might be construed as misleading and is therefore prohibited by EU legislation. However, no risk assessment is mandated prior to use of PAL therefore suspicion of any risk of contamination (however minimal) can be used to justify use of PAL.
**Legislation requires use of precautionary labelling to be substantiated by a documented risk assessment demonstrating adherence to GMP.

ISSN: 1939-4551