Lost in Intentions: Making Sense of Food Labels

Image by the Irritated geek.

Over the past few decades, there has been a surge in food allergies which some experts think is at least partly due to the use of more allergens in processed foods, both as whole allergens (e.g. milk) and their constituent parts (e.g. caseins, whey proteins, lactose, etc.). Another consequence of the rising popularity of complex, processed foods has been the implementation of food labelling regulation to warn people with allergies about the (potential) presence of triggers. But increasingly sophisticated manufacturing processes and patchily-implemented regulations have resulted in a proliferation of labels which confuse both the food-allergic and doctors alike.

This page deals with the following topics:

Common mistakes made about ingredients labels

Ingredients labels are meant to inform a consumer of everything that’s in a product’s recipe and should include every food deliberately added to the product.

Not realising that ingredients labels are subject to legal requirements

Around 1 in 3 people do not realise that ingredients labels are regulated in most countries. Currently, around 100 countries have legislation requiring manufacturers to list all priority allergens intentionally present in the food as an ingredient.

Manufacturers selling food products in the EU, the UK, Canada, the US, Australia and New Zealand are also required to make those priority allergens stand out in the ingredients list, so they may be bolded, italicised, CAPITALISED, highlighted and/or underlined.

In those countries, when tree nuts, fish or shellfish are included in the food product, manufacturers also have to specify what type of tree nut, fish or shellfish is in the food.

For example: Contains: dates (54%), pecans (27%), almonds (19%).

Allergens must also be listed using plain language; this means that manufacturers can’t just use the scientific name for a protein. Either they have to use the common name for the food or they have to put it in parentheses behind the scientific name.

For example: Casein (Milk)

Some countries also require an allergen summary statement after the ingredients list.

For example, after the ingredients list on a box of delicious triple chocolate chip biscuits, you might see: ‘Contains: wheat, milk, soya, oat’.

In the vast majority of countries, ingredients labels are the only type of label on food packages that are subject to legal requirements.

Not taking into account the fact that different countries have different legal requirements for ingredients labelling

In order to get to their list of priority allergens, most countries have looked to the Codex—short for Codex Alimentarius—which is a collection of internationally adopted food standards that are overseen by the Food and Agriculture Organization (FAO) and the World Health Organization (WHO). The Codex considers the following 8 foods to be priority allergens, because they have high prevalence rates and provoke a significant number of cross-reactions in many countries around the world:

• cereals containing gluten: wheat, rye, barley, oats, spelt or their hybridised strains
• crustaceans
• egg
• fish
• milk
• peanuts
• soy
• tree nuts

Many countries have modified the major allergen list to reflect local dietary habits and the prevalence of particular allergies within their populations.

So, for example, South Korea has the most demanding legislation that mandates labelling for 15 priority allergens; the ‘Big 8’ recommended by the Codex as well as buckwheat, molluscs (as a separate category from crustacean shellfish), beef, chicken, peach, pork, and tomato. The European Union has the next longest list of priority allergens; 14, including the Codex ‘Big 8’ plus celery, lupin, molluscs, mustard, sesame and sulphites. At the other end of the scale, the US has 9 priority allergens, namely the Codex ‘Big 8’ and sesame, and Japan has ‘only’ got 7; buckwheat, crab, eggs, milk, peanuts, shrimp and wheat.

Note that ‘milk’ and ‘egg’ do not mean the same thing in all countries. Although the category ‘milk’ in many countries refers to cow’s milk, in other countries—namely those in the EU as well as the UK, Turkey, Ukraine, the US, Brazil, Israel, Australia and New Zealand—‘milk’ refers to the milk produced by farmed mammals (e.g. cow, goat, sheep, buffalo). In Taiwan and South Africa, ‘milk’ refers to cow’s milk and goat’s milk and in Singapore it includes the milk of cows, buffaloes and goats. Similarly, in most countries, ‘egg’ refers to chicken egg, but in certain countries—namely those in the EU, the UK, Turkey, Ukraine, the US, Israel and South Korea—‘egg’ includes all farmed birds.

If you’re travelling with food allergies, find out what the priority allergens are in the country or countries that you’re going to. For allergen labelling requirements around the world, see the FARRP (Food Allergen Research and Resource Program) chart.

Thinking that a product with an allergen in the ingredients list poses more of a danger than one with PAL about that allergen

It certainly makes sense to think that a product with, for example, peanut in the ingredients list will be more hazardous than a product with PAL for peanut. After all, the former product should definitely contain peanut, whereas the product in the latter case may contain (traces of) peanut.

However, this reasoning is faulty because, in the end, what matters is the actual amount of allergen in the product rather than the probability that it’s in the product. Studies have shown that products with allergens listed as ingredients can contain low, very low or even no allergen, whereas products with PAL for a certain allergen (especially milk) can actually contain a lot of it.

A product with a PAL for a certain allergen can contain more of that allergen than a product which includes the allergen in the ingredients list (especially if it’s listed as a minor allergen, as some food producers do this instead of using PAL, see Thinking that PAL on a product means that a manufacturer is just protecting themselves later).

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Common mistakes made about precautionary allergen labelling

Precautionary allergen labelling (PAL) is intended to alert consumers to potential cross contamination happening at any point from the farm to the final food product sold in the shop.

PAL is only meant to be used for allergens that were not put in the food intentionally. It tends to be found on cereals, cereal products, confectionery and baking mixes and instant soup, where it’s often advertising the potential presence of tree nuts, peanuts, milk, gluten and egg.

Over the past few years, there has been a marked increase in the number and type of labels put on food packaging, with up to two thirds of the products on sale in some markets displaying some form of PAL. Along with this overabundance of caution comes a confusion of statements, with research from the US to Malaysia finding around 20 alternative phrases on the labels in their markets, and one analysis of markets in Latin America even finding 33 variations of a ‘May contain’ statement. On top of that, the wide variety of designs on food packaging that can make the PAL difficult to find and to read in the first place.

The same mishmash of allergen information is also available on retailers’ websites, meaning that the allergen information available online is not always the same as the information on the actual food packaging itself.

Adding to the unhelpfulness of it all, PAL, unlike the ingredients label, is not required to specify allergens within categories, so you generally won’t know if, for example, the nuts they are warning about in a food product are walnuts rather than any other type of nut, which severely limits the eating options of a person with nut allergies.

And if that wasn’t enough, some of the PAL warnings clash with the marketing labels also pasted on food packaging—what are you supposed to think when you’re confronted with a product that is labelled ‘Dairy free’ but also displays PAL for milk? Did someone put the wrong labels on it? Is this dairy-free product potentially hazardous for people with milk allergies? Are they warning about almond milk and saying that this product is potentially hazardous for people with nut allergies? Have you been wrong all these years in thinking that milk is a dairy product? Is the world going mad, or is it just you? And who has the time or the mental bandwidth to ponder these possibilities during their regular grocery shop anyway?

As a result of this scattershot approach, instead of helping people with food allergies, PAL labelling creates stress and uncertainty and leaves even health care professionals confused about how the labels are regulated and what they actually mean.

Here are some of the most common mistakes made about PAL.

Thinking that PAL is subject to law and more reliable than the ingredients list

One of the most common misconceptions about precautionary allergen labelling is that it’s required by law. A 2021 survey of food-allergic Saudis reported that only about half of them knew that PAL is neither required by law nor is it based on specific amounts of allergen present in the food, which the researchers attributed to the fact that new regulations around food allergens had only gone into effect in Saudi Arabia in 2019.

However, surveys of food-allergic Brits, Canadians and Americans also find that about 1 in 2 people are unaware that PAL is entirely voluntary and that there is no regulatory guidance for manufacturers regarding PAL at all, and those populations have had much longer to get used to food labels.

In fact, this lack of knowledge about PAL is repeated in every survey carried out around the world, and it inevitably means that many consumers trust PAL more than the ingredients labels and tend to ignore the ingredients label altogether, reading only the allergy advice (‘Contains’) box instead.

However, precautionary allergen labelling in most countries is completely voluntary and not as reliable as the ingredients label. With the exception of Switzerland, Argentina and South Africa (where the use of PAL requires strict risk assessment and lots of paperwork), as well as Japan (where ‘May contain’ labels are banned), PAL statements are not subject to any legal requirements and do not involve any type of standardisation. Companies can choose to use them or not to, in which case a food can contain traces of allergens that are simply not declared.

Many food safety experts are exploring how countries could impose regulation on precautionary allergen labelling. There are currently 2 methods under consideration.

One hinges on thresholds. A person’s threshold is the largest amount of their food trigger that they can eat before having an allergic reaction.

This is the motivation behind the Voluntary Incidental Trace Allergen Labelling (VITAL®) program, developed by the Allergen Bureau of Australia & New Zealand. Using large datasets containing the results of oral food challenges undertaken by food-allergic patients around the world, the VITAL team has calculated the dose of allergen that it would take to provoke symptoms in a certain proportion of people allergic to those foods.

The idea is that food producers can use these reference doses together with other data— the prevalence of an allergy in a certain population, average food consumption data, the likelihood and amount of allergen contamination during manufacturing—to calculate whether a food product probably contains more allergen than an agreed-upon threshold-based limit. If it does, they slap a precautionary allergen label with a standardised statement on that product.

In 2023, an expert committee convened by the U.N.’s Food and Agriculture Organization (FAO) and the World Health Organization (WHO) recommended that thresholds for PAL should be set at 5%, a recommendation that was adopted by Vital 4.0 in 2024.

These thresholds should protect 95 percent of an allergic population from having a reaction. This means that the most sensitive 5% of people with food allergies could still react to their traces of their trigger allergen in a food product. However, existing data shows that the vast majority of these people would not experience anaphylaxis. There are also no confirmed reports of fatalities as a result of allergen levels that fall below those thresholds.

Companies headquartered in several countries where PAL is not regulated—including France, the UK, the US, Canada, South Africa and Thailand—are voluntarily following the VITAL standard. In the Netherlands, a mandatory system based on these recommendations will go into force in 2026, and statements will be limited to ‘May contain xxx’ or ‘Not suitable for xxx’.

However, this scheme is not without its problems. For a start, most people don’t actually know what their own threshold dose is (something that will probably require a trip to an allergy specialist and an oral food challenge) and over half of the food-allergic (at least, in Canada) don’t know what a threshold is in the first place.

In addition, a person’s threshold is affected by whether there are any cofactors—things that may lower their threshold dose, like exercise or fatigue—involved when they eat their trigger food, and their reaction will also be affected by how much of the food they actually eat.

Furthermore, the processing and composition of the food product—the so-called food matrix—is also important. Research has shown that heating allergens can make them less (or more) likely to trigger reactions, and that the presence of, for example, wheat or fat in a food can affect how much of your trigger allergen you can eat before you have a reaction. In fact, these known properties of food allergens are used to good effect in the milk ladder and the egg ladder.

The second method that could be used to regulate PAL would involve using proteomic mass spectrometry to directly measure the amount of allergen in the food itself as it goes through the manufacturing process. However, the equipment needed to carry this out is costly, requires specialised expertise and is not, in its present form, quick enough to be used on food production lines.

The only food label that is governed by any type of regulation in the vast majority of countries is the ingredients label. The only countries that have laws governing PAL are Switzerland, Argentina, South Africa and Japan.

Thinking that the PAL wording actually means something

One consequence of believing that precautionary allergen statements are regulated is thinking that variations in the wording reflect a hierarchy of risk.

Studies from around the world—including the UK, the Netherlands, Serbia, Canada, the US, Australia and Lebanon—have revealed the widespread belief that a product with a ‘May contain peanuts’ label is more likely to actually contain peanuts than a product with a ‘May contain traces of peanuts’ label which, in turn, seems more likely to contain peanuts than a product with a ‘Manufactured in a facility that also processes peanuts’ label.

Labels like ‘Not suitable for people with nut allergies’ seem more authoritative than others like ‘Our packing house handles nuts and seeds’ because more concrete warnings are seen as indicating that there is some particular knowledge about the increased risk of the presence of allergens.

As such, people tend to prefer clearer, more specific information and are much more likely to avoid products with PAL statements like ‘Not suitable for…’ because it ‘not only provides information for the consumer but also makes the decision for them regarding the appropriateness of the product for consumption.’

Unfortunately, however logical that may seem, research has found no relationship between the risk of contamination and the type of PAL statement on a food product. For example, one study that examined the peanut content in foods with different PAL statements found contamination in 2 of 51 (4%) products with a ‘may contain’ label, 3 of 57 (5%) products with a ‘shared equipment’ label and 7 of 68 (10%) products with a ‘shared facility’ label. Levels of peanut residue in some products with a ‘shared facility’ label were up to 50 times bigger than those found in the products with the ‘may contain’ labels.

Similarly, another study that examined food products bearing advisory statements for milk also noted that the level of contamination varied widely per product and bore no relation to the PAL wording itself, with some products bearing ‘shared facility’ statements containing over 500 times more milk than equivalent products carrying a ‘may contain’ label.

The wording of a PAL statement is random and essentially meaningless.

Thinking that a product without PAL is automatically safer than one with

Another logical extension to thinking that PAL is regulated is believing that a product that does not bear a PAL statement is safe to eat. However, a product with no label represents 2 possible scenarios:

1. the producer has performed a risk assessment and has concluded that the risk posed by cross-contamination during the manufacturing process is negligible and the product is highly unlikely to contain enough of a priority allergen to provoke a reaction in people with food allergies
2. the producer has not performed a risk assessment and the product could contain enough unintended allergen to provoke a reaction in people with food allergies

A consumer currently has no way of knowing why a product has no label and, as several studies demonstrate, products without PAL are no safer than products with a warning.

For example, a 2011 study commissioned by the Food Safety Authority of Ireland (FSAI) examined 229 food samples for the presence of peanut, egg or soya and reported that 11 items out of 106 (11%) tested positive for undeclared allergens. By contrast, only 7 of the 108 (6.5%) products with precautionary allergen labelling actually contained any level of the allergenic ingredient mentioned on the label.

Likewise, a 2007 study that examined a wide range of biscuits and chocolates sourced from 10 European countries for the presence of peanut or hazelnut reported that peanut was detected in 25% of the biscuits with PAL and 11% of the biscuits without PAL, 40% of the chocolates with PAL and 25% of the chocolates without PAL. Hazelnut was detected in 32% of the biscuits with PAL and 25% of the biscuits without PAL, 77% of the chocolates with PAL and 53% of the chocolates without PAL.

That said, producers tend to be cautious when it comes to peanuts and are more likely to use PAL if they think a product might contain the intimidating legume. For example, a 2014 study commissioned by the British Food Standards Agency to examine a range of food products for the presence of unintended gluten, milk, hazelnut and peanut reported that, although gluten and milk were present in both products with and without PAL, and hazelnut was present in some products with PAL, peanut was present in only 2 (0.21%) of 950 products with PAL and no products without PAL.

Likewise, a 2010 study of 401 foods available in US supermarkets looking for traces of unintended egg, milk, or peanut found milk and egg residue in products both with and without PAL, but only found traces of peanut in 5 of 112 products with PAL and none without.

Milk is a much more problematic allergen. A 2017 study that examined dark chocolate bars on the US market noted milk as a frequent contaminant of bars both with PAL (67%) and without PAL (33%), some of which contained pretty high levels of milk. The study also found peanut residue in 8% of products with a peanut PAL and 17% of chocolates with no mention of peanut, demonstrating that you can never be too careful with chocolate if you are particularly sensitive to peanut.

The big problem with milk is that it’s often present in high enough levels to be troublesome. In the study of products from US supermarkets mentioned above, while the levels of egg that were detected were thought to be too low to cause any reactions in anyone with an egg allergy, the levels of milk detected in 7 of the 10 products with milk PAL and 3 of the 4 products that made no mention of milk were thought to be high enough to provoke reactions in people sensitive to milk.

Likewise, a 2010 study of pre-packaged foods carried out by Dutch researchers after a milk-allergic patient experienced a severe allergic reaction to some dark chocolate reported that ‘milk protein concentrations in unlabelled products reach levels that may elicit allergic reactions in up to 68% of the adult allergic consumers’.

A more recent Dutch study that followed 157 food-allergic adults for a year reported that, during the study period, 73 had accidental reactions that they were able to trace back to 51 pre-packaged food products. These were analysed and 1 to 4 culprit allergens that should not have been present according to the ingredients list were identified in 19 products. Of those, 9 had a PAL statement and 10 did not. Milk, peanut and hazelnut were detected most often, but concentrations (the measure that matters) of contaminant were greatest for peanut, milk and sesame.

Once again, milk was shown to be the most tricky contaminant, detected in 8 products, of which 3 had PAL and 5 of which made no mention of milk. Somewhat surprisingly, all of the products in which peanut (6) or egg (2) were detected did not have PAL statements. Products that did have a PAL statement for these allergens, however, did not actually contain any.

So, not only can a product without PAL contain undeclared allergen, it can also contain quite a lot of it. A 2024 study that examined 77 food products available to buy online in the UK for traces of milk and/or peanut reported that 24 of these products contained unintended allergen, 7 of which had no PAL. All of the latter contained levels of contaminant that were high enough to potentially provoke reactions among 1% of people with milk (5 products) or peanut (2 products) allergies, 2 of which (1 milk, 1 peanut) contained levels high enough to potentially cause reactions in 5% of people with milk or peanut allergy.

An earlier study of food available on the UK market looked at products that might pose a risk to milk-, wheat-, hazelnut- and peanut-allergic individuals and reported that the majority of the products that tested positive for an allergen contained enough of the allergen to cause a reaction in over 1% of the allergic population.

Bear in mind that milk, peanut and nuts are the allergens that researchers are most often looking for. Other (priority) allergens are probably just as likely to be contaminants in processed foods, it’s just that no-one has been looking for them.

Although many reactions due to accidental exposure are likely to be mild, some will not be—in the 2018 Dutch study mentioned previously, for example, most of the 151 reported reactions were mild or moderate, but 3 were classified as severe.

Likewise, a 2018 survey of 198 Australian doctors asking whether they had seen any patients in the previous 3 months who had experienced anaphylaxis after eating food which should not have contained their trigger allergen reported 14 cases of anaphylaxis to packaged foods, half of which did not have PAL.

The absence of PAL on a food product should not be taken to mean ‘allergen free’. Sometimes a product with no PAL will contain more allergen than one with PAL.

Thinking that PAL on a product means that a manufacturer is just protecting themselves

Food manufacturers don’t have it easy; food production is a complex process which creates many good reasons for using PAL. For a start, cross-contamination can be present right at the beginning of the process; global grain standards, for instance, allow for the presence of a small amount of different grain to be mixed in with the one ostensibly being bought.

Then, many companies make several different products, all of which can contain a combination of none, one or more different allergens, and many of which are made on production lines that involve a lot of different equipment. In a perfect world, a company would use a dedicated production line for each product, but this is generally neither economically nor practically viable. Unfortunately, cleaning protocols are limited by the resources they require, the downtime they impose and environmental as well as sanitary considerations; wet cleaning, one of the most effective means of removing allergens, is simply impossible on some production lines.

Manufacturers also have to deal with different priority allergens and paperwork requirements in different countries, incompatible computer systems, unreliable information from suppliers, changing recipes and different opinions as to what type of statement best fits the risk. As well as no official guidance on how much ‘trace’ of an allergen should be in a product before PAL is used, and no way of detecting allergens at very low levels anyway.

Finally, some (but not all) authorities adopt a zero-tolerance approach and consider that the presence of any detectable allergen in a food product without PAL infringes Food Safety Law. Leaving companies to find different ways to handle the uncertainty brought on by all the contrasting legislation.

Some producers have opted to keep the number of allergens in their factories to a minimum and only to work with suppliers who don’t use too many allergens, either. These producers think very carefully before changing recipes and adding new products to their brand and will often reject new ideas and partnerships with other companies, even if they sound tempting, because they want to retain control of their products and processes and don’t want to have to change their existing PAL procedure.

Some producers have opted to list (but not necessarily include) allergens in their recipes as minor ingredients so that they can follow clearer guidelines. Trying to determine the chances of an allergen accidentally ending up in your food product at some point during the manufacturing process is complicated. It’s more complicated still if you are selling your products globally and have to deal with different allergen laws in different countries. But it’s fairly straightforward to follow the rules for ingredients labeling, and minor ingredients are highly unlikely to be missed by people eating the food product.

Declaring an unintended allergen as a minor ingredient—listing it as one of the last three ingredients on the label—is a practise that seems to have started in the United States but can increasingly be seen in other countries. This explains why studies that have examined food products for priority allergens declared as minor have often discovered that, even though the allergen is on the list of ingredients, it’s not in the food.

So, for example, a 2007 study carried out in the US that looked for the presence of peanut in 21 products listing peanuts as a minor ingredient only found detectable levels of peanut in 7 of them. Similarly, a 2013 study examining 186 products on the American market found peanuts in just over a third (37.5%) of those listing peanut as a minor ingredient. That same year, a study carried out in Ireland reported that ‘No detectable levels of peanut were found in the products that indicated peanut/nuts as a minor ingredient.’ And in 2021, a study carried out in Canada found peanuts in only 3 of the 9 products in which peanuts were listed as a minor ingredient.

These results depend on the nature of the allergen; milk, which is a more difficult allergen to deal with when it comes to cross-contamination, is much more likely to be detected in a food which declares it as a minor allergen (though it still won’t be present in all products).

And some producers looking for a way out of this regulatory grey zone have adopted the liberal use of PAL. Some will use a PAL statement of some kind on most, if not all, of their products, and some will even use a blanket statement reporting every allergen they work with in their factories as possible contaminants of a food, even when there is no chance of cross contamination because the allergens are only used on another line—legally-speaking, it’s better to be safe than sorry.

So it’s not surprising that some people—one third of the food-allergic recently surveyed in Canada—don’t think that a food with a PAL statement contains the allergen it’s referring to and have understandably concluded that PAL is used as a ‘backside-covering exercise’ to enable producers to avoid liability rather than to provide useful information for customers.

But PAL warnings are not all empty threats. In one of many examples, an American study that reported that fewer people were paying attention to advisory labelling over the years found that 1 in 10 of the food products that it examined for the presence of peanuts mentioned on the PAL actually did contain peanut residue, and in widely varying concentrations. While the amounts detected would probably not affect the majority of people with peanut allergies, they could if a person ate more than the recommended serving size which, let’s face it, many of us do.

The problem with taking a chance and ignoring PAL is that you can never be sure whether a product will actually contain enough of your trigger food to prompt an allergic reaction.

Thinking that if a product with PAL doesn’t provoke a reaction once, a) it will never cause a reaction and/or b) you can actually handle traces of that allergen

Around 1 in 2 people with food allergies are apparently prepared to ignore precautionary allergen labelling on a product if they have eaten it before without experiencing a reaction. This is even more likely to happen if the food is made by a trusted brand or bought in a trusted supermarket.

Because PAL is there to warn you about potential ‘traces’ of food allergens, it seems logical assume that, if you have eaten a product with PAL concerning your trigger food without reacting, either a) the brand is so careful with its manufacturing processes that it will always produce a product that is safe for you to eat, and/or b) the product did contain traces of your trigger allergen but you can handle a tiny amount of it after all.

However, this is not a safe assumption.

For a start, allergen residue is not necessarily uniformly distributed through a food product. Allergen contamination in food can take 2 forms; particulate and non-particulate. Non-particulate contamination comes from allergens that are in liquid or powdered form, like milk. These are more likely to be distributed relatively uniformly throughout a food. This means that, when you eat some contaminated food like, for example, a chocolate bar, you are likely to get some of the allergen in every bite.

Non-particulate allergens like nuts, however, tend to clump and will therefore not be distributed evenly in a food. Instead, a contaminated chocolate bar, for example, might only contain one bit of nut at one end, or it may be the case that, out of a whole batch of chocolate bars, 3 are contaminated with widely differing amounts of nuts, whereas 37 don’t have any nut in them at all. You may have just got lucky when you bought your chocolate bar with the PAL for nuts.

This helps to explain why researchers have found that products with PAL for milk are more likely to contain milk than products with PAL for peanuts, which are actually often free of peanut contamination (this is also because peanuts have a reputation for producing severe reactions and producers are therefore more likely to slap PAL on a product warning about peanuts even if the likelihood of the infernal legume getting in there is actually minuscule).

And there are other factors that can impact whether or not you will react to a food product, including:

• a change in the product recipe
• a change in the manufacturing process which increases the chance of cross-contamination
• the involvement of cofactors
• whether your meal includes foods containing histamine liberators

Just because you didn’t react to a certain food product once does not mean that you won’t react to the same product when you buy and eat it again.

Thinking that something that doesn’t contain ‘nuts’ doesn’t contain peanuts

Peanuts are not in the same botanical family as nuts like almonds, hazelnuts, pecans and walnuts. Peanuts are legumes, and part of the Fabaceae or Leguminosae family, commonly known as the legume, pea or bean family. Almonds, hazelnuts, pecans and walnuts are grouped under the ‘tree nut’ umbrella, which is actually comprised of several different botanical families; Rosaceae (almonds and hazelnuts) and Juglandaceae (pecans and walnuts) in this particular example.

Peanuts are often unofficially grouped with nuts because they have the same kind of nutritional profile and provoke the same kinds of allergic reactions. But,officially, they must be mentioned separately on ingredients lists and, while PAL statements are generally unregulated, it’s unlikely that producers are including peanuts in statements that mention ‘nuts’. It’s certainly not worth taking the chance; that mistake has cost at least one person her life (according to page 13 of this book, which you can no longer view online, so you’ll have to take my word for it).

Read the ingredients list on a product to be sure that it doesn’t contain peanuts.

Image by Photoroyalty on Freepik

Common mistakes made about marketing labels

Marketing labels are added to products to make them more appealing to certain segments of the market.

Thinking that labels that advertise foods as ‘free from’ are regulated and contain none of the relevant allergen

‘Free from’ is often taken to mean that whatever allergen the product is supposedly free from is either completely absent or, at the very least, undetectable, but this is not the case. There is no legislation governing the use of terms like ‘Lactose free’, ‘Dairy free’ or ‘Peanut free’. In most countries, as far as the law is concerned, these types of labels are considered marketing statements and exist in regulatory grey zones.

Legislation has been implemented in a piecemeal fashion across and within countries. Countries in Europe have all got slightly different regulations. For example, in the case of lactose, at the European Union level, EU legislation (Regulation No. 2016/127) covers the use of the claim ‘lactose-free’ only when it comes to infant and follow-on formula, specifying that it must contain no more than 10 mg of lactose per 100 Kcal. The Republic of Ireland expects products with ‘free from lactose’ labels to contain no detectable amount of lactose. Germany, Slovenia and Hungary set a level of 1000 parts per million (ppm) (or 0.1%) lactose in products claiming to be ‘Lactose free’. Scandinavian countries (Denmark, Finland, Sweden, Norway) and Spain allow 100 ppm (or 0.01%) lactose in these products. Spain and Ireland also allow products to be labelled ‘low lactose’ if they contain 10,000 ppm (or 1%) lactose.

In the UK, there is no specific quantification attached to ‘free from’ labels, they are simply required not to be misleading. A company must implement rigorous controls to ensure that the final food product is free of whatever allergen they are claiming that their product is free from, including doing its best to ensure that cross-contamination from other foods made on site is prevented and checking that the ingredients and packing materials do not contain the allergen.

It’s the same in the US, where products can also be labelled ‘lactose reduced’ if they contain 70% less lactose than a regular product would.

Somewhat ironically, the one exception to the lack of regulation among ‘free from’ labels is the ‘Gluten free’ label, butt his regulation specifically allows a certain amount of gluten to be present in the food; 20 milligrams per kilo of gluten, to be precise, which can also be described as 20 parts per million (ppm), or 0.002%.

This is the rule in the EU, the UK, Canada, the US, Australia, New Zealand and any country that implements Codex standards. European legislation (Regulation No. 828/2014) also allows products to be labelled as ’very low gluten’ if they contain no more than 100 mg/kg (100 ppm) of gluten.

This means that products that are labelled ‘gluten free’ may still pose a risk for a small proportion of people with coeliac disease, as individual sensitivity to gluten varies and some people only need to eat as little as 10 mg of gluten a day to provoke inflammation in their guts.

And then there’s always the risk of accidental contamination, which has been reported to affect around 1 in 10 products in countries like Italy and India, and almost 2 in 10 products in countries like Turkey and Mexico. Certain markets, like the US, report much lower levels of contamination (about 1 in 100 products).

In the European Union, 5.9% of the recalls made during the period of January 2018 to January 2022 were of products labelled ‘gluten free’, three quarters of which were due to the presence of gluten and the rest to other allergens (e.g. milk, nuts) in the food. In total, 7.6% of all the food product recalls in the EU were of undeclared allergens in ‘free from’ products.

Because companies know that mistakes can be made, it’s not unusual to find food products which display both a ‘free from’ label and PAL for the allergen the product is intended to be free from, like a supposedly ‘Dairy free’ bar of chocolate with PAL for milk.

Again, different countries have different legislation governing this situation. In Germany, for example, food products with ‘free from’ labels are prohibited from also displaying PAL for the same allergen, which is why you won’t find that many food products claiming to be ‘free from’ anything there.

Ultimately, seeing a ‘Free from’ label on a product does not replace the need to to look for a PAL statement or to read the ingredients list. However, research suggests that products that are labelled as having been made in a dedicated facility or on a dedicated production line should be safe to eat.

Thinking that a food labelled ‘Gluten free’ is suitable for a person with wheat allergy

There are 2 problems with this. For a start, products that are labelled ‘gluten free’ can still contain very low levels of gluten which could theoretically still trouble a small number of people with wheat allergy. If, for example, a person eats a 200 g serving of gluten-free food containing the maximum amount that is legally allowed (20 ppm gluten), they would be eating around 5.5 mg of total wheat protein, something that has been calculated to cause an objective reaction in 2–6% of the wheat-allergic (and could cause mild subjective symptoms in 10–15% of them).

And then there’s the fact that food producers have found a way to wash most of the gluten protein out of wheat so that the levels come in under the <20 ppm threshold, enabling them to label their products as ‘gluten free’ while still using the wheat starch that’s left behind to thicken or bind the food.

Unfortunately, gluten—a major protein complex principally made up of two types of wheat protein, namely gliadins and glutenins—makes up about 75 to 85% of the total protein content in wheat, but not the whole protein content. Wheat starch contains low levels of other types of wheat protein such as albumins, globulins and amylase/trypsin inhibitors, all of which are known to cause reactions in some people with wheat allergy. Therefore, a product that is labelled ‘gluten free’ can still contain cause allergic reactions in people with wheat allergy who are allergic to those wheat proteins.

If a product does contain wheat starch, wheat will still have to be mentioned in the ingredients list in many countries, and the product may also display PAL for wheat, so check the product labelling carefully if you are allergic to wheat.

Conversely, products that are labelled as ‘wheat-free’ can still contain gluten from other grains, notably rye and barley, so people with coeliac disease must also check ingredients labels on these food products to be sure that they can eat them.

People who are allergic to wheat should always read the ingredients list and look for PAL on products labelled ‘Gluten free’.

Thinking that a food labelled ‘Dairy free’, ‘Non-dairy’ or ‘Lactose free’ is suitable for a person with milk allergy

There are several problems with this belief.

In the US, ‘Dairy free’ and ‘Non-dairy’ do not mean the same thing. As we have already seen at the beginning of this section, the term ‘Dairy free’ is unregulated, so you can never be sure that the product does, indeed, contain no dairy. The term ‘Non-dairy’ is regulated, but the FDA allows ‘non-dairy’ products to contain up to 0.5% milk protein in the form of casein or caseinates. The term is actually a result of the dairy lobby wanting to make sure that vegan milk and cream products could not be called ‘dairy’. The casein has to be declared on the ingredients label, though, so always check there before buying something.

Lactose is a type of sugar found in milk. People with lactose intolerance cannot digest milk properly because they are missing the enzyme lactase and cannot break down the lactose in milk. This can cause symptoms like bloating, gas and diarrhoea. Lactose-free products have had the lactose sugar removed so that people with lactose intolerance can still eat (or drink) them. However, lactose-free products still contain milk protein and will still cause reactions in people with milk allergy.

Finally, milk is one of the most difficult allergens to avoid putting into food by accident, so contamination is also possible in products that have been labelled as dairy-free. For example, a 2017 study that examined dark chocolate bars available on the US market found that 15% of the bars labelled ‘Dairy free’ were positive for milk, and some had pretty high concentrations of milk protein. Some of the products had PAL for milk and were indeed more likely to contain milk, but milk was also found in the chocolates without PAL statements.

People who are allergic to milk should always read the ingredients list and look for PAL on products labelled ‘Dairy free’, ‘Non-dairy’ or ‘Lactose free’.

Thinking that a food labelled ‘Vegan’ contains no animal products

Like ‘Free from’ products, the ‘Vegan’ claim is not covered by food law, so a food labelled ‘Vegan’ can still contain animal-derived products, notably milk.

A study of the product recalls occurring in the European Union during a 4-year period revealed that products that were marked as ‘Veggie’, ‘Vegetarian’ or ‘Vegan’ represented 4.4% of the total recall notifications. Of these products, around two thirds (64.9%) contained undeclared allergens of animal origin (56.8% milk and 16.2% egg), and the rest contained non-animal-related allergens (mustard, nuts, soy, celery, gluten, and peanuts).

In the UK, a 2023 study reported that just over a third (39%) of foods labelled ‘Vegan’ actually contained egg or dairy, including 13 dairy alternatives and 48 meat alternatives. In 2022, one death was reported after a woman with milk allergy ate a vegan wrap which contained yoghurt with detectable traces of milk protein.

In Canada, a 2023 study into ‘Vegan’ food detected milk in a supermarket cake and several dark chocolate bars (although no egg was detected in any of the foods sampled). Keeping milk out of dark chocolate bars seems to be the biggest challenge for food producers, with a 2017 study of chocolate on the US market finding that 25% of the bars that were labelled ‘Vegan’ were positive for milk, including bars with and without PAL.

People who are allergic to milk or eggs should always read the ingredients list and look for PAL on products labelled ‘Vegan’.

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The problem with not reading labels

Given the abundance of precautionary allergen labels with their medley of meaningless statements, it’s not surprising that a lot of people are suffering from ‘warning fatigue’. Surveys from Serbia to Canada have found that only around 1 in 2 people always read food labels, a number that gets smaller each year, although the population of some countries, like Saudi Arabia (where labelling is still relatively new), Ireland and the US are more careful than others like Australia and the UK, and people are more likely to read labels on products that are new to them.

Surveys of the food allergic have thrown up plenty of seemingly good reasons for ignoring labels, like the fact that if people with nuts allergies avoided all products with PAL for nuts, they would find it difficult to eat anything at all. Additionally, it’s difficult to trust companies that put labels on most of their products, especially when those labels seem strangely out of place.

And we all make mistakes. Sometimes we don’t expect a food product to contain a certain allergen, so we don’t look for it, sometimes we are hungry and in a rush, sometimes we’ve had the product before and been fine, sometimes we just like a certain product so much that we are prepared to take a chance on it, sometimes the product is on sale which makes it look tastier, and sometimes we just can’t read the label in the first place.

Unfortunately, despite all of the existing legislation and the precautions taken by food producers, every year, about 1 in 2 people with food allergies still suffer from reactions to food that they have bought and eaten.

Canadian research has found that just under half of the food-allergic experience an allergic reaction after eating a pre-packaged product, with over 1 in 4 admitting to not having read the label on the package and around 1 in 14 to having ignored the PAL. A Lebanese study reported similar figures, with just over half of the people surveyed having experienced an allergic reaction to a food product, and just over 1 in 4 admitting to ignoring the labelling and around 1 in 6 to ignoring the PAL.

Luckily, many of these reactions are mild. For example, a survey of 100 Swiss children allergic to peanut, tree nuts, sesame, soy, wheat, egg, and/or milk who regularly consumed foods with PAL reported that around 1 in 5 had had a reaction to a food with PAL (often chocolates, cookies and cakes), all of which were mild (skin and/or digestive symptoms).

However, some people still run a risk of experiencing severe reactions, including anaphylaxis to traces of allergen in a food.

A Dutch study which followed 157 food-allergic adults for a year reported that 73 experienced a total of 153 reactions after accidental exposure to their food trigger(s) in a pre-packaged product; of those reactions, just under a quarter (22%) were classified as mild, half (50%) as moderate and just over a quarter (28%) as severe (about a fifth of which involved cardiovascular symptoms).

On very rare occasions, a reaction can be fatal. To date, there have been 2 reports from the US where 2 people have apparently died after eating a product with PAL; one from cake and the other from a snack bar, whose PAL for peanut was ignored because ‘Nearly every chocolate bar you buy has the peanut warning on it.’

That said, while caution is required, there is certainly no reason to panic. Given the fact that pre-packaged foods with PAL are frequently eaten by people with allergies, there are remarkably few reports of significant allergic reactions to pre-packaged foods due to unintentional cross-contamination.

Aside from certain high-risk products (see Top tips for avoiding accidental reactions next), extensive reviews of studies and oral food challenges have concluded that exposure to traces of allergen (<5 mg protein) in pre-packaged products is unlikely to cause anything other than mild allergic symptoms in the vast majority of people with food allergies. This applies to people who are allergic to hazardous food allergens like peanuts and those with severe food allergies.

The fact is, companies spend a lot of money on allergen control plans to try to minimise the risk of cross-contamination during food production. These plans typically include buying specialised equipment, paying for employee training and setting up procedures for the safe storage and handling of raw materials and the cleaning of equipment on production lines. Because it’s cheaper than spending money on product recalls which typically average around $10 million and reach up to $100 million. Not to mention the bad publicity.

However, if you have food allergies, buying a pre-packaged food product will never be without risk. Even if you put aside human error and cases of accidental cross-contamination, existing limitations in technology and allergy knowledge mean that, even when producers use PAL correctly, a very small number of the food-allergic cannot be totally protected from the possibility of having an allergic reaction.

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Top tips for avoiding accidental reactions

Read the ingredients list

The ingredients list is the only food label that is required by law to disclose priority allergens that have been intentionally added to the food.

Read the ingredients label of a product even if you have eaten it before safely. A food product’s recipe and/or its manufacturing process can change at any time without warning. Watch out for packaging changes and/or labels saying things like ‘New recipe’, ‘More protein’, ‘New allergen advice, see the back of pack’ which could indicate a change in ingredients.

Familiarise yourself with alternative names for your food allergen; components of an allergen like milk, for example—such as ‘casein’, ‘lactose’, ‘whey’—can be used to improve the texture and structure or nutritional profile of a food. Although many countries require manufacturers to use plain English when describing ingredients, this may not be be the case for every country you travel to, and mistakes do occur, with some labels listing ingredients like ‘whey proteins’ or ‘milk protein isolate’ instead of ‘milk’.

Give yourself enough time to shop for your groceries so that you can read the food labels properly. Read the ingredient lists carefully from start to finish. Not all countries require food companies to make allergens stand out by e.g. bolding or italicising the print.

Familiarise yourself with the labelling laws of countries that you are travelling to; for example, if you have an allergy to squid, some countries—members of the European Union, Canada, Australia and New Zealand—consider molluscs priority allergens and require them to be emphasised in the ingredients list, but other countries like the US, Japan and South Korea only consider (certain) crustaceans to be priority allergens. Their definition of ‘shellfish’ will not cover you.

If you are especially sensitive to your food trigger, read the PAL

Some people have what doctors term ‘exquisite allergy’ to their trigger food and they can react very badly to tiny amounts of allergen.

Doctors generally advise people to avoid foods with PAL concerning their trigger allergen if;

• they also have asthma
• they have previously experienced anaphylaxis
• they have previously reacted to a tiny amount of their trigger allergen

PAL statements often appear near the ingredient list, but not always. Check the entire package for a ‘May contain’ statement or one of its many alternatives.

If you have any doubt about a food product or its label, you may not want to risk it. Research from the UK has revealed that over half (56%) of people with allergies have had a reaction to pre-packaged food after not understanding the labelling on packaging.

However, if you really want to try the food, you should be able to reach out to the manufacturer. Manufacturers’ websites often include additional allergen information about their food products or contact details so that you can get in touch and ask them directly. Sometimes, store personnel may be able to help you.

If you decide to buy the food, you may want to avoid eating it in a ‘high risk’ environment— e.g. a remote location without access to emergency services—and make sure you have your rescue medication handy, just in case.

Pay special attention if you are allergic to milk, gluten or (pea)nuts

A 2021 study of global food recalls identified milk, gluten and peanut as the allergens most likely to be involved in cases of cross-contamination, primarily because of the physical nature of the allergen in the food; gluten in the form of flour and milk powder tend to spread easily throughout products. Milk powder, being a concentrated form of milk (i.e. milk without water content) also contains 8 to 10 times more protein than liquid milk, making it a particularly likely to cause reactions in low quantities.

Milk has been reported as the most problematic food allergen in processed foods in a variety of countries including the UK, the Netherlands, the US and Canada, where researchers have noted its tendency to be added by accident to more food products than other allergens, and in relatively high concentrations, thus posing a relatively high risk to people who react to small amounts of milk in food.

In one study, American researchers analysed a variety of foods—a whole wheat roll, some tofu chocolate cheesecake, a soy coffee drink, baker’s icing, an apple-flavoured energy bar, dark chocolate, organic dark chocolate and a dairy-free chocolate cupcake—suspected of causing allergic reactions in eight milk-sensitive individuals and found between 5,500 to 44,500 ppm (0.55% to 4.45%) of undeclared milk protein (casein).

Peanut paste poses a challenge when it comes to cleaning equipment on shared lines, and the removal of clumps of nuts is also difficult. Because (pea)nuts tend to be unevenly distributed in foods, you can get quite a high concentration in one mouthful.

Although some experts believe that non-snack food items with peanut PAL may be relatively safe for people with milder forms of allergy because they are less likely to contain unintended allergen than snack food items, it pays to remember that, if you’re unlucky enough to have a bite of a food that contains a clump of peanuts, your reaction could be severe, and some experts recommend staying away from any food with a peanut PAL.

Pay special attention to certain food categories

Studies that have examine the presence of undeclared and unintended priority allergens in pre-packaged foods, both with and without PAL, have found that the most hazardous food categories are bakery and cereal products—notably muesli/trail bars—ready meals and snacks, including chocolates, biscuits/cookies, confectionery and ice cream. Meat products have also been reported as causing accidental allergic reactions relatively frequently among the food-allergic.

Dark chocolate has been shown to be a particularly ‘high risk’ food for people with milk allergies by several studies. Milk and dark chocolate are often made on the same production lines and, because milk is added early in the manufacturing process for milk chocolate, several major pieces of equipment are contaminated with milk. This equipment is not easy to clean; the most efficient type of cleaning involves water, but since chocolate products have been implicated in Salmonella outbreaks in the past, most chocolate manufacturers do not use water to clean their equipment.

Another food category that you might not suspect as being risky for the milk-allergic is meat products, including beef and pork pâtés flagged by a team in Italy and edible insects identified as a potentially risk food by a team in the Netherlands.

People who are allergic to peanuts and nuts should be especially wary of confectionery, cereal and nutrition bars, and the experienced nut-allergic also tend to be cautious about buying baked goods, ready meals and desserts. Remember that peanuts are not nuts, but they do often accidentally end up in nut mixes, as well as nut and seed products.

Be more wary of food produced by smaller food companies

Small companies have fewer resources than larger ones, so they tend to use shared equipment more often, and removing allergen residues from this equipment is generally difficult and time-consuming. Research from the US has noted that small facilities tend to lag behind larger ones when it comes to implementing allergen controls and they are also more likely to use PAL on their products.

A study that investigated foods products on the US market with PAL for milk noted that, although the difference was not statistically significant, the products that actually did contain milk were more likely to be manufactured by smaller companies than larger ones (48.9% versus 31.6% of the products, respectively).

Another study that compared products from large and small manufacturers found that milk, egg and peanut was more likely to be found in products from small versus large manufacturers (5.1% of all the products versus 0.75%, respectively), whether those were products with PAL or products that contained undeclared traces of allergens, although only milk reached statistical significance. The authors of the study conclude:

‘Our study underscores the need for allergic consumers to avoid advisory-labeled products, which present a small but real risk, and to have some concern for products without advisory labeling, particularly from small companies, especially within categories of higher-risk products.’

Sign up for allergy alerts

Undeclared allergens have been identified as the most common cause of food product recalls globally, with mislabelling, new recipes without a corresponding change in labelling, cross contamination from food processing equipment and human error all contributing to the problem. Most of these recalls involved milk, gluten and multiple allergens present in one food, with baked goods, confectionery and dried goods making up the most commonly associated food product categories, as well as ready meals and ‘mixed products’ (like frozen veggie burgers), soups, broths and sauces/condiments.

What these foods have in common is a lot of different ingredients and a high degree of processing.

In Europe, around 100 alerts are reportedly issued each year through the Rapid Alert System for Food and Feed (RASFF) and around 70 food recalls related to allergenic foods occur annually in the US, where around 1 in 6 recalls (involving milk, eggs, tree nuts and wheat) are said to be associated with ‘adverse health consequences’, 1 in 10 of which are reported to be anaphylaxis.

Although industry and allergy organisations are working together to reduce the number of recalls, accidents still happen. Luckily, you can sign up with various agencies to receive email alerts about food allergy recalls.

For European-based alerts, you can search the EU’s Rapid Alert System for Food and Feed (RASFF) portal here. The RASFF system database was created by the European Commission to keep track of food recalls and public health warnings in all European Union countries, as well as Iceland, Norway, Liechtenstein and Switzerland. As of January 2021 the RASFF stopped reporting notifications from the United Kingdom since it was no longer part of the EU.

People in the UK can read news and alerts on the UK’s Food Standards Agency (FSA) website and sign up for email or text alerts here. You can also sign up for email alerts about food recalls Allergy UK here.

People in Canada can sign up with Food Allergy Canada for food recalls and food allergy news, as well as opportunities to participate in food-allergy related research here.

People in the US can get information about food recalls from FoodSafety.gov and the Food and Drug Administration (FDA) and sign up for FDA email alerts here.

The US Department of Agriculture’s Food Safety and Inspection Service (FSIS) also provides alerts specifically for meat, poultry and egg products, which you can read about here.

Other sources for recall alerts include Food Allergy Research and Education (FARE) and Kids With Food Allergies.

People in Australia can sign up for alert emails courtesy of Allergy & Anaphylaxis Australia (A&AA) here.

People in New Zealand can get advice from Allergy New Zealand and sign up for email alerts for food recalls from the Ministry for Primary Industries (MPI) here.

Of course, there’s also an app for that.

The food allergic in Europe can try RecallFood (for Android), which provides real-time notifications about food recalls in Italy, Spain, the Netherlands, Germany, France and other European countries. Includes details about recalls, such as the reasons for the recall and the affected batches.

The food allergic in the US have more choice, including:

• MAE (Making Allergies Easy) (for Android) provides recall notifications based on your specific allergies as well as allowing you to scan ingredient labels for allergens and track your reactions
• Allergy Force (for Android and iPhone) provides alerts about food recalls and contamination alerts from the Food and Drug Administration & Kids with Food Allergies, as well as other features including a barcode scanner to check for allergens, medications reminders and tools for communicating your allergies to restaurants in 21 languages. It also has a premium option for several additional features
• Food Recalls & Alerts (for Android and iPhone) aggregates FDA, USDA and pet food recalls
• Recall Pal (for iPhone) offers alerts for food, drugs and appliances recalls. It also has a feature allowing users to earn cash by submitting complaints and reporting defective products

My Recalls (for Android): Provides notifications about the latest recalls for food and health products, cars and consumer goods for people in Canada, Australia, USA, Brazil and Nigeria.

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