Implementing Threshold-Based Precautionary Allergen Labelling in the UK Food Industry

Precautionary allergen labelling (PAL) is a key component of food safety, designed to inform consumers of potential allergen cross-contact in food products. However, inconsistent and overused PAL practices have diminished its effectiveness, causing confusion among consumers, especially those with food allergies. A study published in Heliyon investigates the impact of adopting a threshold-based approach to PAL, which could standardise labelling practices and better protect allergic individuals. This article explores the findings of the study and discusses the implications for food businesses.

Current Challenges with Precautionary Allergen Labelling

The study highlights that the current use of PAL is often inconsistent and can lead to consumer confusion. In Canada, where the study was conducted, it was found that PAL is applied to many products where the risk of allergen exposure is minimal. For example, products like dark chocolate frequently carry PAL for milk, yet the actual risk of cross-contact varies greatly. The overuse of PAL has led to a situation where nearly half of all food products in certain categories carry these warnings, limiting choices for consumers with food allergies and leading some to disregard PAL altogether, potentially increasing their risk of an allergic reaction.

The Concept of Threshold-Based Labelling

The study proposes a threshold-based approach to PAL, where labels are applied only when the concentration of allergens exceeds a level that poses a significant risk. These thresholds are based on eliciting doses (EDs) such as ED01 and ED05, which represent the amount of allergen that would trigger a reaction in 1% and 5% of allergic individuals, respectively. By implementing such a system, food businesses could reduce the overuse of PAL, making it a more reliable indicator of risk.

The study used Monte Carlo simulations to assess the impact of this approach. The results showed that applying PAL based on ED01 or ED05 could significantly reduce the number of allergic reactions caused by products without PAL. For instance, the study found that using ED01 thresholds would lead to fewer than 15 allergic reactions per 10,000 eating occasions across all product categories studied, a significant reduction compared to current practices.

Implications for Food Businesses

For food manufacturers, adopting a threshold-based approach to PAL offers several advantages. It provides a clear, science-based standard for when PAL should be applied, reducing the guesswork and potential overuse. This can help rebuild consumer trust in allergen labelling, as the presence of PAL on a product would more accurately reflect a real risk of allergen exposure.

Additionally, this approach could expand the range of products available to consumers with food allergies. Currently, the overuse of PAL limits the choices available to these consumers, as they may avoid products with any PAL warning. By reserving PAL for products where the allergen concentration exceeds a safe threshold, businesses could offer more options without compromising safety.

However, implementing this system would require investment in accurate allergen testing and monitoring processes. Food businesses would need to ensure that they can reliably measure allergen concentrations to apply PAL appropriately. Despite the upfront costs, the long-term benefits include fewer product recalls, enhanced brand reputation, and potentially greater consumer loyalty.

Consumer Education and Safety

A critical component of successfully implementing threshold-based PAL is consumer education. Consumers, especially those with food allergies, need to understand what these thresholds mean and how they can trust the labels. The study suggests that in regions where threshold-based PAL has been implemented, such as Switzerland and the Netherlands, consumer education has played a vital role in ensuring the effectiveness of the system.

In these countries, clear communication from both regulatory bodies and food manufacturers about the meaning of PAL and the safety of products has been essential. By following similar practices, UK food businesses could ensure that consumers with food allergies can make informed decisions without unnecessary restrictions on their diet.

Challenges and Considerations

Despite the potential benefits, there are challenges to implementing a threshold-based PAL system. One significant challenge is the variability in individual allergic responses. While thresholds like ED01 and ED05 are designed to protect the vast majority of allergic individuals, there will always be outliers who are more sensitive. Ensuring that these individuals are adequately protected remains a concern.

Moreover, the study highlights the importance of regulatory alignment across different markets. For UK food businesses, particularly those that export products, understanding and complying with varying international PAL regulations will be crucial. The success of a threshold-based approach depends on consistent application and understanding across borders.

Conclusion

The threshold-based approach to precautionary allergen labelling represents a promising advancement in food safety, particularly for the UK food industry. By adopting scientifically determined allergen thresholds, food businesses can provide clearer and more reliable information to consumers, ultimately improving safety for those with food allergies while expanding the range of safe products available. However, successful implementation will require robust allergen control measures, significant consumer education efforts, and careful consideration of the unique challenges this approach presents.

As the industry moves towards more standardised and evidence-based allergen labelling practices, businesses that embrace these changes will likely see benefits in consumer trust and market opportunities, all while playing a crucial role in protecting public health.

References

Lizée, K., Dominguez, S., Théolier, J., La Vieille, S., & Godefroy, S. B. (2024). Simulated use of thresholds for precautionary allergen labeling: Impact on prevalence and risk. Heliyon, 10, e33316. Available online at Heliyon.