Food Allergies and PALs, Codex Alimentarius


Food allergies and PAL,Protect A Life from food allergies. But also ‘Precautionary Allergen Labeling. The 22 associations representing allergy patients in different areas of the globe are calling on Codex Alimentarius to adopt uniform guidelines worldwide.

Food allergies, a global threat

The ‘
World Allergy Organization
‘ estimates 240-550 million individuals with food allergies. The prevalence of which is increasing globally and has significant impact on quality of life. Where, to date, there is no cure.

It is a matter of life and death, since in the most severe cases, the intake of a minute amount of the substance to which the individual is allergic is enough to trigger an immune reaction with even lethal outcome. And it is still underestimated even by Big Food. (1)

Precautionary Allergen Labeling,
the critical issues

Precautionary information

about the possible presence of allergens in pre-packaged, pre-wrapped and bulk food products is now a serious critical issue for

food safety


The Journal of allergy

and clinical immunology’

has indeed published a recent study (2) where they identify as the primary causes of accidental allergic reactions both factors of:

– labels lacking appropriate indications about the possible presence of allergenic ingredients,

– Defect of consideration by allergic patients of precautionary indications. (3)

Confusion of label news is the first cause of criticality. Uncertainty reigns supreme:

– in the concepts, whenever reference is made to indefinite ‘traces or to production conditions unavoidably unknown to the consumer (e.g. ‘produced in a plant where they also process/are present…).

– in the contents. Where the identity of individual allergenic ingredients is masked behind generic, banned claims, such as ‘cereals containing gluten‘ e ‘nuts in shell‘.

A second critical issue is due to inadequate self-control by operators participating in the food chain. Who, it should be remembered, have precise responsibilities In terms of the application of good hygiene practices and HACCP.

The operator responsible

of consumer information

, in turn, must decide whether to include correct precautionary information only as a result of a thorough analysis of the risk of contamination of the food product with one or more of the individual proteins covered by the mandatory claim. (4)

The correct precautionary information – ‘Contains‘ or ‘May contain…’, followed by the specific name of the individual allergens that could remain in the food, due to cross-contamination – must therefore be displayed, in the margin of the ingredient list, in equally visible (in terms of height and graphics) characters.

associations’ requests to the
Codex Alimentarius

Food Allergy Italia and 18 other organizations representing allergic consumers in various parts of the world – EU, USA, Brazil, Hong Kong, Japan – entrusted Codex Alimentarius with their shared and unwavering demands in a letter 7.11.18.

International Food Allergy
& Anaphylaxis Alliance’) has written to the Working Group engaged in drafting the Code of Practice for Food Business Operators (‘Draft Code of Practice for Food Business Operators‘). To expose the problems and call for the adoption of appropriate Guidelines.

The management of food allergens and their labeling, with particular regard to PAL (‘Precautionary Allergen Labeling‘), must come based on risk analysis. To enable allergic consumers to make safe and informed food choices. It is therefore necessary:

revise risk assessment criteria, which should include a quantitative approach (with the potential development of reference doses),

Apply these criteria in the guidelines addressed to practitioners. For appropriate risk communication, throughout the food supply chain (B2B) and to consumers,

establish a guideline addressed to FAO/WHO member state legislators to harmonize allergen labeling rules, including PAL declarations (still voluntary in most countries).

Dario Dongo


(1) See previous investigations on Nestlé,


, Lindt

(2) Blom, Wendy A M, Anouska D Michelsen-Huisman, Harmieke van Os-Medendorp, Gert J van Duijn, Mary-Lène de Zeeuw- Brouwer, Astrid Versluis, Jacqueline J M Castenmiller, Hubert P J M Noteborn, Astrid G Kruizinga, André Knulst and Geert Houben. ”Accidental food allergy reactions: Products and undeclared ingredients.’ The Journal of allergy and clinical immunology 142 3 (2018): 865-875

(3) An earlier study, published in Allergy in 2016, helps to understand the interconnection between the two phenomena. In the sense that, in the absence of uniform criteria on the precautionary statement, allergic consumers tend to underestimate some of its expressions,

(4) Cf. reg. EU 1169/11, Annex II. Note well that the list of allergens subject to mandatory indication varies in different ordinances. The list established in Japan, for example, is completely different from the EU list. See the article