The Codex Alimentarius Commission , the international food standards body established by the FAO and WHO, has adopted new guidelines on precautionary allergen labelling (PAL) , the wording commonly known as “may contain traces of”.The context
The new rules were approved at the 49th session of the Commission, held in Geneva from 6 to 10 July 2026, on the basis of the recommendations developed by the Codex Committee on Food Labelling (CCFL) at its meeting in Ottawa from 11 to 15 May 2026.Food allergies affect approximately 4.3% of the world's population, with reactions ranging from mild symptoms to life-threatening anaphylaxis.
To date, the use of wording such as "may contain" has remained largely uneven across countries and companies: in some cases too general, in others applied "blanketly" even in the presence of minimal or well-controlled risks, with the effect of reducing consumer confidence in labels.
What do the new guidelines provide?
The provisions will be integrated as an annex to the General Standard for the Labelling of Pre-packaged Foods (CXS 1-1985) and introduce a principle destined to impact the entire food safety management system: the wording "may contain" can no longer be a generalized defensive option, but must be the result of a scientifically based risk assessment.The key points:
- Risk-based approach : PAL should only be used after the company has implemented adequate allergen management measures (in line with the Code of Practice on Food Allergen Management, CXC 80-2020) and has demonstrated, through scientific assessment, the persistence of a residual risk due to unintentional presence.
- Reference Doses (RfD) : global quantitative reference thresholds (mg/kg of allergen in food) are being introduced, which will allow us to objectively establish when precautionary labelling is truly justified, overcoming the indiscriminate use of "may contain" statements.
- Qualitative and quantitative assessment : the decision to apply the PAL must be based on a presence/absence analysis, possibly supported by quantitative data on the exceeding of the reference thresholds.
- Education and information : the competent authorities are required to promote information programs aimed at operators and consumers for the correct use and understanding of labels.
The implications for businesses
Although these are Codex guidelines – and therefore voluntary in nature – their regulatory weight is far from symbolic: compliance with Codex standards constitutes a presumption of conformity with the WTO free trade principles (SPS and TBT agreements) and represents the technical-scientific reference on which many countries, including the EU, are building their own national regulations.On the European front, the EU Commission has already launched a public consultation for the adoption of an implementing regulation on PAL , with adoption tentatively expected by the fourth quarter of 2027 , to fill the regulatory gap left by Regulation (EU) 1169/2011 on unintentional cross-contamination.
For agri-food companies, the paradigm shift has concrete impacts on multiple levels:
- Product : review of the risk assessment related to recipe, format, portion size and consumption method.
- Process : Reinforced line segregation, sanitization, production sequencing, sampling, and cross-contamination control.
- People and skills : the need for closer coordination between quality, production, R&D, purchasing, laboratory, and marketing to be able to document and justify every labeling choice.
What to do right away
Companies in the sector can start preparing for the new scenario now:- Conduct a PAL Readiness Assessment of the "may contain" statements currently in use on recipes and production lines.
- Verify the robustness of current cross-contamination prevention measures .
- Prepare documentation to support any precautionary labelling decisions , in anticipation of audits and future harmonised national/EU regulations.