Precautionary Labelling & Free-From Claims

Precautionary allergen labelling (PAL), such as 'may contain milk', should be used when:

• AAny allergen is present anywhere at all in the kitchen, no matter how small the risk
• BA dish has at some point previously been served to a customer who has a known allergy
• CA supplier simply recommends adding a general precautionary warning label to be safe
• DA risk of allergen cross-contamination has been identified and cannot be controlled✓

Answer: PAL should only be used where a risk assessment has identified a genuine, unavoidable risk of allergen cross-contamination that cannot be sufficiently controlled through measures such as segregation and cleaning. It is not meant to cover every allergen present anywhere in the building, regardless of risk. Using PAL without a real identified risk can mislead consumers and breach food law.

A manager wants to add a precautionary label to a product but has not identified any specific cross-contamination risk. What should they do?

• AAdd the label but quietly reduce the product's shelf price to compensate customers
• BAdd the label during the business's busiest trading periods, when mistakes are likelier
• CAvoid using PAL, because it is not justified without a genuine identified risk✓
• DAdd the label anyway, since it protects the business from liability if a reaction occurs

Answer: Using PAL when no genuine risk to the consumer has been identified is misleading and breaks food law, so a business should not add the label without a proper risk assessment first. Applying a precautionary label 'just in case' does not make a product safer, is no substitute for a risk assessment, and can needlessly limit choice for allergic customers. Timing or pricing changes have no bearing on whether PAL is appropriate.

Which wording is acceptable as precautionary allergen labelling?

• AContains a small risk
• BMay contain allergens
• CMay contain milk✓
• DUnclear to consumers

Answer: Precautionary allergen labelling should name a specific allergen, such as 'may contain milk', so consumers know exactly what risk they are being warned about. Vague statements such as 'may contain allergens' are not acceptable, because they fail to identify which of the 14 allergens is at risk. Non-specific or unclear wording gives the consumer no useful information at all.

A ready meal is labelled 'may contain nuts' to warn about a risk of pistachio cross-contamination. What is the correct approach?

• APAL wording must always avoid naming any specific allergen by name
• BThe specific nut should be named, for example 'may contain pistachio'✓
• CThe general term 'nuts' is adequate
• DThe label should instead simply say 'gluten-free' to cover the risk area

Answer: Best practice is to name the specific nut at risk, for example 'may contain pistachio (nuts)', so consumers are not given a wider warning than necessary and can make an informed choice. A general 'may contain nuts' label does not tell a consumer which nut is at risk, and a gluten-free statement is unrelated to a nut cross-contamination risk. PAL statements are expected to reference specific allergens, not avoid naming them.

A product is labelled 'free from milk'. Can the same label also say 'may contain milk' as a precaution?

• AThis combination is allowed, provided the free-from claim is printed in larger type
• BPAL must never be used alongside a free-from claim for the same allergen✓
• CThe two statements simply give extra detail
• DThis combination is allowed only for products that are sold online

Answer: PAL must not be used in combination with a free-from statement for the same allergen, because a free-from claim is a guarantee that the food is suitable for everyone with that allergy. Pairing 'free from milk' with 'may contain milk' directly contradicts that guarantee rather than adding detail. This rule applies to all sales channels and cannot be resolved by adjusting label print size.

A gluten-free product carries a precautionary label reading 'may contain wheat (cereal)' because of a risk of cross-contamination with barley. Is this combination permitted?

• AThis is permitted, because a gluten-free claim is not an absolute free-from guarantee✓
• BThis is permitted only if the product is also separately labelled vegan
• CThis is not permitted, because 'gluten-free' always means zero risk from any cereal at all
• DThis is never permitted, because PAL cannot appear alongside any gluten-related claim at all

Answer: A 'gluten-free' statement is not an absolute claim like other free-from statements; it means gluten levels are below the legal threshold, so it can appear together with a PAL statement such as 'may contain wheat (cereal)'. This combination can be appropriate where testing shows gluten is below the limit but a genuine risk from another cereal protein remains. Whether a product is also labelled vegan has no bearing on this rule.

Precautionary allergen information must always appear:

• AInside the product's full ingredients list, alongside the other emphasised allergens
• BOn a certificate specially issued by the local authority's inspectors
• CBy some accessible means, but it does not have to be printed on the food label✓
• DPrinted directly on the food label itself

Answer: Precautionary allergen information does not need to be on the food label itself; it can be communicated in other ways, such as verbal warnings from staff or a sign displayed at the premises. It is not restricted to appearing inside the ingredients list. No certificate from the local authority is required or issued for PAL statements.

PAL is best understood as:

• AA marketing tool used simply to make a product sound more appealing to shoppers
• BA full replacement for proper cleaning and segregation procedures used daily
• CA mandatory declaration, required on every single food product without any exception
• DA voluntary warning about an unavoidable cross-contamination risk, not a hygiene substitute✓

Answer: PAL is voluntary information that a business can choose to apply once it has identified an unavoidable cross-contamination risk, and it is explicitly not a substitute for good food hygiene and safety practices. Unlike the mandatory declaration of allergens actually used as ingredients, PAL is not required on every product. It exists to warn consumers of genuine risk, not to serve as a marketing device.

A free-from claim on a food product is best described as:

• AA rough estimate of how likely contamination might possibly be
• BA marketing term that carries no real legal significance at all in everyday practice
• CA guarantee that the food tastes and looks almost identical to the standard version
• DA guarantee that the food is suitable for everyone with that allergy or intolerance✓

Answer: A free-from claim is a guarantee that the food is suitable for all consumers with a hypersensitivity to that allergen, so it requires strict control of ingredients, handling and preparation. It says nothing about taste and is not simply a rough estimate of risk. Far from having no legal significance, a false free-from claim can breach food information law.

A kitchen handles wheat flour and cannot remove the risk of cross-contamination through segregating time and space. What should it do about a 'gluten-free' claim on a dish made in that kitchen?

• AMake the claim, provided the dish is cooked last thing in the day
• BAvoid making the gluten-free claim, and instead let the customer know about the risk✓
• CMake the claim, and mention the risk to regular customers who ask
• DMake the claim anyway, since customers will rarely notice or ever complain

Answer: If cross-contamination cannot be removed through measures such as segregation by time and space, the kitchen should not make a gluten-free or wheat-free claim and should instead let the customer know about the risk. Making the claim regardless of the risk is unsafe, whether or not customers notice. Telling only regular customers, or relying on cooking order, does nothing to address the underlying contamination risk.

A customer assumes a vegan curry is automatically free from milk, egg and other animal-derived allergens. What is the correct position?

• AVegan curry is exempt from allergen labelling because it contains no animal products
• BLow-level cross-contamination with animal allergens can still occur during production✓
• CVegan food is legally required to carry a 'may contain milk' warning
• D'Vegan' and 'free from animal allergens' mean exactly the same thing under UK food law

Answer: Vegan meals are not automatically free from animal-based allergens such as egg, fish, crustaceans, molluscs and milk, because low-level cross-contamination from these ingredients can occur during production. A 'vegan' label communicates a different message to a 'free from' claim and is aimed at a different consumer group. Nor is there any rule that vegan food must carry a 'may contain' warning; precautionary labelling should follow a genuine risk assessment.

Voluntary 'gluten-free' labelling under Regulation (EU) No. 828/2014 may be used when the gluten level in the food, as sold to the final consumer, is:

• A100 mg per kilogram or less
• B20 mg per kilogram or less✓
• C200 mg/kg or less
• D5 mg per kilogram or less

Answer: A 'gluten-free' claim can be used where gluten in the food, as sold to the final consumer, is 20 mg per kilogram or less. This is a stricter threshold than the one for 'very low gluten', which allows up to 100 mg per kilogram. These thresholds apply to all foods, including non-prepacked food such as meals served in a restaurant.

What is the maximum gluten level permitted for a product to be voluntarily labelled 'very low gluten'?

• A500 mg per kilogram, as measured in the food when sold to the final consumer
• B20 mg per kilogram, as measured in the food when sold to the final consumer
• CNo maximum at all, provided the packaging also separately says 'gluten-free'
• D100 mg per kilogram, measured in the food as sold to the final consumer✓

Answer: A 'very low gluten' claim requires the gluten level, measured in the food as sold to the final consumer, to be no more than 100 mg per kilogram. This threshold is higher than the 20 mg per kilogram limit that applies to a 'gluten-free' claim. There is no version of the rule that allows an unlimited gluten level just because the packaging also carries a 'gluten-free' statement, since the two claims have distinct, separate thresholds.

A product uses gluten-free oats that have been specially processed to reduce their gluten content. When such a product is labelled 'gluten-free', how must the oats be shown in the ingredients list?

• AOats only need to be listed on the label if they make up more than half of the entire finished recipe
• BOats can be renamed as 'cereal fibre' to avoid confusing allergic customers
• CThe word 'oats' must still be emphasised and declared, even though the product is gluten-free✓
• DOats can be left off the ingredients list entirely, once the product safely meets the gluten-free threshold

Answer: Even when gluten-free oats meet the legal threshold for a 'gluten-free' claim, the word 'oats' must still be emphasised and declared in the ingredients list, because oats remain an Annex II cereal. Meeting the gluten-free threshold does not remove the separate duty to declare the allergen itself. Renaming or omitting oats from the ingredients list would breach the allergen labelling rules regardless of the proportion used.

Which statement about 'Non-Gluten Containing Ingredients' (NGCI) statements on a menu is accurate?

• AThey guarantee gluten levels below 20 mg per kilogram, exactly the same as a proper gluten-free claim
• BThey are required by law to appear clearly on any menu that lists even a single gluten-containing dish
• CThey are a legally protected alternative to making a proper gluten-free claim
• DThey can mislead consumers, because the business cannot always guarantee the food is gluten-free✓

Answer: NGCI statements, which list dishes said to have no gluten-containing ingredients, can be misleading because the business using them cannot always guarantee the food is genuinely gluten-free. They are not a legally protected substitute for a proper 'gluten-free' statement backed by testing against the 20 mg per kilogram threshold. There is no legal requirement to display an NGCI statement on any menu.

A restaurant reviewing its free-from menu identifies that it cannot fully control cross-contamination for a 'dairy-free' dessert. What is the correct course of action?

• ATell customers about the risk and do not make the dairy-free claim✓
• BMake the dairy-free claim and also add a PAL statement for milk on the same dish
• CMake the dairy-free claim, but quietly reduce the size of the portion served
• DMake the dairy-free claim only for takeaway orders, never for eating in

Answer: If cross-contamination cannot be controlled, the business must tell customers about that risk and must not make the dairy-free claim, since a free-from claim is a guarantee suitable for everyone with that allergy. Pairing the claim with a 'may contain milk' precautionary statement is not permitted, because PAL cannot be combined with a free-from statement for the same allergen. Portion size and whether the order is eaten in or taken away make no difference to this rule.