Precautionary allergen labelling: NO MORE TRACES!

Dietary avoidance of allergens is crucial in the management of food allergy. Food-allergic individuals (and those who prepare their food) rely on the disclosure of allergens as ingredients. Under the EU Food Information for Consumers (EC Regulation No. 1169/2011), food producers are required to disclose the presence of any of 14 allergens as ingredients, whether prepacked or not (e.g. from restaurants and other catering outlets). However, legislation does not extend to the possibility of food allergens present from cross-contamination or crosscontact in the supply chain or due to shared production facilities. In consequence, many food producers use precautionary allergen labelling (PAL) to alert consumers to the possible unintended presence of allergens (1). The figures speak for themselves. Up to half of prepacked foods sold in supermarkets in the UK, USA and Australia have a ‘may contain’ or precautionary allergen label (PAL) (2–4), but only the minority will actually pose a risk to the allergic individual (1). The use of PAL is voluntary and unregulated; this results in different practices by individual manufacturers and food outlets, with a plethora of labelling formats which both consumers and the healthcare professionals advising them find to be vague, confusing and inconsistent (1, 5, 6). Recently, Marchisotto et al. (7) reported the results of a patient survey on attitudes to PAL conducted across 16 countries. Almost 10 000 consumers completed the survey, and while 58% of respondents were resident in the USA, the authors attempted to control for this in their analysis. The majority of consumers reported that they would be more likely to purchase products labelled ‘may contain “traces” of. ’ compared to those products labelled ‘may contain allergen X’. There was significant country-to-country variation: overall, 25% would purchase ‘traces’ while 16% would purchase an item with a ‘may contain X’ label. However, in some countries (most notably Australia, France, Germany, New Zealand and the Netherlands), well over 50% of consumers would purchase products labelled ‘traces’ – double that for PAL where the wording was more explicit, for example ‘may contain X’. Even more would purchase an item where the PAL indicated ‘manufactured in a facility that also processes X’. These data are not novel, having been previously reported in surveys in the UK (8) and Australia (9). Consumers associate less explicit, more ‘wordy’ PAL as implying a lower risk. However, this is not supported by the available evidence: food products with phrases such as ‘manufactured in a facility that also processes X’ often have the same or even a higher rate of unintended allergen presence compared to products with more explicit phraseology (e.g. ‘may contain. . .’) (10). Thus, PAL may – paradoxically – lead to increased risk-taking, with fewer allergic consumers avoiding products with less explicit PAL phrases. Concerningly, the results of the survey by Marchisotto et al. indicate a significant inconsistency. Consumers were also asked whether they would purchase a product that actually contains the allergen, even if the company could guarantee (presumably on the basis of testing and with the support of national regulation) that no reaction would occur (whether this is a realistic scenario, given the limitations in allergen detection and inconsistent distribution (‘particulate contamination’) of allergen within most food products, is debatable). Nonetheless, far more consumers would purchase a food item with a PAL (where there is an unclear risk of reaction) than an item where the allergen is present but not in sufficient quantities to cause a reaction. One could argue that this might be due to a lack of trust over labelling – however, apparently more consumers ‘trust’ a PAL which has no regulatory basis, than an ingredient label which does. The survey has a number of limitations which are discussed by the authors. These include the fact that respondents were in contact with patient support groups which tend to attract allergic consumers with higher levels of education and who perceive their (or their child’s) allergy to be more severe. Indeed, in this survey, this perception might have been reinforced by the survey itself; the authors defined a severe allergic reaction as including symptoms which might include tongue/facial angioedema, something generally considered to be symptomatic of a non-severe reaction (when occuring in isolation) by most accepted working definitions (11). However, this incongruity – where consumers apparently ‘trust’ PAL more than a declaration of risk dependent on actual allergen presence – must be taken seriously by all stakeholders (including the healthcare sector, government regulators and food industry) who are currently working towards improving the scientific basis of PAL. There is increasing interest in a VITAL-type system, where food producers conduct a risk assessment to help guide the need for PAL (12). However, a fundamental principle of VITAL and similar schemes is that no food can be guaranteed to be 100% safe (13). While this has been acknowledged by many stakeholders, one has to wonder whether a typical allergic individual (or a person preparing their food) would consider this to be acceptable. Allergic consumers need to have trust in the information provided to them, yet clearly this is not currently the case. Trust is based on factors beyond the information on the label (14). To improve the current situation, any allergen information (including PAL) on packaging must be clear, legible and easy