Did you know? Codex Alimentarius released new guidance on when to use Precautionary Allergen Labelling (PAL). Begin Free PAL Assessment →
Did you know? Codex Alimentarius released new guidance on when to use Precautionary Allergen Labelling (PAL). Begin Free PAL Assessment →
Did you know? Codex Alimentarius released new guidance on when to use Precautionary Allergen Labelling (PAL). Begin Free PAL Assessment →
Did you know? Codex Alimentarius released new guidance on when to use Precautionary Allergen Labelling (PAL). Begin Free PAL Assessment →

Category: Global

  • Food service green claims guide: Navigating the Green Claims Code and Empowering Consumers Directive (EmpCO)

    Food service green claims guide: Navigating the Green Claims Code and Empowering Consumers Directive (EmpCO)

    Food Service Green Claims Guide: Navigating the Green Claims Code & Empowering Consumers Directive (EmpCO)
    FOOD SERVICE REGULATORY COMPLIANCE

    FOOD SERVICE GREEN CLAIMS GUIDE
    NAVIGATING THE GREEN CLAIMS CODE AND EMPOWERING CONSUMERS DIRECTIVE (EmpCO)

    Environmental claims across food service operations – such as “sustainably farmed”, “eco-friendly packaging”, or “low-carbon dish” – are now subject to strict legal enforcement in the UK and Europe.

    Regulators have moved beyond voluntary guidelines to mandatory consumer protection laws with severe financial penalties. Food service businesses operating in the UK must comply with the CMA’s established Green Claims Code, while those distributing across Europe must prepare for the EU Empowering Consumers Directive (EmpCO) deadline of September 2026.

    Food service operators must now align packaging, menus, and digital marketing copy with the Competition and Markets Authority (CMA) established Green Claims Code, and the EU’s incoming Empowering Consumers for the Green Transition Directive (EmpCO EU 2024/825).

    EXISTING REGULATIONS VS. EMPOWERING CONSUMERS DIRECTIVE (EmpCO): WHAT IS CHANGING?

    Environmental marketing in food service is transitioning from voluntary self-regulation to legally binding prohibition backed by direct financial penalties. To safeguard business margins and brand reputation, commercial buyers and operations leads must evaluate how existing rules compare with incoming legislation:

    EXISTING REGULATION: UK CMA GREEN CLAIMS CODE & ASA

    EXISTING LEGISLATION

    • 6 Core Principles: Claims must be truthful, unambiguous, account for full lifecycle impact, backed by verified evidence, and offer fair comparisons under the CMA Green Claims Code.
    • Broad Operational Scope: Covers all consumer-facing channels including digital menus, takeaway packaging, social media marketing, and delivery aggregator listings.
    • Enforcement & Direct Fines: Co-regulated by the UK CMA and the ASA, backed by direct civil penalties of up to 10% of global annual turnover under the Digital Markets, Competition and Consumers Act 2024.
    INCOMING LEGISLATION: EU EmpCO DIRECTIVE (EU 2024/825)

    NEW LEGISLATION (September 2026)

    • Blacklisting Generic Terms: Total prohibition of generic descriptors like “eco-friendly,” “green,” “bio-based,” or “climate-smart” without verified, recognized environmental excellence.
    • Total Carbon Offset Ban: Strict legal ban on claiming menu items or packaging are “carbon neutral,” “net zero,” or “climate-compensated” via external offset purchases under EmpCO Directive (EU 2024/825).
    • Verification Mandate: In-house eco-badges or custom environmental logos are not allowed unless backed by official public schemes or accredited third-party certification.

    COMMERCIAL & OPERATIONAL IMPACT ON FOOD SERVICE BUYERS

    Substantial Financial Risk: Relying on unverified supplier claims or offset credits leaves businesses exposed to severe regulatory fines (up to 10% of turnover under UK DMCC powers) and forced public retractment notices. Food service leads must transition away from manual, paper-based claims tracking toward automated, software-driven Lifecycle Assessments (LCA) at the recipe and ingredient level.

    THE THREE PILLARS OF LEGAL GREEN CLAIMS COMPLIANCE IN FOOD SERVICE

    Achieving long-term compliance across catering and food service operations relies on three core operational pillars:

    Compliance manager auditing automated food service recipe LCA and packaging environmental claims softwarePILLAR 1

    AUTOMATED LIFECYCLE SUBSTANTIATION

    Under the CMA Green Claims Code, claims must evaluate full product lifecycle impact. Highlighting sustainable agricultural sourcing while ignoring non-recyclable packaging or high-emission processing constitutes unlawful greenwashing.

    Food packaging green claims audit removing prohibited generic eco tags and carbon offset claimsPILLAR 2

    ELIMINATION OF OFFSET & GENERIC CLAIMS

    The EmpCO Directive (EU 2024/825) explicitly bans generic claims like “green” or “eco-friendly.” Crucially, claiming a food dish or meal kit is “carbon neutral” based on tree-planting offset schemes is legally blacklisted.

    Food service procurement team verifying automated recipe carbon accounting and Scope 3 emissions calculationsPILLAR 3

    VERIFIED CERTIFICATIONS & SCIENCE DATA

    Environmental claims and eco-scores must be backed by official public schemes or accredited third-party verification. Future carbon reduction claims require transparent, publicly accessible implementation roadmaps verified by external audit data.

    ACTION PLAN FOR GREEN CLAIMS CONTROL IN FOOD SERVICE

    Commercial buyers and operations directors must embed automated compliance into daily workflows. Follow this 6-step action plan to mitigate risk and streamline environmental marketing across your brand:

    1. AUDIT ALL PACKAGING & MENU CLAIMS

    Conduct a complete inventory of every environmental claim printed on takeaway containers, hot cup sleeves, napkins, printed menus, digital ordering apps, and marketing channels. Flag all unverified claims for immediate correction.

    2. ELIMINATE UNVERIFIED CARBON OFFSET STATEMENTS

    Immediately remove claims like “Carbon Neutral Lunch” or “Climate Compensated Meal” that rely on tree-planting or external carbon credits. Under the EmpCO Directive, claims of climate neutrality based on offsetting are banned.

    3. IMPLEMENT AUTOMATED RECIPE-LEVEL CARBON ACCOUNTING

    Replace manual spreadsheets with automated recipe management software that calculates CO2e per dish directly from supplier ingredient databases. Software-driven LCA calculations provide instant audit trails required by regulators like the CMA.

    4. SCRUB GENERIC ‘ECO’ LABELS & UNACCREDITED LOGOS

    Replace generic descriptors like “100% Eco-Friendly” or self-designed “Green Choice” leaf badges. All environmental symbols must belong to officially recognized public certification schemes or independent third-party verification standards.

    5. ALIGN WITH THIRD-PARTY CERTIFICATIONS & PUBLIC SCHEMES

    Ensure packaging claims cite specific, recognized standards (such as FSC, PEFC, or EN 13432 industrial compostability). If advertising corporate carbon targets, publish detailed, externally monitored implementation roadmaps.

    6. PUBLISH REAL-TIME DYNAMIC CARBON MENUS

    Publishing clear, QR-accessible digital menus integrated with live recipe environmental software allows consumers to view verified dish footprints (A-E carbon ratings or CO2e grams) directly, protecting caterers from misleading marketing liability.

    INTERACTIVE DIAGNOSTIC TOOL

    CHECK IF YOUR GREEN CLAIM ALIGNS WITH RECOMMENDED BEST PRACTICE

    Select the option that best describes your menu, packaging, or marketing environmental claim to evaluate how well it aligns with established guidelines under the Green Claims Code and incoming EmpCO rules.

    BEST PRACTICE MANAGEMENT FOR ENVIRONMENTAL MARKETING

    To exceed statutory benchmarks and protect your business against enforcement actions, implement these commercial safeguards:

    • INTEGRATED RECIPE-LEVEL LCA SOFTWARE:
      Connect central recipe and procurement software directly to peer-reviewed environmental databases to automate dish carbon footprinting and eliminate manual calculation errors.
    • CENTRAL COMPLIANCE REGISTER:
      Maintain a centralized digital repository of independent lab testing reports, supplier LCA declarations, and environmental certifications for every packaging SKU and menu item.
    • EXPLICIT DISPOSAL INSTRUCTIONS:
      Avoid vague terms like “biodegradable” or “compostable.” Clearly state disposal requirements (e.g., “Compostable via Industrial Facilities Only – Do Not Home Compost”).

    INSPECTION CHECKLIST FOR GREEN CLAIMS: TRADING STANDARDS & CMA

    REGULATORY ENFORCEMENT FRAMEWORKS

    Under the UK Digital Markets, Competition and Consumers Act 2024, the CMA possesses direct enforcement power to impose substantial financial penalties (up to 10% of global turnover) without court action for deceptive green claims. Concurrently, Local Trading Standards and the ASA monitor misleading advertising across print, packaging, and digital menus.

    Consolidate all supplier specification sheets, dish lifecycle assessment data, and certification evidence in a dedicated green claims audit folder for immediate regulator review.

    READY FOR THE GREEN CLAIMS COMPLIANCE DEADLINE?

    Do not leave menu copy, carbon claims, and food packaging specs to commercial risk. Audit active packaging lines, evaluate automated recipe LCA tools, and clean unverified environmental claims today.

  • Global Foodservice Compliance Trends: 7 Major Regulatory Trends in 2026

    Global Foodservice Compliance Trends: 7 Major Regulatory Trends in 2026

    Global Foodservice Compliance Trends: 7 Major Rules
    SPECIAL INDUSTRY BRIEFING

    GLOBAL COMPLIANCE TRENDS 7 SHIFTS RESHAPING FOODSERVICE

    Understanding top global foodservice compliance trends is vital whether you operate a multi-unit ghost kitchen, an institutional cafeteria, a catering business, or a neighborhood dining venue.

    We explore how these global compliance trends are actively inpact daily operations for food service operators.

    Written allergen labels showing global foodservice compliance trends in commercial kitchens TREND 01

    WRITTEN ALLERGENS IN FOODSERVICE

    Written allergens on menus is becoming the standard.

    VIEW TREND

    For decades, printed allergen warnings were reserved for grocery store packages. Foodservice venues relied on informal verbal explanations. However, asking guests to rely on server memory poses severe medical risks for diners with life-threatening allergies.

    The first major shift occurred when pre-packaged grab-and-go foods became popular. Laws like Natasha’s Law1 in the United Kingdom required full ingredient and allergen labels on items packaged before ordering. Today, regulators are expanding this concept to fresh restaurant plates, commercial catering spreads, and institutional food service operations.

    Evidence and Global Picture

    Across the European Union, Regulation (EU) No 1169/20112 establishes the standard 14 major allergens. However, individual nations decide rules for unpackaged food. In Ireland, Statutory Instrument S.I. No. 489/20143 legally mandates written allergen details at the point of ordering. In the UK, advocacy surrounding Owen’s Law4 is pushing the Food Standards Agency (FSA)5 toward mandatory written allergen matrices on all dining tables.

    In Australia and New Zealand, the Plain English Allergen Labelling (PEAL) Standard 1.2.36 requires explicit written declarations. In Asia, agencies like the Singapore Food Agency (SFA)7 and Japan’s Ministry of Agriculture, Forestry and Fisheries (MAFF)8 enforce written disclosures. In the MENA region, the Saudi Food and Drug Authority (SFDA)9 mandates written allergen matrices across printed menus and online delivery apps.

    In the United States, federal rules like the Food Allergen Labeling and Consumer Protection Act (FALCPA)10 and the FASTER Act11 traditionally focused on packaged retail foods. However, California enacted Senate Bill 68 (the ADDE Act)12. Starting July 1, 2026, restaurant chains with 20 or more locations nationwide must provide written disclosures of the nine major food allergens directly on physical menus, digital boards, or printed guides.

    Impact and What to Expect Next

    This shift is ending the era of verbal server assurances. In the next few years, food service operations will replace static paper menus with dynamic digital menus linked directly to kitchen recipe management software. Diners will expect instant, searchable allergen matrices on their phones, while health inspectors will treat missing allergen documentation with the same severity as dangerous food temperatures.

    💡 Advice for Foodservice Operators

    Swap vague verbal server statements for a live digital recipe matrix. Ensure kitchen staff update it instantly whenever sub-ingredients change on line.

    Point-of-order nutrition representing global foodservice compliance trends TREND 02

    TRANSPARENT MENUS

    Mandatory calorie & kilocalorie displays are now expected from more businesses.

    VIEW TREND

    Point-of-order nutrition means displaying exact calorie and macronutrient numbers right where guests make their food choices. In the past, calorie labels were seen only on fast-food drive-thru boards. Today, public health agencies view commercial food service menus as tools to fight obesity, diabetes, and heart disease.

    Instead of hiding nutritional data in online fine print, governments are requiring clear calorie counts right beside dish names across menuboards, self-serve kiosks, and delivery apps.

    Evidence and Global Picture

    In the UK, The Calorie Labelling Regulations 202113 mandate that hospitality businesses with 250 or more employees show total energy in kilocalories (kcal) beside every dish. These displays must appear on physical menus, display cases, and online ordering portals, supported by reference notes for daily adult intake.

    In the United States, the Food and Drug Administration (FDA)14 enforces menu rules under Title 21 of the Code of Federal Regulations Section 101.11 (21 CFR 101.11)15. Foodservice chains with 20 or more nationwide locations must state calories next to item names. Furthermore, operators must maintain complete written records showing fat, sodium, fiber, and sugar content for guests who request them.

    In Australia, programs like the New South Wales Fast Food Kilojoule Scheme16 (enforced by the NSW Food Authority17) make prominent kilojoule (kJ) displays mandatory. In the MENA region, the Saudi Food and Drug Authority and GSO Standard SFDA.CO/GSO 223319 enforce calorie counts across dine-in and delivery apps. In Asia, the Singapore Food Agency7 and Taiwan Food and Drug Administration (TFDA)20 continue extending point-of-order rules into mid-tier commercial dining networks.

    Impact and What to Expect Next

    Point-of-order nutrition rules are encouraging food service operators to reformulate heavy sauces and reduce portion sizes. Over the next few years, expect nutrition labeling requirements to expand from large national chains to smaller regional multi-unit groups. Digital menus will also offer interactive sliders that update calorie counts automatically as guests customize toppings or dressings.

    💡 Advice for Foodservice Operators

    Standardize kitchen portioning scoops and connect recipe management tools with your Point-of-Sale (POS) so nutrition updates sync smoothly everywhere.

    Clear pricing rules reflect global foodservice compliance trends on delivery apps TREND 03

    CLEARER PRICING

    Surprise additional costs for customers ordering food are being phased out.

    VIEW TREND

    Drip pricing is a deceptive digital tactic where a business advertises a low starting price for a meal, but gradually reveals mandatory add-on fees as the customer moves through checkout. These extra costs are often described as service fees, bag fees, or convenience charges.

    As mobile ordering apps and delivery platforms became major revenue sources across food service operations, consumer protection agencies began taking legal steps to ban hidden fees and force honest upfront pricing.

    Evidence and Global Picture

    In the United States, the Federal Trade Commission (FTC)21 is taking aggressive action against junk fees. In California, Senate Bill 478 (the Honest Pricing Act)22 prohibits hidden service surcharges across food delivery and booking apps. This law requires displayed menu prices to include all non-optional charges upfront.

    In the UK, the Competition and Markets Authority (CMA)23 enforces strict price rules under the Digital Markets, Competition and Consumers Act 2024 (DMCCA)24.

    In Australia, the Australian Competition and Consumer Commission (ACCC)25 regularly penalizes delivery aggregators for misleading drip pricing. Across the European Union, regulators enforce the EU Consumer Rights Directive (Directive 2011/83/EU)26 to ban hidden delivery fees. In Asia and the MENA region, bodies including Japan’s Consumer Affairs Agency (CAA)27 and the Gulf Standardization Organization (GSO)19 require complete fee disclosures before checkout.

    Impact and What to Expect Next

    Strict pricing rules are changing how food service brands set up their digital storefronts. Over the next few years, delivery apps and first-party ordering websites will eliminate checkout fee surprises entirely. Operators will shift toward transparent all-inclusive item pricing, helping restore customer trust in online delivery channels.

    💡 Advice for Foodservice Operators

    Audit your web store and delivery platforms to ensure packaging or platform fees display upfront rather than appearing at checkout.

    Promotional food rules demonstrating key global foodservice compliance trends TREND 04

    RESTRICTIONS ON UNHEALTHY FOODS

    Advertising and promoting high-fat, high-sugar items is becoming harder.

    VIEW TREND

    In addition to pricing transparency, public health agencies are restricting how foods high in fat, sugar, and salt (HFSS) are marketed on digital channels.

    Rather than banning items outright, regulations target marketing techniques like pop-up upsells, algorithm recommendations, and multi-buy promotions that encourage consumers to purchase oversized portions or sugary drinks.

    Evidence and Global Picture

    In the UK, The Food Promotions Regulations 202128, the Health and Care Act 202229, and DMCCA rules24 ban volume discounts like buy-one-get-one-free and algorithm-driven checkout prompts for HFSS foods. Compliance is measured using the Department of Health and Social Care (DHSC) Nutrient Profiling Model30.

    In Asia, the Singapore Ministry of Health (MOH)31 enforces Nutri-Grade Rules32 under the Sale of Food Act33. This framework bans advertising and digital placements for Grade D high-sugar beverages on websites and app banners.

    In Australia and New Zealand, the ACCC25 and FSANZ18 monitor digital marketing claims. In the MENA region, the Saudi Food and Drug Authority9 enforces strict advertising controls on high-sodium menu items across delivery apps.

    Impact and What to Expect Next

    Digital marketing controls are prompting food service brands to rethink how they structure app upselling. Over the next few years, ordering apps will replace sugary side-item prompts with healthier recommendations like baked goods, sparkling water, or fresh fruit cups to comply with regional advertising laws.

    💡 Advice for Foodservice Operators

    Review app upsells and banner offers with your marketing team to ensure online promotions comply with regional HFSS restrictions.

    Front of pack warning labels highlighting key global foodservice compliance trends TREND 05

    FRONT-OF-PACK LABELS

    High-visibility warning badges on nutrients like sodium and sugar are becoming more common.

    VIEW TREND

    Front-of-Pack (FOP) warning labels are high-visibility symbols printed on the front of packaged foods or placed next to menu items. They immediately warn consumers when a dish contains high levels of sodium, sugar, or saturated fat.

    Unlike traditional nutrition facts tables printed on the back of packages, front-of-pack labels give diners instant warning cues before they order.

    Evidence and Global Picture

    In the United States, municipal health departments led the front-of-pack movement. For example, New York City requires chain food service establishments with 15 or more locations to post a salt-shaker warning icon next to any menu item containing 2,300 mg or more of sodium (the daily recommended limit). NYC also enforced the Sweet Truth Act, requiring a sugar spoon warning icon next to any menu item or beverage containing over 50 grams of added sugar. At the federal level, the US FDA Center for Food Safety and Applied Nutrition (CFSAN)34 is developing national front-of-pack warning label standards.

    Internationally, countries choose different front-of-pack labeling models based on their public health priorities. In the UK, the Food Standards Agency5 uses a voluntary traffic-light system (red, amber, green) for calories, fat, sugar, and salt. In Latin American countries like Chile and Mexico, governments mandate prominent black octagonal warning stops for high-sodium or high-sugar foods.

    Across the European Union, authorities working under Regulation (EU) No 1169/20112 continue reviewing Nutri-Score labeling. In Australia and New Zealand, public health officials rely on the Health Star Rating system35 (ranging from 0.5 to 5 stars), while the Saudi Food and Drug Authority9 mandates traffic-light indicators across packaged foods in the MENA region.

    Impact and What to Expect Next

    Front-of-pack warning labels are encouraging food service operators to adjust their recipes to avoid showing warning icons on menus. Over the next few years, front-of-pack warning symbols will become standard across grab-and-go meal containers and digital delivery menus worldwide.

    💡 Advice for Foodservice Operators

    Check grab-and-go packaging layouts to ensure enough principal display space is reserved for standardized front-of-pack graphic badges.

    Eco takeaway packaging following global foodservice compliance trends TREND 06

    SAFER FOOD PACKAGING

    More chemicals and types of plastics are being banned from food service.

    VIEW TREND

    Environmental authorities are banning PFAS alongside single-use plastics due to health concerns, pushing commercial food service operators toward safe, certified fluorine-free packaging alternatives.

    Per- and Polyfluoroalkyl Substances (PFAS) are man-made synthetic chemicals known as “forever chemicals” because they do not break down naturally in the environment or the human body. Packaging manufacturers long used PFAS treatments to make paper wrappers, bowls, and takeaway boxes grease and water resistant.

    Evidence and Global Picture

    In the United States, state-level bans led the transition. California’s Assembly Bill 1200 (AB 1200)36 prohibits intentionally added PFAS in paper-based food containers and requires certified fluorine-free alternatives.

    Across the European Union, the Packaging and Packaging Waste Regulation (PPWR)37 bans PFAS in food-contact packaging while setting minimum requirements for post-consumer recycled plastic content.

    In the UK, health and environmental agencies guided by the Food Standards Agency5 restrict hazardous food-contact substances alongside the Plastic Packaging Tax. In Australia and New Zealand, environmental agencies under the Department of Climate Change, Energy, the Environment and Water (DCCEEW)38 are promoting fluorine-free takeaway containers.

    Impact and What to Expect Next

    Packaging regulations are forcing commercial kitchens to verify their packaging supplies with care. Over the next few years, packaging suppliers will offer plant-based and aqueous-coated containers that provide grease resistance without relying on PFAS chemicals.

    💡 Advice for Foodservice Operators

    Audit supplier compliance certificates for takeaway containers to guarantee fluorine-free credentials and satisfy chemical rules.

    Digital inventory tracking showing key global foodservice compliance trends TREND 07

    DIGITAL SUPPLY CHAINS

    Paper documentats are being phased out in favour of digital trails.

    VIEW TREND

    Paper trails are being replaced by more high tech digital systems. Digitizing kitchen receiving logs means replacing paper delivery clipboards and paper invoice binders with digital inventory tools, handheld barcode scanners, or cloud management apps. When deliveries arrive at the kitchen dock, staff scan barcodes to log batch lot numbers, expiration dates, and supplier details automatically.

    This shift allows commercial food service operations to respond instantly during food recalls, tracing contaminated ingredients in minutes rather than sifting through stacks of paper receipts.

    Evidence and Global Picture

    In the United States, federal rules under Food Safety Modernization Act (FSMA) Section 204 (21 CFR Part 1 Subpart S)39 require electronic recordkeeping for foods on the Food Traceability List. Operators must track Critical Tracking Events (CTEs) and Key Data Elements (KDEs) across their supply chain.

    In the UK, safety authorities enforce the Border Target Operating Model (BTOM)40. BTOM is the UK’s post-Brexit digital border control system for imported meat, dairy, produce, and plants. It uses risk-based sanitary certificates and digital tracking to manage imports securely.

    Across the European Union, customs authorities enforce the EU Deforestation Regulation (EUDR – Regulation (EU) 2023/1115)41. EUDR requires food businesses to prove key commodities like coffee, cocoa, palm oil, beef, and soy were not grown on land deforested after December 31, 2020, requiring precise GPS geolocation mapping back to the farm.

    In the MENA region, platforms like the Saudi SFDA ‘Rased’ system9 mandate automated lot tracking, while Japan’s Ministry of Agriculture, Forestry and Fisheries (MAFF)8 enforces electronic lot records across Asia.

    Impact and What to Expect Next

    Digital supply chains are eliminating paper receiving binders across commercial foodservice operations. Over the next few years, cloud-based inventory software will connect dock receiving directly with Point-of-Sale recipe management. If a supplier issues a recall, the system will flag affected menu items automatically and halt sales instantly.

    💡 Advice for Foodservice Operators

    Move receiving dock logs to cloud software so lot numbers can be queried instantly during an inspection or recall.

    REFERENCES & CITATIONS

    1. UK Food Standards Agency – Natasha’s Law Guidance
    2. EUR-Lex – Regulation (EU) No 1169/2011
    3. Irish Statute Book – S.I. No. 489/2014
    4. Owen’s Law Campaign
    5. UK Food Standards Agency (FSA)
    6. FSANZ – Plain English Allergen Labelling (PEAL)
    7. Singapore Food Agency (SFA)
    8. Ministry of Agriculture, Forestry and Fisheries Japan (MAFF)
    9. Saudi Food and Drug Authority (SFDA)
    10. US FDA – Food Allergen Labeling and Consumer Protection Act (FALCPA)
    11. US FDA – FASTER Act Guidance
    12. California SB 68 – Allergen Disclosure for Dining Experiences (ADDE) Act
    13. UK Legislation – The Calorie Labelling Regulations 2021
    14. U.S. Food and Drug Administration
    15. eCFR – 21 CFR 101.11 Menu Labeling
    16. NSW Food Authority – Fast Food Kilojoule Scheme
    17. New South Wales Food Authority
    18. Food Standards Australia New Zealand (FSANZ)
    19. GCC Standardization Organization (GSO)
    20. Taiwan Food and Drug Administration (TFDA)
    21. Federal Trade Commission (FTC)
    22. California SB 478 – Honest Pricing Act
    23. UK Competition and Markets Authority (CMA)
    24. UK Legislation – Digital Markets, Competition and Consumers Act 2024
    25. Australian Competition and Consumer Commission (ACCC)
    26. EUR-Lex – EU Consumer Rights Directive 2011/83/EU
    27. Japan Consumer Affairs Agency (CAA)
    28. UK Legislation – The Food Promotions Regulations 2021
    29. UK Legislation – Health and Care Act 2022
    30. UK DHSC – Nutrient Profiling Model
    31. Singapore Ministry of Health
    32. Singapore Ministry of Health – Nutri-Grade Guidelines
    33. Singapore Statutes – Sale of Food Act
    34. US FDA CFSAN – Front-of-Package Nutrition Labeling
    35. Australian Health Star Rating System
    36. California Assembly Bill 1200 (AB 1200)
    37. European Commission – EU Packaging & Packaging Waste Regulation
    38. Australian Department of Climate Change, Energy, the Environment and Water
    39. US FDA FSMA Section 204 – Food Traceability Rule
    40. UK Government – Border Target Operating Model (BTOM)
    41. EUR-Lex – EU Deforestation Regulation (EUDR)
  • New Codex Precautionary Allergen Labelling (PAL) Guidance: What Food Businesses Need to Know About ‘May Contain’ Labels

    New Codex Precautionary Allergen Labelling (PAL) Guidance: What Food Businesses Need to Know About ‘May Contain’ Labels

    For decades, consumers living with food allergies have relied on warning statements such as “May contain” or “May contain traces of…” to help them make safe food choices. However, these statements have often been applied inconsistently, with different wording and approaches to risk used across the industry.

    This inconsistency has real consequences. Some consumers avoid products that present little or no risk, while others become accustomed to seeing precautionary warnings so frequently that they no longer trust them. At the same time, food businesses have lacked a consistent, internationally recognised framework for deciding when a PAL statement is genuinely required.

    The adoption of new international guidance on Precautionary Allergen Labelling (PAL) by the Codex Alimentarius Commission marks one of the most significant changes to global allergen management in recent years. Food businesses are now expected to demonstrate that decisions to use a PAL (“may contains”) statement are supported by a documented, science-based risk assessment.

    For food service operators, completing and maintaining PAL risk assessments can be challenging. Food businesses must combine supplier information with site-specific operational risks, then keep assessments up to date as suppliers, ingredients, recipes and kitchen layouts change. For organisations managing hundreds of recipes across multiple sites, this can quickly become difficult to manage manually.

    Free Interactive Tool
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    Screen your recipes and determine whether a precautionary allergen label (PAL) may be required.
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    The new Codex guidance aims to change this by introducing a more consistent, evidence-based approach to precautionary allergen labelling, centred on documented risk assessment rather than precaution alone.

    PART 1: A BIG SHIFT IN GLOBAL FOOD ALLERGEN RULES

    At its 49th Session in Geneva, the Codex Alimentarius Commission agreed to adopt a new global approach to Precautionary Allergen Labelling (PAL). This update aims to make “may contain” statements clearer, backed by science, and consistent for allergic consumers everywhere.

    Food allergies affect an estimated 4.3% of the global population. Reactions can range from mild hives to life-threatening anaphylactic shock. Developed after seven joint expert discussions between the Food and Agriculture Organization (FAO) and the World Health Organization (WHO), the new guidelines set out a clear scientific method to decide when a PAL label is actually needed.

    WHAT HAS CHANGED?

    Previous guidance often led to broad use of “may contain” statements whenever an allergen was handled on-site. The updated Codex guidance supports a risk-based approach: PAL should only be used where a residual cross-contact risk remains after appropriate controls and is supported by a risk assessment, rather than as a precautionary disclaimer.

    Instead of using warnings as an excuse for poor cleaning or missing kitchen controls, the new rules state that food businesses must first:

    • Identify where allergen hazards exist.
    • Put proper allergen safety controls in place.
    • Clean surfaces thoroughly to minimize cross-contact.
    • Perform and write down a clear scientific risk assessment.

    A precautionary allergen label (PAL) (may contain) should only be used when a documented risk assessment shows that a cross-contact risk remains after all reasonable control measures.

    KEY FAO/WHO RESOURCES ON PRECAUTIONARY ALLERGEN LABELING

    To support industry leaders and regulators in adopting this risk-based approach, in 2024 the FAO and WHO have published several critical tools, meeting reports, and technical guides. Use these assets to transition your allergen management frameworks successfully:

    Technical Document 1FAO/WHO Priority Food Allergens

    Limits used to define priority allergens.

    Technical Document 2FAO/WHO Reference Doses

    Scientific data to establish safe Reference Doses (RfDs).

    Technical Document 3FAO/WHO Precautionary Allergen Labelling

    Workflow to apply warnings using quantitative data.

    PART 2: WHAT FOOD BUSINESSES NEED TO KNOW

    We first need to understand some key terms and where cross-contact can happen.

    WHAT IS PRECAUTIONARY ALLERGEN LABELLING (PAL)?

    PAL refers to the voluntary warning statements (also known as “may contain”) placed on labels or menus. It informs customers that trace amounts of an allergen might be accidentally present, even though it is not a planned ingredient (e.g. May contain peanuts).

    WHAT IS ALLERGEN CROSS-CONTACT?

    Cross-contact happens when an allergen is accidentally transferred from one food, surface, utensil, or person and it’s not supposed to be there.

    Unlike bacteria, food allergens are highly heat-stable. Cooking, baking, or frying does not destroy them. Once transfer occurs, it can be difficult to see and remove. This is why kitchens focus on preventing this transfer.

    WHERE DOES THE RISK COME FROM?

    As a Food Business Operator (FBO), you must understand that allergen cross-contact risks come from two areas: your supply chain and/or your operations.

    1 SUPPLY CHAIN
    Supply Chain Food Manufacturing Facility

    This is the cross-contact risk present on products from your manufacturers or suppliers before they reach your kitchen.

    EXAMPLES

    • Contamination during raw ingredient transport
    • Shared harvesting or processing equipment at farm level
    • Inadequately cleaned supplier production facilities

    HOW IT IS MANAGED

    Food manufacturers manage this by using dedicated facilities, dedicated production lines, or shared lines with strict cleaning and segregation protocols.

    If they still cannot eliminate the risk, they apply a supplier PAL warning to their packaging.

    2 OPERATIONAL
    Restaurant Kitchen Cooking

    This is the cross-contact risk from your own operations and physical cooking environment.

    EXAMPLES

    • Airborne allergens (like loose flour or milk powder in the air)
    • Shared ingredient storage and open food containers
    • Shared utensils, cutting boards, and prep surfaces
    • Cooking processes (like shared frying oil or flat-top grills)

    HOW IT IS MANAGED

    Kitchens manage operational risk by setting up separate preparation areas, establishing dedicated color-coded utensils, and physical scheduling of allergen-free food preparation.

    Additionally, validated allergen cleaning protocols between batches and comprehensive staff safety training helps eliminate cross-contact incidents.

    If they still cannot eliminate the risk, they apply an operational PAL warning to their packaging.

    THE CONFUSION AROUND “VOLUNTARY”

    A major source of confusion in the food industry is the word “voluntary” used in legislation. Food businesses can misunderstand this to mean that warning about cross-contact is completely optional, or that they do not need to report it at all.

    Let’s go through some key food safety regulations and what they mean –

    CORE LEGAL FRAMEWORKS & GUIDANCE

    GENERAL FOOD LAW (EU 178/2002, ART. 14)
    “Food shall not be placed on the market if it is unsafe.”

    To determine if a food is safe, a business must assess all potential hazards, including cross-contact.

    FIC REGULATION (EU 1169/2011, ARTICLES 4 & 7)
    “Food information shall not be misleading, in particular as to the characteristics of the food, including its allergen content,” and “Food information shall be accurate, clear, and easy to understand for the consumer.”

    Ignoring potential cross-contact risks could make food unsafe or misleading.

    UK FSA GUIDANCE
    “Food business operators are responsible for assessing the need to provide precautionary allergen labelling and to ensure that it is not misleading for consumers,” and “Food businesses may voluntarily provide precautionary allergen labelling such as ‘may contain’ to help consumers make safe and informed choices where there is a risk of allergen cross-contact that cannot be removed through good allergen control practices.”

    As a food business, you are responsible for assessing the risk, and informing your customers of any unavoidable risk.

    US FDA GUIDANCE (FALCPA & ADVISORY)
    “Advisory statements such as ‘may contain’ are voluntary. Firms may use them to alert consumers to possible cross-contact with allergens.”

    Food businesses may use PAL to alert customers where risk exists.

    The word “voluntary” is only used because regulators cannot mandate a warning that does not apply across the entire food supply chain. PAL are only required under specific circumstances.

    However, the legal mandate is clear:
    Businesses are responsible for assessing risk, and any risk that cannot be removed must be communicated.

    If you have assessed your kitchen and there is no real cross-contact risk, you do not need – and should not use – a PAL label. If a risk assessment shows a real cross-contact risk that you cannot eliminate, communicating that hazard is required to make sure your food is safe and not misleading.

    NEW RULES IN THE NETHERLANDS

    Since January 1, 2026, the Netherlands introduced new precautionary allergen rules. The Dutch Food Safety Authority (NVWA) is actively checking labels and kitchen procedures under these standards:

    • No more “just-in-case” labels: Putting a warning on a label “just to be safe” without a risk assessment is now illegal. If risk assessments show no risk of cross-contact, using PAL is not allowed.
    • Strict Wording: Food businesses can only use two PAL statements on their packaging or menus:
      1. “May contain [allergen]”
      2. “Not suitable for persons with [allergen] allergy/intolerance”
      Older wordings like “may contain traces of…” or “made in a factory that handles…” are not allowed.
    • Higher cut-off limits: They have also officially adopted the “$\text{ED}_{05}$” reference dose. This is a scientific threshold designed to protect 95% of the allergic population from experiencing any reaction. As these limits are not as strict as the older target of $\text{ED}_{01}$ (99% of the population), this will reduce the use of PAL.

    REMAINING CHALLENGES WITH PAL

    While the Codex framework provides a helpful global reference, executing these rules in a busy kitchen or packing facility is difficult. Food businesses face several practical challenges:

    1. Knowing how to do a risk assessment with the new $\text{ED}_{05}$ limit

    With modern standards like the Dutch NVWA framework adopting the $\text{ED}_{05}$ limit (eliciting dose for 5% of the allergic population), operators may struggle to transition from visual hazard identification to complex mathematical risk characterization. Determining if cross-contact levels fall below or above the $\text{ED}_{05}$ threshold requires scientific precision, supplier intake validation, and consistent testing, presenting a significant hurdle for many culinary operations. Food service operators need to request this information from their suppliers in order to assess corss-contact from their supply chain, and communicate it to their customers where it cannot be eliminated.

    2. Differences Between Kitchens and Sites

    Managing multiple sites is complex. A large restaurant group or catering chain might use the exact same recipe across 50 different locations. However, the kitchens themselves are rarely identical. Some locations may have large, modern kitchens with separate prep stations for gluten-free or nut-free dishes. Other sites might have tiny kitchens with shared tables, shared ovens, and no room to separate ingredients. Food businesses need recipe and menu management (RMM) digital systems that allow managers to add or remove site-specific allergen warnings based on the physical setup of each individual kitchen.

    3. Limited Space on Labels and Menus

    Food labels are running out of physical space. When you combine mandatory ingredient lists, bolded allergen warnings, nutrition tables, and scientific cross-contamination statements, packaging becomes incredibly crowded. Printed allergen information on labels and menus are generally required by law, though QR codes and digital screens can help keep label and menus clean without overwhelming the customer.

    4. Lack of Time and Resources to Document Assessments

    A proper, science-based allergen risk assessment requires time, technical knowledge, and consistent training. Many small-to-medium food businesses struggle to complete risk assessments due to limited resources, high staff turnover in the kitchen, and lack of training on how to measure cross-contact risk. Digital systems can streamline collecting and maintaining digital records from suppliers and sites.

    5. Knowing When to Redo Your Risk Assessments

    An allergen assessment is not a one-time task. These need to be kept up to date and repeated when:

    • You change a raw material supplier or an ingredient brand.
    • You reformulate a recipe or add a new item to your menu.
    • You change your kitchen layout, add new prep tables, or buy new machinery.
    • An allergen incident, customer complaint, or product recall occurs.
    • At a minimum, as part of your annual routine food safety check (HACCP review).

    6. Real-world Kitchen Challenges

    Beyond paperwork, real-world kitchens present dynamic daily physical challenges: shared deep fryers can contaminate cooking oil with gluten, human error during fast-paced services is common, and sudden supplier substitutions mean ingredients must be checked and menus updated immediately. High staff turnover in the industry mean that food businesses need to ensure that they have a set process with a digital trail in place to show due diligence.

    KEY TAKEAWAYRISK ASSESSMENTS ARE KEY

    PAL should only be used when a documented risk assessment proves there is an unavoidable allergen risk that cannot be managed through standard kitchen safety practices.

    PART 3: HOW TO COMPLETE A RISK ASSESSMENT?

    To help kitchens systematically evaluate and lower cross-contact risks before resorting to warning labels, food businesses should adopt this structured, five-step control workflow:

    1

    ELIMINATE

    Eliminate avoidable cross-contact risks from the supply chain.

    2

    MINIMISE

    Remove the allergen or substitute it with an alternative across your site and your supply chain.

    3

    RESTRICT

    Restrict the extent and movement of remaining allergens within the physical layout of your site.

    4

    MANAGE

    Implement operational procedures to reduce the day-to-day risk of accidental contamination.

    5

    LABEL

    Where you have made every effort to minimise contamination but a risk remains, apply PAL.

    HOW CAN FOOD BUSINESS OPERATORS AUTOMATE PAL?

    With allergen laws tightening and the demand for science-based risk assessments growing, managing cross-contact risk on paper or static spreadsheets is no longer practical. Modern food operations rely heavily on digital SaaS platforms to secure their data from supplier to plate.

    By digitizing ingredient specification sheets, cloud-based software platforms such as recipe and menu management (RMM) systems can monitor your supply chain and operations in real time. If a supplier updates an allergen warning on an ingredient, the platform automatically flags the change and updates every affected recipe, digital menu, and customer portal across the business.

    These digital tools allow culinary and quality assurance teams to apply site-specific PAL overrides based on the physical capabilities of each kitchen.

    This ensures that the warnings displayed to your guests reflect the true, physical state of the kitchen, reducing human error and keeping a digital trail to prove due diligence.

    Interactive PAL Risk Assessment Calculator

    Ready to transition from visual hazard guesses to precise quantitative analysis? Launch our free interactive PAL checker to as a screening to see if a PAL warning may be required.

    Launch Interactive PAL Calculator

    LOOKING AHEAD: THE GLOBAL DIRECTION

    The guidelines adopted at the 49th Session of the Codex Alimentarius Commission signal a clear path forward for global allergen management. While international Codex texts are voluntary guidelines, they form the basis for upcoming local laws, health inspections, and international food trade standards.

    By moving to documented, science-based allergen risk assessments and using modern software tools to track ingredients, food businesses can move past the confusion of “voluntary” labels. Ultimately, the success of these new guidelines will be measured by whether “may contain” declarations become more meaningful, consistent, and trusted by food-allergic consumers around the world.

    Follow the FAO on LinkedIn to stay up to date on PAL guidance VIEW LINKEDIN POST

    REFERENCES

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