The FSA's Updated Allergen Labelling Guidance: What Your Kitchen Must Do
The FSA has refreshed its best-practice guidance on precautionary allergen labelling. Here's what actually changed — and the practical steps for your kitchen.
Key takeaways
Only use a 'may contain' warning where there's a genuine, unavoidable cross-contamination risk you can't remove by separation and cleaning — and name the specific allergen (e.g. "may contain peanuts", not "may contain nuts").
A 'vegan' label and a 'may contain milk' warning can appear together — they tell customers different things.
Drop "No Gluten Containing Ingredients" wording; use only "gluten free" or "low gluten".
The guidance is best practice and awareness — it doesn't replace correctly identifying allergens, training staff, and your food safety management system.
If you run a café, restaurant or catering business, allergen information is one of the areas an Environmental Health Officer (EHO) will look at closely — and one customers increasingly ask about by name. The Food Standards Agency (FSA) has updated its best-practice guidance on precautionary allergen labelling (PAL) — the "may contain" style warnings — to make them clearer and more useful.
This is guidance, not a brand-new law, but it sets the standard an EHO and a well-run kitchen will expect. Here's what changed and what to do about it.
What the FSA changed
The headline shift is about when a "may contain" warning belongs on food, and how specific it should be. A precautionary allergen label should only be used where there is a genuine, unavoidable risk of cross-contamination that you cannot remove through separation and cleaning. It is not a catch-all disclaimer to add "just in case".
Where a PAL is justified, it should name the specific allergen. "May contain peanuts" tells an allergic customer something they can act on; a vague "may contain nuts" does not. The guidance also confirms that a 'vegan' label and a 'may contain milk' warning can sit together — the vegan claim describes the recipe, while the PAL is food safety information about possible cross-contamination.
What this means for your kitchen
Turn the guidance into a short checklist:
Review every "may contain" you use. For each one, ask: is there a real, unavoidable cross-contamination risk here, or is this a reflex disclaimer? Remove the ones you can't justify.
Name the allergen. Replace generic warnings ("nuts") with the specific allergen ("peanuts", "almonds") wherever you keep a PAL.
Separate recipe claims from safety warnings. A dish can be 'vegan' and still carry a 'may contain milk' warning — don't drop the safety information to protect the claim.
Write it down. Record why each PAL is there in your food safety management system, so you can show an EHO your reasoning.
Gluten labelling: what to say now
The guidance also tidies up gluten wording. Avoid "No Gluten Containing Ingredients" statements. Where you make a claim, use only the legally defined phrases "gluten free" or "low gluten" — these have specific thresholds behind them, so they mean something consistent to a coeliac customer. If you can't stand behind the threshold, don't make the claim.
What this means for compliance
Getting allergen information right is a legal duty under UK food law: businesses must provide accurate allergen information for the food they sell, and Natasha's Law requires full ingredient and allergen labelling on food prepacked for direct sale. The FSA's PAL guidance sits on top of that as best practice for the "may contain" warnings the law doesn't prescribe word-for-word.
An EHO will expect to see that your allergen information is accurate, that staff know how to answer an allergen question, and that your decisions are recorded. Precautionary labels are part of that picture, not a substitute for it.
One honest note: reading this article, or displaying a poster, does not by itself make you compliant. Compliance comes from correctly identifying the allergens in your dishes, giving customers accurate information, trained staff and a documented system. Always check the current FSA guidance and your local authority's requirements.
Frequently asked questions
What changed in the FSA's allergen labelling guidance?
A precautionary allergen label such as "may contain" should only be used where there is a genuine, unavoidable risk of cross-contamination that can't be controlled by separation and cleaning — and it should name the specific allergen (e.g. "may contain peanuts" rather than a generic "may contain nuts").
Can a product be labelled both 'vegan' and 'may contain milk'?
Yes. A 'vegan' label and a precautionary allergen label communicate different things: 'vegan' is about recipe and sourcing, while a PAL is food safety information about possible cross-contamination. Both can appear together where a genuine risk has been identified.
Does reading this article make my business compliant?
No. This article explains current FSA best-practice guidance for awareness; it is not legal advice and does not by itself make you compliant. Compliance comes from correctly identifying allergens, giving accurate information, trained staff, and a documented food safety management system. Always check current FSA guidance and your local authority's requirements.
How should gluten be described on labels now?
Avoid "No Gluten Containing Ingredients" statements. Where a claim is made, use only the legally defined phrases "gluten free" or "low gluten", which have specific thresholds behind them.
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The FSA updated its allergen 'may contain' labelling guidance — here's what changed and what our kitchen needs to do: https://www.thesaferfoodgroup.com/fsa-allergen-labelling-update.php
About the author
PG
Paul Grantham
Food Safety Trainer, Educator & Consultant
Paul is a food safety trainer, educator and consultant with over 15 years' experience helping food businesses work safely. He lectures at university level and spent decades across the hospitality and retail sectors, giving him a practical, floor-level understanding of the pressures real kitchens face. Much of his consultancy work centres on food safety auditing and management system design.