HomeSafetyAllergen labeling, the great chaos. The Utrecht studio

Allergen labeling, the great chaos. The Utrecht studio

Allergen labeling continues to be unclear, often outlawed, causing serious health risks for consumers with food allergies and intolerances.

To these conclusions comes a very recent study by the University of Utrecht which measured the (poor) effectiveness of precautionary indications on the labels of prepackaged foods. (1)

Allergen labeling, there is a flaw

Il Food Information Regulation (EU regulation 1169/11), as already the so-called allergen directive (directive 2003/89 / EC), prescribes the specific indication on the label of the presence of one or more of the 14 categories of allergenic substances and ingredients referred to in its Annex II (see image). With graphic evidence - for example, in capital letters and / or bold and / or underlined - to the keyword that identifies each allergen, in the ingredients list. (2)

14 allergens

Precautionary labeling allergens (Precautional Allergen Labeling, PAL) is in turn used to warn consumers about the possible presence in the product of certain allergens that have not been deliberately introduced into the product (e.g. ingredients, additives) but may have residuals due to cross contamination (environmental and process ).

The lightning rod of precautionary labeling

The unacceptable deficiency of clear requirements on how to formulate the precautionary warning, in the EC guidelines, has favored the spread of three different approaches to precautionary labeling on the possible presence of allergens:

- 'may contain allergen X'. And this is the only admissible indication, as we have seen, (3)

- 'may contain traces of allergen X’,

- 'made in a factory that also processes allergen X'.

Even more serious is the designation of allergens through names of categories not allowed by regulation (EU) no. 1169/11 (Annex VII, Part B), rather than with their specific names. Ex. 'dried fruit in shell'instead of walnuts, almonds, hazelnuts, .. But also 'cereals containing gluten' rather than wheat, barley, rye, oats and their hybridized strains.

Allergen labeling, the Utrecht study

A systematic review conducted at the University of Utrecht (The Netherlands) measured the effectiveness of allergen labeling on 18 prepackaged foods. The researchers developed fictitious samples, with fictional brands not present on the market, in order to prevent conditioning linked to previous consumer experiences.

The sample was subjected to 238 individuals over-16, with and without diagnosed food allergies, required to shop for a person with a food allergy.

Unclear allergen labeling for 1 in 2 consumers

The results of the study are alarming. Approximately 50% of the participants, both allergic and non-allergic, expressed uncertainty about the allergen information.

The indication 'May contain allergen X', unsurprisingly, got the highest score for comprehensibility.

The wording 'made in a factory that also processes allergen X 'instead, it is intended as an indication of a lower risk than the other two phrases in use. A dangerous underestimation, because inadvertently contaminated prepackaged foods can contain significant levels of allergenic proteins and pose high risks for allergic consumers.

Confusion and underestimation of risk

A serious problem emerged in the Utrecht study is the different perception of food safety risk, between allergic and non-allergic subjects.

Paradoxically, non-allergic consumers express greater caution and also consider the absence of indications on the possible presence of allergens problematic. The allergic consumers who participated in the study, on the other hand, came to underestimate some precautionary warnings.

Resignation and danger of food allergies

'Allergic consumers you may have taken serious risks with these products, on multiple occasions, and may not have reacted. Thus, understandably, they develop a contemptuous attitude towards risk.

 In our opinion, this finding is a strong indication that allergy information is sending the wrong signals to those people who want and need to understand the meaning of this information.'. (1)

A previous study Utrecht University Perspective on Allergic Adults found that nearly half of the participants experienced unexpected allergic reactions, with reactions mostly moderate or severe. And most of the reactions (41%) concerned prepackaged foods.

Marta Strinati and Dario Dongo


(1) Bregje C. Holleman et al. (2021). Poor understanding of allergen labeling by allergic and non-allergic consumers. Clinical and experimental allergy.

(2) Dario Dongo. Allergens, guidelines. GIFT (Great Italian Food Trade) 15.9.17.

(3) Dario Dongo. May contain allergens, ABC. GIFT (Great Italian Food Trade). 24.6.18.ò-contenere-allergeni-abc

(4) Michelsen-Huisman AD, van Os-Medendorp H, Blom WM, et al. (2018). Accidental allergic reactions in food allergy: Causes related to products and patient's management. Allergy. 2018;73(12):2377-2381. Full text of the study available at

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Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

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