Allergen policy adjusted to cross-contamination risks

The Dutch health authorities have regulated their policy on application of precautionary allergen labelling (PAL) and adjusted reference doses for allergens.

In 2016, the Dutch Food and Consumer Product Safety Authority (NVWA) set temporary reference doses for the risk assessment of food allergens. This resulted in some products being labelled with a PAL warning (e.g. ‘May contain peanuts’), even though the product did not intentionally contain allergens but as a precautionary measure against the risk of cross-contamination with allergens.

As a result of the superfluous use of PAL, the NVWA has re-evaluated allergen reference doses and established legal values for the use of PALs. The focus has been on pre-packed foods. 

The application of 'May contain XXX' or similar food allergy warning labels must be supported by a documented risk based on a suitable reference dose. For companies using VITAL’s reference doses, it is necessary to revise the risk assessment with the reference doses given in the Dutch allergen policy if they market food products in the Netherlands.

The new reference doses were implemented on 1 January 2024 and will come into effect in the Netherlands by 1 January 2026. 

For more information about allergens and reference doses, please contact:

Helle Buchardt Boyd   
Tel +45 4516 9097