New Codex guidance signals a more science-based approach to precautionary allergen labelling.

You pick up a chocolate bar and turn it over. The ingredient list looks fine. Then, near the bottom of the label, you see the words: “May contain peanuts.” On another product, the warning reads: “May contain traces of nuts.” A third says it was “manufactured in a facility that also processes nuts.” For a consumer without a food allergy, those statements may barely register. For someone living with a potentially life-threatening allergy, however, a few words on a food label can determine whether that product goes into the shopping basket or back onto the shelf. That is why a major international development in food allergen labelling deserves our attention in Jamaica.

In July 2026, the Codex Alimentarius Commission adopted new guidelines on the use of precautionary allergen labelling (PAL) — the type of warning commonly expressed as “may contain”. The change is significant because Codex is pushing the food industry away from using precautionary statements simply because an allergen could be present, and towards a science- and risk-based approach. In simple terms, “may contain” should actually mean something.

Food Allergy Is Not A Preference

A food allergy occurs when the immune system reacts to proteins in a food as though they are a threat. Reactions can range from relatively mild symptoms, such as itching or hives, to vomiting, swelling, breathing difficulty, and anaphylaxis, which can be life-threatening.

The Food and Agriculture Organisation of the United Nations (FAO) estimates that approximately 220 million people worldwide live with food allergies. That makes accurate allergen information more than a labelling technicality. For affected consumers, it is a food-safety control.

The problem becomes particularly serious when an allergen is present in a food but is not declared. This may happen because of an incorrect label, use of the wrong packaging, an ingredient change that was not reflected on the label, or allergen cross-contact during production.

The Recall Numbers Tell A Story

Undeclared allergens consistently rank among the leading causes of food recalls. A 2026 analysis of United States Food and Drug Administration enforcement data covering 2012 to 2024 found that undeclared allergens accounted for 9,018 recall events — 33.6 per cent of the events analysed. A separate analysis of more than 35,000 US food and beverage recalls from 2002 to 2023 found allergens accounted for approximately 28 per cent of recalls.

FDA data have also identified milk as the most common undeclared allergen associated with allergen-related recalls in the United States. The agency reports that milk has accounted for more than one-third of food-product recalls caused by undeclared allergens over the past decade.

These are US figures and should not be presented as Jamaican recall statistics. They are nevertheless useful in demonstrating how frequently allergen-management and labelling failures can reach the marketplace — even within highly regulated food systems.

So, What Exactly Is Codex?

Codex Alimentarius is Latin for “food code”. The Codex Alimentarius is the collection of international food standards, guidelines and codes of practice developed through the Codex Alimentarius Commission, established by FAO and the World Health Organization (WHO) in 1963.

Its two central purposes are protecting consumer health and promoting fair practices in food trade. Codex addresses areas ranging from food hygiene and contaminants to additives, pesticide residues, methods of analysis and food labelling.

Codex texts are generally voluntary; countries must incorporate requirements into national laws or regulations for them to become legally enforceable domestically. However, their influence is considerable. Codex food-safety standards are internationally recognised reference points under the World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures. For Jamaican manufacturers — particularly those exporting food — developments at Codex can therefore have implications far beyond a technical meeting room.

Established in 1963 by the Food and Agriculture Organisation of the United Nations and the World Health Organisation, Codex Alimentarius sets global food standards to protect consumer health and ensure fair trade.

Why “May Contain” Became A Problem

Precautionary allergen labelling is used when an allergen is not intentionally added to a food, but there is a risk that it could unintentionally be present because of cross-contact during production.

For example, if peanuts are deliberately used as an ingredient, they must be declared on the label in accordance with applicable labelling requirements. A statement such as “may contain peanuts” serves a different purpose. It warns consumers that, although peanuts are not part of the product’s recipe, small amounts could unintentionally be present — for example, if the product is manufactured on equipment that is also used to process peanuts.

Over time, precautionary statements have become commonplace. In many markets, they are not applied consistently. One manufacturer may say “may contain”, another “may contain traces of”, while another warns that a product was “made in a facility that also processes” a particular allergen.

The overuse of precautionary allergen statements can also create problems for the very consumers they are intended to protect. When warnings such as “may contain” appear on a wide range of products, consumers with food allergies may find it difficult to determine when there is a genuine risk. Some may avoid foods unnecessarily, limiting their choices, while others may become so accustomed to seeing the warning that they begin to disregard it.

In either case, the warning becomes less effective as a food safety communication tool.

What Has Changed?

The newly adopted Codex guidelines promote a risk-based approach to PAL. Food businesses should first implement appropriate measures to prevent or reduce allergen cross-contact. A precautionary statement should not be used as a substitute for good allergen management.

The business should then assess the residual risk. Codex now provides science-based reference doses that can be used as the basis for establishing action levels. Under the guidelines, PAL should be used only where, after appropriate mitigation measures have been applied, the assessment demonstrates that unintended allergen presence is above the relevant action level.

This is an important shift from asking, “Could an allergen possibly get into this product?” to asking, “After we have applied appropriate controls, does the remaining exposure represent a level of risk that warrants a precautionary warning?”

This does not mean that cross-contact suddenly becomes acceptable. This means that allergen-management decisions, including label warnings, should be grounded in evidence and risk rather than using “may contain” as a blanket disclaimer.

What Jamaican Manufacturers Should Do Now

Local food manufacturers do not need to wait for an export customer or regulator to raise the issue before strengthening allergen controls. Start with your ingredients. Know which allergens enter the facility, including allergens contained within compound ingredients, seasonings, sauces and processing aids where applicable. Supplier specifications and ingredient declarations must be current and reviewed whenever formulations or suppliers change.

Next, map where cross-contact could occur. Consider receiving and storage, weighing, mixing, shared utensils, production equipment, rework, employee movement, cleaning, packaging and labelling. Segregation and production scheduling can reduce risk. Where possible, allergen-containing ingredients should be appropriately identified and controlled. Production may be scheduled from products with fewer allergen concerns to those containing allergens, supported by validated or appropriately verified cleaning procedures.

Pay particular attention to labels and packaging. A perfectly controlled production process can still result in a dangerous recall if the wrong label is placed on the right product. Label verification at start-up, changeovers and during production should therefore be treated as a food-safety activity, not merely a quality check.

What Consumers Can Do

Consumers with food allergies also have an important role in protecting themselves. Read the full label every time, even for a product you have bought many times before. Recipes, suppliers and manufacturing arrangements can change.

Do not assume that a familiar brand is automatically safe across every product or every country. Allergen-labelling requirements differ among jurisdictions, and products manufactured for different markets may have different formulations.

Understand the difference between an ingredient declaration and a precautionary statement. If the allergen is an intentional ingredient, it should be declared in accordance with the applicable requirements. “May contain” relates to possible unintended presence from cross-contact.

If a label is unclear, damaged, missing, or you cannot confidently determine whether the food contains your allergen, the safest choice is not to guess. Contact the manufacturer or supplier for clarification.

For people diagnosed with serious food allergies, follow the management plan provided by your health-care professional and keep prescribed emergency medication accessible. A food label is an essential risk-management tool, but it does not replace individual medical advice.

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About the Author

Allison Richards is a food safety communicator, certified trainer and the founder of The Food Safety Girl, a consumer awareness platform promoting food safety in Jamaica and the Caribbean. She is the Caribbean Chapter Director for Women in Food Safety (WIFS) and host of The Big Bite Food Safety Show. With over 14 years of experience in food safety regulation, she is committed to public education and consumer empowerment. Through public education initiatives, including free community webinars, she continues to create space for learning, dialogue, and practical food safety awareness.

Allison Richards | thefoodsafetygirlja@gmail.com.