New allergen policy proves challenging in practice

A warning such as “may contain xxx” seems like a simple solution. For consumers with allergies, it actually makes choosing products harder. The new Dutch allergen policy therefore aims to reduce unnecessary label warnings. Food businesses have been required to follow this policy since January 1, 2026. But implementation is proving challenging, NBC reports. It takes more than simply updating a label.

Insufficient usable data

Working with new reference doses requires reliable information. Businesses depend on data from the food supply chain for this. That data is not always available, clear, or usable. This affects both bakeries and other food industry businesses. Raw material suppliers also encounter problems with this information.

Foreign suppliers sometimes provide no data on potential cross-contact. Others report quantities that do not seem to reflect actual conditions. Some figures are highly theoretical or based on extensive extrapolation. As a result, they offer little support for properly identifying risks. This makes it difficult to conduct a qualitative risk assessment using this data. Suppliers also sometimes issue precautionary warnings about potential cross-contact. In practice, there is not always a clear basis for doing so.

Differences between countries

Foreign suppliers often calculate risks using a lower reference value based on ED01. As a result, they issue warnings about potential allergen cross-contact more readily. They also sometimes fail to distinguish between different gluten-containing grains or types of nuts. Dutch rules require this distinction. The lack of European harmonization makes implementation even more difficult.

For artisanal businesses, NBC refers to the NVWA’s questions and answers document. Does a raw material specification indicate potential cross-contact? If so, the prepackaged finished product containing that raw material must carry an allergen warning. This type of warning is called Precautionary Allergen Labeling, or PAL.

Raising issues with industry associations

Inadequate data and international differences can lead to more warnings than necessary. This means implementation can undermine the policy’s objective.

NBC is gathering information on the challenges businesses face in practice. The organization brings these to the attention of industry associations. NBC also brings parties together to discuss these issues. Through these efforts, the organization hopes to provide greater clarity on practical implementation.

Nbc.nl