The Association of European Coeliac Societies (AOECS) is the umbrella organization that represents the voice of over 40 National Associations in Europe and beyond, which represent hundred thousands of coeliac patients and their families.
Established in 1988, it is our mission to promote better quality of life for coeliac patients, including better access to safe gluten-free food.
Celiac disease is a serious autoimmune disease that affects about 1,5% of the population. It is associated with a higher risk of brain damage and mental health issues, and if not treated timely and correctly, it can lead to anaemia, infertility, osteoporosis, and even certain cancers.
Today, the only treatment available for coeliac patients is a rigorous, life-long gluten-free diet. However, access to safe gluten-free food is still challenging.
The so-called Precautionary Allergen Labelling, by which food business operators use the wording “May contain…” in their food, is not regulated at EU level.
As highlighted by the European Court of Auditors (ECA) in its report ‘Food labelling in the EU. Consumers can get lost in the maze of labels. Special Report 23/2024’[1], neither the presence nor the absence of PAL labelling allows a reliable risk assessment by the consumer.
Several studies[2] suggest that there is little correlation between the “May contain” message and the actual presence of the allergen; vice versa the absence of precautionary labelling does not ensure the absence of contamination.
For these reasons, AOECS welcomes the Dutch Policy Rule on Precautionary Allergen Labelling 2024/0678/NL as a pragmatic effort to provide clarity on when there is cross-contamination with allergens and when allergen labelling should be applied as a precautionary measure.
As mentioned in the Policy, substances or products that cause allergies, intolerances or autoimmune reaction may inadvertently become present in food due to cross-contamination. The possible and inadvertent presence of allergens in food poses a health risk to consumers with food allergies, celiac disease and other similar conditions.
The correct application of precautionary allergen labelling is important and must ensure balance between public health protection and limitation of food choices to consumers with allergies or coeliac disease due to unnecessary use of precautionary allergen labelling, which could increase the risk of developing nutrient deficiencies.
For all the above, AOECS acknowledges that the Dutch Policy offers a reasonable level or protection, with clear reference limits, for both consumers with allergies to wheat as well as those with coeliac disease. Simultaneously, the Policy seems to provide food business operators and official control bodies with clear guidelines based on quantitative risk assessments.
AOECS acknowledges the ongoing work at international level launched by the Codex Committee on Food Labelling, for which AOECS is an observer member, and the active participation of EU Commission and Members States active towards developing a “General Standard for the labelling of pre-packaged Foods and guidance on precautionary allergen labelling”.
Nevertheless, we would like to highlight the pragmatic approach of the Dutch Policy Rule and encourage the EU Commission to explore this path for a future adoption of uniform Union rules, that could create a level playing field for all food business operators active the EU territory and a high and homogeneous protection of patients.
We remain open to provide further feedback and assistance.
[2] Allen et al., Precautionary labeling of foods for allergen content: are we ready for a global framework?, World Allergy Organ Journal 2014
Dunn Galvin et al., Precautionary allergen labelling: perspectives from key stakeholder groups, Allergy 2015
Rasmussen et al., Risk of consuming products with or without precautionary wheat or gluten labeling for persons with coeliac disease, Food Chem Toxicology 2022
Lizee et al. Simulated use of thresholds for precautionary allergen labeling: Impact on prevalence and risk, Heliyon 2024.
