"May contain" labels: when small food businesses should use them

"May contain nuts." "Made in a kitchen that handles sesame." You've seen these on almost everything, and you've probably wondered whether you need one. The short answer: only if there's a real risk you can't remove, and never instead of controlling that risk.

These warnings are called precautionary allergen labelling (PAL). In the UK and US they're voluntary, but if you use one it must be true and not misleading.

Allergens in the recipe vs allergens that might get in

Allergens that are ingredients must be declared in the ingredients list. That's not optional and it's not what "may contain" is for. "May contain" is about allergens that aren't in the recipe but could get in by accident: from shared surfaces, equipment, airborne flour, or ingredients your suppliers warn about.

Step 1: Assess the risk honestly

Walk through how each product is made and ask:

• Which allergens are used in the kitchen at all?
• Are they used on the same surfaces, bowls, mixers or trays?
• Can they spread, like flour dust, sesame seeds or crushed nuts?
• Do any bought-in ingredients carry their own "may contain" warning?

Step 2: Reduce the risk first

Before labelling, see what you can control: make nut-free products first and nut products last, use separate equipment for the allergen you handle most, clean down between batches, store allergen ingredients in sealed tubs on low shelves. Often this is enough that a warning isn't needed.

Step 3: Label only what remains

If a real risk remains that you can't remove, name the specific allergen: "may contain peanuts" is useful; "may contain allergens" is not. If a bought-in ingredient says "may contain sesame", carry that warning through to your product.

When not to use one

• On everything "just in case". It cuts off allergic customers from food that's actually safe.
• As a replacement for cleaning and separating.
• Alongside a "free from" claim for the same allergen. They contradict each other.

Tell customers about unwrapped food too

For food you sell loose, make sure you and anyone on your stall can explain how things are made, and keep a written allergen record for each product to hand. A clear sign asking customers with allergies to speak to you helps.

Keep it recorded

Write down your risk assessment and review it when you change your menu, equipment or suppliers. In MakrPrep you can add an allergen by hand to a recipe or component, for example from a shared fryer, and the label reminds you to add it to your packaging. See also Natasha's Law explained and how to write an ingredients list.