Guide
How to label traces of allergens
Traces from cross-contamination are not declared the same way as intentional ingredients. PPDS labels must list and emphasise allergens that are ingredients. Precautionary “may contain” statements are optional risk communication — only use them when a genuine residual risk remains, never instead of a proper ingredients list.
Reviewed against official guidance.SourcesNot legal advice.
Ingredients vs traces
Butter in a recipe is an ingredient (declare milk with emphasis). Flour dust in the air that might land on a “flour-free” product is a cross-contamination question. Mixing those up produces either missing declarations or meaningless “may contain everything” labels.
Precautionary allergen labelling
If after cleaning, scheduling and storage controls a real risk remains, a clear precautionary phrase may be appropriate. Blanket “may contain” on every SKU trains customers to ignore warnings.
PPDS packs
Build the emphasised ingredients list first. Add precautionary wording last, if your risk assessment supports it.
Never
Never omit an intentional allergen because you plan to write “may contain” instead.
Questions
Should every bakery product say may contain gluten?
Where do I put may contain on the pack?
Official sources
Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.
- Introduction to allergen labelling for PPDS foodFood Standards Agency / GOV.UK
- Labelling guidance for prepacked for direct sale (PPDS) food productsFood Standards Agency / GOV.UK
- Food allergen labelling and information requirements technical guidanceFood Standards Agency / GOV.UK