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Guide

“May contain” vs “contains” allergens

“Contains” (or emphasis inside the ingredients list) declares allergens that are intentional ingredients. “May contain” is precautionary wording about possible cross-contamination — it does not replace listing ingredients that are actually used, and it is not a legal substitute for Natasha’s Law ingredients lists on PPDS food.

Reviewed against official guidance.SourcesNot legal advice.

Intentional ingredients

Contains vs may contain

WordingWhat it meansDoes it meet Natasha’s Law?
Emphasis in the ingredients list / “Contains”Allergens that are intentional ingredientsYes — this is the PPDS duty
“May contain” / “made in a kitchen that handles…”Possible unintended presence after controlsNo — never a substitute for the ingredients list
Allergen icons aloneVisual shorthandNo — symbols do not replace the written list

If milk, egg, peanuts or any other Annex II allergen is part of the recipe — including inside a compound ingredient — it belongs in the ingredients list with emphasis. That is the “contains” reality, whether or not you also print a summary “Contains:” line.

Precautionary “may contain”

“May contain” / “made in a kitchen that handles…” statements are about risk of unintended presence. UK policy expects them only when a real risk remains after controls — not as a blanket disclaimer on every product. They never remove the duty to list intentional allergens.

Mistakes we see on PPDS packs

  • Printing only “May contain nuts” with no ingredients list
  • Omitting butter from the list because a “may contain milk” line feels safer
  • Copying a supplier’s “may contain” onto a product that deliberately includes that allergen

PPDS bottom line

Lead with an accurate emphasised ingredients list. Add precautionary statements only where your risk assessment supports them.

Questions

Is “may contain” required by Natasha’s Law?
Natasha’s Law is about name and ingredients with emphasised allergens. Precautionary statements are a separate, voluntary risk-communication practice.
Can I use symbols instead of “contains”?
Symbols alone do not meet PPDS ingredients-list requirements. Emphasis must appear in the written list.

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.