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Allergen management consulting, for manufacturers, retailers and food service

Undeclared allergens are one of the leading causes of food recalls worldwide. We build allergen risk assessments, validate cleaning procedures, and get your labelling right across every market you sell into.

What is allergen management?

Allergen management is the set of processes a food business uses to identify, control and communicate the presence of allergenic ingredients in its products. It sits at the intersection of food safety, regulatory compliance and product labelling.

It covers supplier ingredient declarations, recipe and formulation control, production scheduling, cleaning between allergen changeovers, equipment and storage segregation, staff training, and accurate labelling. Effective allergen management prevents two distinct types of failure: cross-contact, where an allergen unintentionally ends up in a product that should not contain it, and labelling errors, where a label fails to declare an allergen that is genuinely present.

Allergen management is required under EU Regulation 1169/2011 for labelling and Regulation 2021/382 for cross-contact controls on equipment, vehicles and containers. In the US, the Food Allergen Labeling and Consumer Protection Act, as amended by the FASTER Act, governs allergen declaration. Codex Alimentarius published a dedicated Code of Practice on Food Allergen Management for Food Business Operators, CXC 80-2020, providing international guidance.

Within certification standards, allergen management is consistently one of the highest non-conformance areas. FSSC 22000's additional requirements specifically expand on the ISO 22000 baseline, and BRCGS Issue 9 includes allergen management within product control, where it is among the most cited non-conformances of any clause.

The reasons allergen management causes so many problems are structural and not a sign of carelessness. A single product can contain dozens of ingredients, each sourced from a supplier whose own formulation can change without notice. A single production line can run multiple recipes in a day, each with a different allergen profile. And a single label, once printed, has no way of knowing that the recipe behind it has changed. Closing these gaps requires a system that connects supplier declarations, recipe records, production scheduling, cleaning records and labels into a single chain where a change at any point is reflected everywhere else.

Allergen management at a glance

EU/UK allergens
14 (Regulation 1169/2011)
US allergens
9 (FALCPA + FASTER Act)
Newest US allergen
Sesame (2023)
EU cross-contact rule
Regulation 2021/382
Codex guidance
CXC 80-2020
Top recall cause
Undeclared allergens
Key controls
Segregation, cleaning, scheduling, labelling
Required by
FSSC 22000, BRCGS, IFS, SQF

The 14 EU and UK major allergens

Regulation 1169/2011 requires these 14 allergens to be declared in bold or otherwise emphasised within the ingredients list, including for non-prepacked food. The US requires 9 of these under FALCPA, with sesame added as the ninth in 2023.

🍅

Cereals with gluten

Wheat, rye, barley, oats

🦐

Crustaceans

Prawns, crab, lobster

🥚

Eggs

🐟

Fish

🥜

Peanuts

🍊

Soybeans

🥛

Milk

Including lactose

🌳

Tree nuts

Almonds, hazelnuts, etc.

🌿

Celery

🌿

Mustard

🌲

Sesame

Added to US list 2023

🧪

Sulphur dioxide & sulphites

Above 10mg/kg or 10mg/L

🍃

Lupin

🐙

Molluscs

Mussels, oysters, snails

Businesses trading across the EU, UK and US often design labels meeting both sets of requirements simultaneously, using bold ingredient text for the 14 EU and UK allergens alongside a separate "Contains" statement for the 9 US allergens, to simplify compliance across markets without maintaining entirely separate label formats.

Who needs an allergen management programme?

Allergen management is required by every food business, regardless of size, since allergen labelling is a legal requirement everywhere food is sold. The scale of the programme should match the complexity of the operation, but the underlying obligation does not disappear for smaller businesses.

Food manufacturers

Manufacturers handling multiple allergens across shared lines and equipment face the highest cross-contact risk and the greatest documentation burden for risk assessments and cleaning validation.

Restaurants and food service

Allergen information must be available for non-prepacked food in the EU and UK, and cross-contact in kitchens, such as shared fryers or utensils, is a frequent source of incidents in dining settings.

Retailers with in-store preparation

In-store bakeries, delis and hot food counters need allergen controls covering shared equipment and surfaces, separate from the allergen labelling already in place for pre-packed goods.

Businesses pursuing certification

FSSC 22000, BRCGS, IFS Food and SQF all require a documented allergen management programme as part of certification, and allergen-related non-conformances are among the most common findings.

Businesses trading across EU, UK and US markets

Differences between the 14 EU and UK allergens and the 9 US allergens mean labels and risk assessments need to address both sets of requirements where products are sold in multiple markets.

Co-packers and private label manufacturers

Businesses manufacturing products under multiple brand labels with varying formulations face elevated risk of label mix-ups and require robust changeover and verification controls.

Allergen management consulting services

We build allergen management programmes that prevent both cross-contact incidents and labelling errors, the two failure modes behind almost every allergen recall.

Allergen risk assessment

A site and product-specific risk assessment identifying every allergen present across your raw materials, recipes and processes, and mapping cross-contact risk across shared lines, equipment, storage and the wider production environment.

Allergen labelling compliance

Review and correction of allergen labelling against EU Regulation 1169/2011, UK requirements and US FALCPA as amended by the FASTER Act, including review of precautionary "may contain" statements.

Allergen cleaning validation

Validation studies confirming that cleaning procedures reduce allergen residue to an acceptable level before the next product run, using visual inspection, ATP swabbing and allergen-specific testing such as lateral flow or ELISA.

Production scheduling review

Review and redesign of production schedules to sequence allergen-containing products last where possible, minimising the frequency and risk of allergen changeovers.

Equipment and storage segregation

Design of physical segregation controls for allergen-containing ingredients and products, including dedicated equipment, colour-coding and storage layout reviews.

Supplier allergen declaration management

Systems for collecting, reviewing and maintaining current allergen declarations from suppliers, with a change control process to catch formulation changes that introduce new allergens.

Allergen management gap assessment

A review of your current allergen controls against relevant regulations and certification standard requirements, producing a written action plan covering risk assessment, labelling, cleaning and training.

Recall simulation for allergen incidents

A mock recall exercise specifically simulating an undeclared allergen incident, testing your traceability, communication and withdrawal procedures under the scenario most likely to trigger a real recall.

Staff allergen awareness training

Training for production, packing and labelling staff on allergen risks, cross-contact prevention, label verification and what to do if an allergen incident is identified.

Pair consulting with allergen training

Our allergen awareness training courses build staff competency in cross-contact prevention and label verification. We also offer HACCP training and food safety culture training that reinforce allergen controls.

The allergen management programme build process

Building or correcting an allergen management programme follows a defined sequence. Our part of the process typically takes a few weeks.

Stage What happens Our role Duration
1. Gap assessment Current allergen controls, labelling and documentation are reviewed against regulatory and certification requirements. We conduct the assessment and deliver a written action plan. 2 to 3 days
2. Allergen risk assessment Every allergen across raw materials, recipes and processes is mapped, and cross-contact risk is assessed across lines, equipment and storage. We conduct the risk assessment and document findings for every product and process. 3 to 5 days
3. Labelling review Current labels are reviewed against EU, UK and US allergen declaration requirements, including precautionary statements. We review labels and recipes and identify any gaps or inconsistencies. 2 to 3 days
4. Cleaning validation Cleaning procedures for allergen changeovers are tested and validated using visual inspection and allergen-specific testing methods. We design and conduct the validation study and document the results. 3 to 5 days
5. Scheduling and segregation Production schedules and physical segregation controls are reviewed and redesigned where needed to reduce cross-contact risk. We review schedules and propose segregation and sequencing changes. 2 to 3 days
6. Documentation The full allergen management programme is documented, including risk assessments, cleaning validation records, supplier declaration systems and labelling procedures. We write the complete documentation in collaboration with your team. 1 to 2 weeks
7. Staff training Production, packing and labelling staff are trained on allergen risks, cross-contact prevention and label verification. We deliver staff training tailored to your specific products and processes. 2 to 3 days
8. Mock recall exercise A simulated undeclared allergen incident tests traceability, communication and withdrawal procedures end to end. We design and run the exercise and issue a findings report. 1 to 2 days

Allergen management gap assessment

Our gap assessment reviews every part of your allergen management programme, from risk assessment through to labelling, and identifies the gaps most likely to cause an incident or audit non-conformance.

Our allergen management gap assessment reviews risk assessment, supplier declarations, recipe and formulation control, production scheduling, cleaning validation, equipment segregation, staff training and labelling against the requirements of relevant regulations and the certification standards you hold or are pursuing.

The assessment is designed to identify the specific gaps most likely to result in either a cross-contact incident or a labelling error, since these are the two failure modes behind a large share of allergen-related recalls and a large share of allergen non-conformances in certification audits.

  • 1

    Documentation review

    We review existing risk assessments, supplier declarations, cleaning validation records and labelling procedures.

  • 2

    Site walkthrough

    We observe production, changeovers, storage and labelling areas to compare documented controls against actual practice.

  • 3

    Label and recipe cross-check

    We cross-check current labels against current recipes and supplier declarations to identify any mismatches.

  • 4

    Written report and action plan

    We produce a written gap assessment with a prioritised action plan covering risk assessment, cleaning, segregation, scheduling and labelling.

What you receive

  • Allergen risk assessment covering all raw materials, recipes and processes
  • Cross-contact risk map across lines, equipment and storage
  • Labelling review against EU, UK and US requirements
  • Cleaning validation status for each allergen and equipment combination
  • Supplier declaration system review
  • Prioritised written action plan
  • Alignment with FSSC 22000, BRCGS, IFS or other relevant standards

If your business is pursuing or maintaining certification, this assessment aligns directly with the allergen requirements of FSSC 22000, BRCGS Issue 9 and IFS Food Version 8.

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The most common allergen management failures

The same failures appear across food businesses of every size and are responsible for both recalls and certification non-conformances.

EU/UK vs US allergen requirements

The two most commonly compared allergen labelling frameworks for businesses trading internationally.

EU and UK United States
Governing regulation Regulation 1169/2011 FALCPA, as amended by the FASTER Act
Number of allergens 14 9
Most recent addition All 14 in place since 2011 Sesame, added 2023
Cross-contact controls Explicit requirements under Regulation 2021/382 for equipment, vehicles and containers Addressed through FSMA modernised CGMPs as an explicit allergen cross-contact requirement
Non-prepacked food Allergen information required for non-prepacked food Varies. Primarily applies to packaged foods with some state-level requirements for food service
Our consulting Allergen management consulting, covering both frameworks

Allergen management cost and timeline

What drives the timeline and cost of allergen management consulting. We provide a written proposal with a fixed fee after the initial consultation.

Timeline

How long our consulting work takes

Cost factors

What drives the consulting fee

Full programme build from scratch

No existing allergen risk assessment, cleaning validation or labelling review. Our consulting work typically takes 2 to 3 weeks depending on the number of products and allergens involved.

Number of allergens and products

A site handling several major allergens across multiple product lines requires a more extensive risk assessment and cleaning validation programme than a single-allergen, single-line operation.

Labelling review only

For businesses with an otherwise adequate programme needing a labelling compliance check across markets. Our consulting work typically takes 2 to 4 days.

Cleaning validation studies

On-site testing required for each allergen and equipment combination. The number of combinations directly affects the scope and cost of the validation programme.

Multi-market labelling

Businesses selling into EU, UK and US markets need labels and risk assessments addressing both the 14-allergen and 9-allergen frameworks, adding to the scope of the labelling review.

Scope of engagement

A gap assessment only, a full programme build, or cleaning validation studies each carry different fees. All scopes are defined in writing before work begins.

Combined with certification consulting

Allergen management overlaps significantly with FSSC 22000, BRCGS and IFS Food requirements. Where combined, this work is scoped within the broader consulting engagement.

Staff training requirements

Allergen awareness training is often combined with the programme build. Training fees are scoped separately based on the number of staff and delivery format.

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Allergen management questions

Answers to the questions we hear most often from businesses building or correcting their allergen management programme.

Allergen management is the set of processes a food business uses to identify, control and communicate the presence of allergenic ingredients in its products. It covers supplier ingredient declarations, recipe and formulation control, production scheduling, cleaning between allergen changeovers, equipment and storage segregation, staff training, and accurate labelling. Effective allergen management prevents both cross-contact, where an allergen unintentionally ends up in a product that should not contain it, and labelling errors, where a product label fails to declare an allergen that is present.

The number of allergens requiring mandatory declaration varies by jurisdiction. The EU and UK require 14 allergens to be declared under Regulation 1169/2011, including cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts, celery, mustard, sesame, sulphur dioxide and sulphites, lupin, and molluscs. The US requires declaration of 9 major allergens under FALCPA as amended by the FASTER Act: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame, with sesame added as the ninth allergen in 2023.

Allergen cross-contact is the unintentional transfer of an allergen into a food product that is not intended to contain it. It commonly occurs through shared equipment, production lines, utensils, storage areas, or airborne particles such as flour dust. Cross-contact is distinct from a recipe deliberately containing an allergen as an ingredient, and is the focus of cleaning validation, production scheduling and physical segregation controls within an allergen management programme.

Undeclared allergens are consistently one of the leading causes of food product recalls globally, often accounting for a substantial share of recalls in some markets. The most frequent root causes are labelling errors, such as using an outdated label after a recipe change, packaging mix-ups where product is placed in the wrong packaging, and supplier ingredient changes that introduce a new allergen without the formulation or label being updated accordingly.

An allergen risk assessment identifies every allergen present across your raw materials, recipes and processes, and maps where cross-contact risk exists, such as shared lines, equipment, storage areas and the wider production environment. It assesses the adequacy of current controls, including segregation, cleaning, scheduling and labelling, and is required under Regulation 2021/382 in the EU, the FSSC 22000 additional requirements, and the allergen sections of BRCGS, IFS Food and SQF.

Allergen cleaning validation confirms that a cleaning procedure is capable of reducing allergen residue on equipment and surfaces to below an acceptable level before the next product is run. This typically involves visual inspection, ATP swabbing as an indicator of general cleanliness, and allergen-specific testing such as lateral flow devices or ELISA kits during the validation study. Once a cleaning method is validated for a given allergen and piece of equipment, routine verification, such as visual checks or periodic swabbing, confirms the validated method continues to work in practice.

Precautionary allergen labelling, such as "may contain" statements, indicates that a product could contain trace amounts of an allergen due to the production environment, even though the allergen is not a deliberate ingredient. While allergen declaration for ingredients is a legal requirement in the EU, UK and US, precautionary labelling is generally voluntary and not standardised, which means "may contain" statements can be inconsistent in meaning between manufacturers. The VITAL programme is one voluntary framework used to apply precautionary labelling more consistently based on quantitative risk assessment.

Certification standards require a documented allergen management programme covering risk assessment, segregation, cleaning validation and labelling controls. The FSSC 22000 additional requirements specifically expand allergen management beyond the baseline ISO 22000 requirements. BRCGS Issue 9 includes allergen management within product control and is consistently one of the highest non-conformance areas in audits. IFS Food Version 8 addresses allergen risk through its hazard analysis and product information requirements, particularly relevant for products carrying PDO or PGI designations.

An allergen management gap assessment reviews your current allergen controls, including risk assessment, supplier declarations, recipe and formulation control, production scheduling, cleaning validation, equipment segregation, staff training and labelling, against the requirements of relevant regulations and certification standards. It identifies gaps, prioritises them by risk, and produces a written action plan with a realistic timeline.

Yes. Risk assessment reviews, labelling audits, documentation development and cleaning procedure design are all available remotely. We work with clients in any country. On-site visits are available for cleaning validation studies, which require physical testing, and for site reviews of segregation and cross-contact controls.

Single pieces of work on this subject

You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.

Get your allergen labelling right

Tell us about your products and the markets you sell into. We will tell you exactly where your allergen controls stand.