New PAL rules in the Netherlands 2026: what this means for allergen management

From 1 January 2026, the Netherlands introduced stricter guidelines on PAL labelling (possible unintentional presence of allergens due to cross-contamination) on labels. With this, the Netherlands aims to take a major step forward in consumer protection. Allergen warnings must now truly mean something: no longer a legal safeguard for producers, but a reliable warning based on risk analysis.

For consumers, this significantly increases the reliability of allergen information: labels become clearer, more consistent and, above all, more relevant.

For companies, it means greater responsibility, but also an opportunity to work in a more transparent and scientifically grounded way on food safety.

What is changing in PAL labelling in the Netherlands?

Which warnings are still permitted?

Only two statements are still permitted for allergens that may unintentionally occur in your product: 

• May contain ….
• Not suitable for people with a … allergy.

These statements may no longer appear on the label:

• May contain traces of ….
• Produced in a factory that also processes ….
• May cause allergic reactions in….

Why do new reference values (ED05) apply to PAL?

PAL may now only be used when a risk analysis shows that the reference value is exceeded. The new reference values are based on the so-called ED05 approach: a scientific method that calculates how much of an allergen is needed before a maximum of 5% of the allergic population may experience mild reactions. This brings the legislation in line with a risk-based and scientifically substantiated approach. These reference values are often higher than the old standards. This means that a product only needs to carry a warning when the allergen content exceeds a higher threshold.

What do Belgian food companies need to do?

In Belgium, the European Regulation (EU) No 1169/2011 (FIC) still applies. This European regulation requires producers to clearly indicate the 14 main allergens when present as an ingredient. The regulation says little about voluntary warnings such as "may contain traces of". This is why there is still no uniform approach within Europe. In Belgium, precautionary allergen statements (PAL) are still often used today, sometimes out of caution, to limit liability or because certain processes are still too complex.

Even without European/Belgian legislation on PAL, it is wise to start taking steps now. Anyone selling products on the Dutch market will also need to demonstrate that allergen warnings are substantiated.  

The biggest change is not on the label, but in the factory. The key question becomes: have you done everything possible to prevent cross-contamination with allergens?

Step 1: Prevention as the foundation

Responsibility begins with preventing cross-contamination. This is a statutory obligation of best effort under the basic hygiene rule (EU Regulation 852/2004) and forms the core of the guidelines.

Preventive measures include:

• Separation of raw materials and products based on their allergen profile. This can be physical (separate zones, lines, storage) or in time (production separation and cleaning between production runs).
• Adjusting recipes to avoid allergens where possible.
• Selecting suppliers and raw materials based on reliable allergen information.
• Technical adjustments to equipment or layout to minimise transfer via surfaces, air or equipment.

Step 2: Raw material information and management

You need complete and up-to-date information on allergens in raw materials, additives and processing and technological aids. This information must indicate which allergens may be present (including cross-contamination from the supply chain).

To enable a quantitative risk assessment, information is needed on the amount of allergen. Cross-contamination is preferably expressed as mg protein of the allergen/kg raw material. This relates to homogeneous contamination.

This information must be regularly updated and reviewed, for example at least once every three years or whenever a product changes.

Step 3: Separation in place or time

Physical separation of product streams with different allergen profiles is one of the strongest barriers against cross-contamination. If physical separation is not feasible, separation in time applies. Where possible, plan production runs in ascending order of allergen content.

Step 4: Cleaning and validation

A cleaning plan alone is not enough. Cleaning must be validated. This means demonstrating that allergen residues remain under control after cleaning, even in worst-case situations. Validation includes:

• defining cleaning methods and frequency;
• taking samples in the most critical situations (high allergen content -> towards an allergen-free product);
• applying analysis methods suitable for detecting traces;

Equipment, means of transport and/or containers that have been used for substances or products causing allergies or intolerances may not be used for foods without these allergens unless they have been cleaned in between and checked for visible residues. Plan these cleaning moments and record them.

Step 5: Risk assessment

After implementing preventive measures, it is essential to carry out a risk assessment for each allergen separately. This involves adding up all sources of cross-contamination (information from raw materials plus your own process) and comparing this against the safe reference limit (ED05 reference dose) and the consumption quantity.

Ready for the stricter PAL legislation? Prevent risks with a strong allergen policy

The new PAL rules in the Netherlands from 1 January 2026 make clear that allergen warnings such as "may contain traces of" are no longer optional. Only scientifically substantiated statements are permitted, based on a risk assessment using ED05 reference values. This means that food companies not only need to update their labels, but above all need to strengthen their entire allergen management and cross-contamination prevention.

Belgian producers, too, would do well to start preparing now, especially if they export to the Netherlands. By focusing on prevention, accurate raw material information, process separation, validated cleaning and a well-substantiated risk analysis, you build a transparent and reliable food safety system.

Want to be sure that your business meets the latest expectations around allergen labelling, PAL, and cross-contamination prevention? This is a good time to review your allergen risk analysis and control measures.