TÜV SÜD Shows How to Correctly Interpret “May Contain” Warning Labels


Munich. Consumers who depend on the declaration of food allergens will find “may contain traces of...” warning labels on a great number of food products. Warnings about traces of nuts, for example, are high up on the list of potentially present allergens. TÜV SÜD's food experts inform consumers what lies behind these warnings.

Food allergies, and people's awareness of them, are playing an increasingly important role. The government already responded to this development in 2011 by introducing regulations that numerous ingredients which are known to trigger food allergies or intolerance must be highlighted in bold print on food packaging. Since 2014, Regulation (EU) No. 1169/2011 on the provision of food information to consumers has regulated the labelling of allergens and extended it to non-prepacked food such as that available at service counters, as ingredients in food services or in online sale.

The food labelling regulation lists fourteen food products or food groups that are considered potential triggers of food intolerance or allergies. They include cereals containing gluten (e.g. wheat, rye), milk and dairy products, eggs, nuts (e.g. almonds, hazelnuts and pistachios), celery, mustard, sesame and lupins, and naturally all products made from these foods. If these foods are used as ingredients in a product, they must be included in the list of ingredients. This even applies if they constitute only one component in a blended ingredient e.g. mustard in a spice blend. However, besides this information many products today include “Contains traces of...”  or “May contain traces of...” warning labels.

This voluntary information provided by manufacturers has a different background from mandatory allergen labelling and refers to the unintentional presence of an allergenic foodstuff, the inclusion of which can occur during production. Such traces of food refer to quantities between the limit of detection and some milligrams per kilogram.

Example: A chocolate factory produces two types of chocolate, one with and one without nuts. In this case, traces of nuts may make their way into the nut-free chocolate, e.g. in the form of nut particles formed during handling of the nuts. As this type of “contamination” cannot be excluded in a factory with 100 per cent certainty, the manufacturer draws the attention of consumers to this fact by adding a “May contain traces of nuts” warning label. By doing so, manufacturers protect themselves against legal problems and liability claims should a consumer develop an allergic reaction to nuts.

“For people suffering from allergies, these warnings can be both boon and bane”, explains Dr Andreas Daxenberger, food expert at TÜV SÜD. While they improve the protection of allergy sufferers by offering additional information about “their” allergen which cannot be ruled out with certainty in the final product for technical reasons, they are also provided on products that contain only traces that are so minute, if indeed there at all, that they would actually be harmless even for allergy sufferers. “The most important information for allergy sufferers is the allergen labelling in the list of ingredients. For people who are classified as particularly sensitive by their treating doctor, the "May contain traces of...” warning can also be important”, explains Daxenberger. “If more detailed information is required for medical certainty, consumers can contact the producer directly.” However, very few consumers suffer from such serious forms of allergy. Given this, the “May contain...” warning by no means indicates that a food product is dangerous or should be approached with caution. 

Not to be confused with food allergy is food intolerance to gluten, a protein found in many cereals, and lactose, a type of sugar found in milk and dairy products. Following the consumption of gluten-containing cereals, patients suffering from coeliac diseases react with bowel irritation. Food products that contain gluten at a level of under 20 mg/kg may be referred to as “gluten free”. Their gluten content is so low that people suffering from coeliac disease need fear no adverse effects.

Adults’ ability to digest lactose varies; while relatively widespread among Europeans (“Caucasian gene pool”), this ability has not automatically evolved in every individual. However small quantities of lactose can be consumed by anybody without any problems. In Germany, it is now common practice that food products with under 0.1 g of lactose per 100 g of food product may be identified as lactose-free.

The information “lactose free” and “gluten free” refers to lactose and gluten intolerance, but does not cover milk or cereal components as ingredients, which may trigger allergies in some people.

Within the scope of its certification procedures, TÜV SÜD carries out assessments according to recognised food-safety standards (e.g. International Food Standard, FSSC 22000), verifying that companies implement the necessary measures to avoid allergen contamination and correctly handle the identification of allergenic ingredients and allergen labelling.

Further information on food safety can be found at: www.tuv-sud.com/foodsafety.