Food In Canada

Focus on Food Safety: Making “may contain” meaningful

By Ron Wasik   

Food Safety Packaging Allergen management Editor pick food allergies Food Allergy Canada food labelling Precautionary allergen label

Photo © eldarnurkovic / Adobe Stock

Food allergies affect over three million Canadians and 50 per cent of households. Consumers with food allergies and those that purchase products on their behalf (family, friends, schools, daycares, etc.) depend on having complete, easy-to-understand and accurate labelling that they can trust.

Consumer perspective

Deciding what to eat is complicated for consumers with food allergies. The challenge is to assess what might be in a product, as indicated by the precautionary allergen label (PAL), or the “may contain” statement. For some people, “may contain” means the product likely has the said ingredient, and others may assume it is not the case and that manufacturers are attempting to cover legal liability. Yet, research has shown that in some cases where PAL is used, there is no detectable level of the allergen. In other instances, the amount of an allergen was found to be at a level that would require it to be listed as an ingredient, but instead, was listed in a PAL statement. Based on this research, some consumers may be unnecessarily limiting food choices, while others may take unnecessary risks.

Industry perspective


Allergen management in the food industry is usually integrated into a company’s food safety program. While clear regulations exist on the labelling of priority allergens (eggs, milk, mustard, peanuts, crustaceans and molluscs, fish, sesame seeds, soy, sulphites, tree nuts, wheat and triticale) as ingredients, food processors can exercise considerable discretion when declaring any of these allergens if they had inadvertently entered the product. This has led to the overuse of PAL and rendered “may contain” confusing. At the same time, food allergen labelling generates the largest percentage of food recalls, accounting for approximately 35 per cent of the total.

Addressing the issue

To help consumers and Canada’s food industry address these issues, Food Allergy Canada, in collaboration with Université Laval, Que., Maple Leaf Foods and Health Canada, is working with the food industry, academia, healthcare and government to develop the following resources:

  • Voluntary, consensus-based industry guidelines on allergen risk management using a risk-based approach following the Codex risk analysis framework (i.e. identify, assess, prevent/control, communicate).
  • Guidance on the application of precautionary allergen labelling in order to make this a useful and meaningful tool that consumers with food allergies can trust. Training tools for all levels of manufacturers.
  • Consumer education framework. Funding for this initiative is being provided through Agriculture and Agri-Food Canada.

This collective effort aims to advance food safety practices and to make “may contain” statements meaningful.

For consumers, this means greater confidence in the safety of the products they are purchasing.

For food manufacturers, this means enabling safe food choices through industry-informed allergen risk management practices and accurate labelling with the lowest levels of risk, while providing product options that are suitable for the maximum number of consumers.

Get involved

Food Allergy Canada and Université Laval are reaching out to the food industry to better understand their current approach to managing allergens and the use of precautionary allergen labelling. They have developed a survey geared toward food manufacturers/processors who create prepackaged food products for the Canadian market. To access the survey, please visit After the survey is completed, all participants will receive a summary report.

By participating in the survey, you will contribute toward the development of voluntary industry guidelines that support food safety and labelling practices in Canada. The findings will also help inform the next phase of the project, which will focus on the development of industry training and resources to support the rollout of the guidelines. Additionally, the survey also allows participants to provide recommendations/feedback to regulators regarding the support needed by industry, as it pertains to allergen risk management.


This collaborative initiative will help the food industry maintain and build public trust and consumer confidence in food products. It will also have a long-lasting impact on the safety of food products and enable consumers to make informed, safe food choices. If you are interested in learning more about this initiative, please reach out to project manager Beatrice Povolo at

Dr. R.J. (Ron) Wasik, PhD, MBA, CFS, is president of RJW Consulting Canada. Contact him at

This article was originally published in the July/August 2021 issue of Food in Canada

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