At the December 2025 UK Food Standards Agency (FSA) Board Meeting, FSA recommended to the Board that the agency support Codex proposals on precautionary allergen labeling (PAL) and seek to establish a baseline for PAL in the UK.

The Codex Committee on Food Labeling has recommended an eliciting dose 05 (ED05) threshold for PAL, meaning that the level of potential allergen contamination of a food requiring PAL should be based on the dose at which 5 percent of people with the relevant allergy would be likely to react.

Studies have suggested that PAL based on an ED05 threshold would be largely protective of consumers, likely only eliciting non-severe reactions in a small proportion of the allergic population.

FSA raised concerns about Codex proposals regarding gluten and labeling for people with celiac disease, as PAL thresholds are based on amount of protein per portion size whereas the existing gluten threshold (for gluten free labeling) is based on a concentration irrespective of amount consumed. However, FSA said it expects this gap to be resolved through the Codex process.

In fact, as of December 1, 2025, an ad hoc committee convened by the Food and Agriculture Organization of the United Nations (FAO) and World Health Organization (WHO) recommended a gluten reference dose (RfD) for gluten and cereals containing gluten in a risk-based PAL framework to protect people with both celiac disease and wheat allergies.

FSA recommended to the Board that the agency support progression of PAL updates to the Codex Alimentarius General Standard for the Labeling of Pre-Packed Foods, which is recommended for approval and adoption at the Codex Alimentarius Commission (CAC) meeting in July 2026, and that the UK subsequently be aligned with the approach set forth in Codex proposals.

Regardless of whether FSA agrees to align the UK with Codex PAL recommendations, however, FSA stressed that the UK should establish a baseline for PAL.