‘May contain’ - the flaw in gluten free food labelling

I believe there is a problem with the way we label gluten free food in the UK, leaving people with coeliac disease trying to make safe decisions with incomplete information.

Walk down a supermarket aisle and you will find products carrying warnings such as ‘may contain wheat’, ‘made in a factory that handles wheat’ or ‘may contain traces of gluten’. Some reflect a genuine risk of cross-contamination, others may carry precautionary warnings despite effective controls being in place.

The consumer has no reliable way of knowing the difference, that is the flaw.

Perhaps the biggest problem with ‘may contain’ labelling is how much the final decision depends on the manufacturer's own judgement. In the UK, precautionary allergen labelling is voluntary. Manufacturers are expected to assess the risk of cross-contamination, but there is no single, universally applied threshold that determines when a warning must appear on a pack.

Imagine two factories producing the same product. They use the same ingredients, follow comparable manufacturing processes and have similar cleaning procedures. Both carry out risk assessments, but their technical managers reach different conclusions.

One decides that the possibility of cross-contamination warrants a ‘may contain gluten’ warning. The other concludes that its controls are sufficient and no warning is necessary. The consumer is left with two ostensibly equivalent products, one carrying a warning and the other not.

Of course, different production environments can present different risks, and legitimate differences should be reflected in the information consumers receive. But when the difference comes down to interpretation, organisational caution or an individual manager's assessment, the system becomes difficult to justify.

A consumer cannot see the difference between a warning based on a genuine, material risk and one driven primarily by a manufacturer's approach to precaution.

The label appears to communicate a clear safety message. In reality, it can communicate as much about the manufacturer's decision making as it does about the product itself.

There is of course a huge risk if these declarations are underused.

If a manufacturer fails to communicate a genuine risk of cross-contamination, a consumer may reasonably assume that the absence of a warning means the risk has been properly assessed and adequately controlled.But the absence of a ‘may contain’ statement does not, by itself, prove that a thorough assessment has taken place or that every relevant risk has been eliminated.

For people with coeliac disease, this matters.

Manufacturers have a responsibility to identify and manage cross-contamination risks, and where a meaningful residual risk remains, consumers deserve to know about it. A voluntary warning system that relies on manufacturers making their own decisions needs robust oversight. Otherwise, the absence of a warning can provide reassurance that the evidence may not justify.

The opposite problem is overuse.

Manufacturers may apply precautionary statements broadly because they handle wheat elsewhere on site, share equipment or simply want to take the safest possible approach from a legal or commercial perspective. But a warning should not be a substitute for effective manufacturing controls. Nor should it be applied automatically just because an allergen is present somewhere in a factory.

Good manufacturing practice should come first: appropriate segregation, cleaning, handling procedures and evidence based risk assessment. Precautionary labelling should communicate a genuine residual risk that cannot adequately be controlled.

When warnings are applied unnecessarily, they restrict consumer choice and risk losing their meaning.

For someone following a strict gluten free diet, every additional warning can mean another product to investigate, another ingredient list to scrutinise and another potential staple removed from the shopping basket. It can also make an already expensive and restrictive diet more difficult to manage.

If too many products carry warnings, consumers are left asking whether each one represents a genuine risk or merely a manufacturer's preference for caution.

When everything carries a warning, the warning itself becomes less useful.

That is not good consumer protection. It is a system that risks both unnecessary restriction and misplaced reassurance.

Part of the problem is that the language used on packaging does not always help consumers understand the distinction between wheat and gluten.

Under UK rules, a food can be labelled ‘gluten free’ if it contains no more than 20 parts per million (ppm) of gluten. This includes products made with suitable specially processed ingredients, such as gluten free wheat starch.

Consequently, a product can legitimately carry a ‘gluten free’ claim alongside a ‘may contain wheat’ warning.

These statements are not necessarily contradictory. Wheat is relevant to both coeliac disease and wheat allergy, but the two are different conditions. A warning about potential wheat contamination does not automatically establish that a product exceeds the gluten free threshold.

Equally, a gluten free claim must be supported by appropriate controls. The 20 ppm threshold is not permission to be careless about cross-contamination, and a label cannot compensate for poor manufacturing practice.

The point is that a generic warning often fails to communicate what consumers with coeliac disease actually need to understand: the nature of the potential risk and whether the product meets the requirements for gluten free food.

Consumers should not have to become experts in allergen management just to understand the food in their supermarket basket.

So, how do we fix it?

The answer is not to abolish ‘may contain’ labelling. Where a genuine, unavoidable risk remains, people deserve to be told.

The answer is to make the system more consistent, transparent and accountable…

First, standardise the risk assessment.

Manufacturers need a clear, evidence based framework for deciding when precautionary labelling is appropriate. That framework should establish consistent criteria for assessing cross-contamination, taking account of the ingredients, production environment, cleaning procedures and effectiveness of controls.
The aim should not be to force every factory to use identical labels regardless of its circumstances. It should be to ensure that materially similar risks are assessed consistently, with clear reasons for any differences.

Second, make manufacturers accountable for their decisions.

Businesses should be able to demonstrate why a warning is present, or why it is absent, through documented risk assessments and evidence of appropriate controls. Those assessments should be reviewed when ingredients, suppliers, equipment or production processes change.
Regulators should be able to challenge unjustified warnings just as they challenge failures to communicate genuine risks.

Third, improve the information available to consumers.

Standardised wording could help distinguish between different types of cross-contamination risk. Where appropriate, clearer information about the basis for a warning could help consumers understand what it means.
This does not mean printing a full technical risk assessment on every packet. It means developing a system in which the wording on the front of the pack reflects a consistent and defensible assessment behind it.

Finally, better access to reliable product information could reduce the burden on consumers, who too often have to contact manufacturers individually to clarify whether a product is suitable.

These are practical improvements, not demands for zero risk. No food production system can guarantee that risk is entirely absent in every circumstance. But the industry should be able to communicate the risks it identifies in a way that is consistent, proportionate and useful.

Living gluten-free already requires constant attention. Ingredients must be checked, labels must be read and cross-contamination must always be considered.

That burden should not be made heavier by a labelling system that offers warnings without sufficient consistency or clarity.

The fundamental problem is not simply that ‘may contain’ labelling is voluntary. It is that manufacturers have considerable discretion over when to use it, and consumers have little insight into how those decisions are reached.

One manufacturer may warn against a product while another, producing something materially similar, may not. Some genuine risks may go uncommunicated, while unnecessary warnings can needlessly narrow the choice available to people who rely on gluten free food.

The result is a system in which consumers are expected to trust labels that do not always provide a consistent basis for comparison.

Manufacturers must retain responsibility for assessing the risks in their own facilities. But that responsibility needs to sit within a clearer, more consistent framework, backed by effective oversight.

People with coeliac disease should not have to guess whether a warning reflects a meaningful risk, nor should they have to wonder whether the absence of one tells the whole story.

A warning should mean something. The absence of a warning should mean something, too.