Allergen Management and Food Labelling: A Checklist

Undeclared allergens are among the most common reasons for food product recalls worldwide, and for export-focused manufacturers in Pakistan a single labelling error can close a market. Good allergen management is not complicated, but it has to be deliberate. Use this checklist to test your system.

1. Know every allergen on site

• Keep an up-to-date allergen matrix listing each raw material and the allergens it contains, including those in sub-ingredients and carriers.
• Require suppliers to declare allergens and to notify you of any change.
• Check the allergen rules of every market you sell into; the lists of regulated allergens differ between countries.

2. Control cross-contact in production

• Store allergen-containing materials separately and label them clearly.
• Plan production so allergen-containing products run after allergen-free ones where possible.
• Validate your cleaning between allergen changeovers, and verify it with suitable tests.
• Control shared equipment, utensils and rework.

3. Get the label right every time

• Declare allergens clearly in the ingredient list, following the rules of the destination market.
• Approve every new label and every label change against the recipe and the allergen matrix.
• Check labels on the line at the start of every run and at each packaging change.

4. Use precautionary labelling honestly

"May contain" statements should be the result of a documented risk assessment showing cross-contact cannot be controlled, not a blanket disclaimer. Overuse of precautionary labels removes safe choices for allergic consumers and is increasingly questioned by auditors and regulators.

5. Train the people who make it work

Most allergen incidents trace back to a person who did not know a control existed or why it mattered. Operators, storekeepers, cleaners and the labelling team all need training matched to their role, and new starters need it before they work on the line.

6. Be ready for an incident

Test your traceability and recall procedure at least once a year, and make sure you know who decides, who communicates with customers, and how quickly you can identify affected batches.

QCS Global offers allergen management training, a Labelling Compliance and Nutritional Information course, and label review support for manufacturers preparing products for local and export markets.

Talk to QCS Global. Our team in Karachi runs public courses, in-house training and consultancy for food businesses across Pakistan. Email info@qcsglobal.org or call +92 337 2112775 (Monday to Saturday, 9 am to 5 pm), or browse our courses.