“May Contain Traces”: What It Means for Allergies

A "may contain traces" warning tells you that an allergen which is not an ingredient may have got into the food by accident during production. In the EU it is a voluntary label with no uniform rules, so the absence of a warning does not guarantee that a product is free of the allergen. If you have an allergy, treat a warning about "your" allergen as a real warning, and with a serious allergy it is better to avoid the product or talk to your doctor.

What such a warning means

Allergens that are an ingredient of a product must be highlighted in the ingredients list (for example in bold). This is required by Regulation (EU) No 1169/2011. The list covers 14 allergens, see the 14 EU allergens.

A "may contain traces" warning is a different case. It concerns the unintentional presence of an allergen that got into the product, for example:

• from a production line where other products were processed earlier,
• from shared equipment (grinders, conveyors, containers),
• from dust and residues of raw materials in the factory,
• from raw materials that the supplier processes together with allergens.

The technical term is precautionary allergen labelling (PAL).

Why it is voluntary

Regulation 1169/2011 does not require manufacturers to state the possible unintentional presence of allergens, and it does not say what wording they should use. Under Article 36 of the regulation, voluntary food information must not be misleading, must be clear and, where appropriate, must be based on scientific data. But the EU has no precise rules on when a manufacturer should include such a warning.

This has several practical consequences:

• Different manufacturers use different wording, for example "may contain traces", "made in a facility that processes" or "may contain".
• Some manufacturers include the warning as a precaution even when the risk is low.
• Others do not include it at all, even when a risk exists.
• You cannot always tell from the wording how big the risk is.

What it means for you

A missing warning is not a guarantee. A warning that is present is not a measure of quantity. That is why it matters what type of allergy you have.

Situation	How to handle the warning
Serious allergy, past anaphylaxis	Do not eat a product with a warning about your allergen unless your doctor has told you otherwise.
Allergy with mild symptoms	Follow your allergist's individual advice.
Coeliac disease	What matters is the "gluten-free" label (no more than 20 mg/kg). See Hidden gluten.
Intolerance	Tolerance is individual, so a doctor or dietitian should decide.

There is no point guessing your own tolerance for traces of an allergen. Sensitivity varies greatly between people, even with the same allergy. The right answer is therefore always individual, with a doctor or allergist.

Traces and the "gluten-free" label

For coeliac disease there is a separate rule. In the EU a food can carry the "gluten-free" label if it contains no more than 20 mg of gluten per kilogram. This is a legally defined limit, set by Implementing Regulation (EU) No 828/2014. Traces of gluten in a product labelled "gluten-free" are therefore judged against this limit. For more on oats see Oats and coeliac disease.

Traces in a restaurant

A restaurant dish has no packaging. Non-prepacked food, meaning food prepared for you on the spot, is covered by the rules for non-prepacked food: the restaurant must provide information about ingredients that belong to the 14 allergens. There are no rules there for the unintentional presence of traces. Contamination can arise on a shared board, in shared oil or on the same knives and pans.

So with an allergy in a restaurant, ask not only about the ingredients but also about how the dish is prepared. Recommended questions are in How to ask about allergens in a restaurant. Restaurant owners will find tips in Allergen labelling in restaurants.

Why manufacturers give traces warnings

The reason is usually practical. The manufacturer knows that several allergens, such as milk, nuts and gluten, are processed in the factory, and completely separating the lines is not possible or not affordable. Even with thorough cleaning, a small amount of residue can remain. The warning is then a way of alerting consumers.

Responsible manufacturers should give the warning on the basis of a risk assessment, not across the board just to be safe. The consumer, however, cannot check on what basis the manufacturer did or did not give a warning. That is why, with a serious allergy, it is sensible to ask the manufacturer directly.

Tips for reading labels

1. Read the whole pack, not just the ingredients list. The warning is often below the ingredients or next to the best-before date.
2. Check every time you buy. Recipes, suppliers and production lines change.
3. Do not compare products by which wording sounds milder. "May contain" and "made in a facility that processes" often mean the same thing.
4. If in doubt, ask the manufacturer. The contact details are usually on the pack. A customer helpline can often tell you whether an allergen is processed on the same line.
5. Talk to your doctor. With serious allergies in particular, the right decision is individual.

Traces and common allergens

A traces warning most often appears for peanuts, tree nuts, milk, soy, sesame, eggs and gluten. These are allergens that are processed in huge numbers of foods and are easily carried between lines. Chocolate, biscuits, muesli, baked goods and plant-based milk alternatives are typical examples. If one product warns about traces and a similar one from another manufacturer does not, that does not mean the second is better. It may simply mean a different approach to labelling.

Traces and children

Parents of children with a food allergy often ask whether they can give their child a product with a traces warning. There is no single answer: it depends on the type of allergy, its severity and the child's experience. A decision like this belongs to an allergist who knows the child. Until then, it is safer to leave out products with a warning about the child's allergen.

How AvoiDino can help

In AvoiDino you set your allergens and narrow down dishes accordingly. The app does not replace reading labels or asking the staff. With an allergy, always check the specific product or dish.

Frequently asked questions

What does "may contain traces" mean?

It means that the allergen is not among the ingredients, but it may have been transferred unintentionally during production. It is a voluntary warning from the manufacturer.

Is a "may contain traces" warning mandatory?

No. Only the labelling of allergens that are an ingredient is legally required. Labelling of possible contamination is voluntary and is not regulated uniformly.

Is a product without a traces warning safe?

No, the absence of a warning guarantees nothing. The manufacturer does not have to include one even when a risk exists. With a serious allergy, it is sensible to check with the manufacturer or talk to your doctor.

Can I eat a product with a warning about my allergen?

That depends on your allergy and your doctor's advice. With a serious allergy, people are generally advised to avoid such products. The decision should be individual.

Is "may contain traces of gluten" the same as "gluten-free"?

No. "Gluten-free" is legally defined by a limit of 20 mg/kg, and a product with a traces-of-gluten warning does not usually carry it. With coeliac disease, look for an explicit "gluten-free" label.

Sources

• Regulation (EU) No 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers, Annex II and Articles 21, 36 and 44.
• Commission Implementing Regulation (EU) No 828/2014 on the requirements for the provision of information to consumers on the absence or reduced presence of gluten in food.
• Muraro A. et al.: EAACI Food Allergy and Anaphylaxis Guidelines. Allergy, 2014.

This information is general and does not replace medical advice. If you have an allergy, always check the ingredients with the staff.