From 1 January 2026, the Netherlands Food and Consumer Product Safety Authority (NVWA) will actively monitor the correct use of Precautionary Allergen Labelling (PAL) on pre-packaged foodstuffs. This follows from a new policy rule published on 25 April 2025, for which the NVWA outlined its enforcement approach on 18 December 2025.
The inspections focus not only on what is stated on the label, but also on the measures that companies take to prevent cross-contamination with allergens. A proper risk assessment therefore forms the basis for this.
PAL stands for Precautionary Allergen Labelling: a precautionary warning on the label regarding allergens that may inadvertently end up in a product, for example via production lines, machinery or handling.
The NVWA accepts two standard phrases:
It is important to note that PAL is not an additional safeguard or ‘safety margin’. According to the policy rule, PAL may in principle only be used where a substantiated risk assessment indicates that established reference values for allergens may be exceeded. Without such substantiation, PAL is not permitted.
For retailers, the new enforcement policy has clear implications on two levels.
Anyone who sells own-brand products or has them manufactured pre-packaged relies on the allergen information provided by suppliers. A PAL declaration without a proper risk assessment is vulnerable. But the reverse is equally true: no PAL declaration when there is a genuine risk is also incorrect.
The policy rule makes this explicit: the risk assessment takes precedence.
In fast-paced retail organisations – where suppliers, batches, recipes, production lines and label versions are constantly changing – inconsistencies are a constant risk. It is precisely in such environments that strict product specifications, version control and clear agreements on the application of PAL are essential.
This is most evident in supermarkets, but in fact applies to any retailer that sells pre-packaged products and/or own-brand goods.
There is often confusion about PAL in the craft and catering sectors. This is understandable, as many products are not sold pre-packaged.
Different rules apply to this category. The NVWA/VWS decision tree shows that products packaged at the point of sale (with a high turnover rate) are classified as not pre-packaged may be regarded as such. In that case, a full label is not required, but the following is:
Allergen information may be provided verbally for unpackaged products, provided that three conditions are met:
This is in line with the NVWA’s existing guidance for the hospitality and craft sectors.
Once a product is genuinely pre-packaged, it is therefore subject to the full labelling requirements. The NVWA decision tree explicitly states that (home-made) products sold frozen are considered to be pre-packaged and must be fully labelled.
In such situations, PAL may therefore indeed be applicable. Furthermore, the policy rule contains a specific provision for artisanal food products: PAL may be used if the risk assessment indicates that cross-contamination is possible in practice.
Finally, the NVWA announces that catering and craft businesses must be particularly vigilant regarding the labels for ingredients and (semi-)finished products. After all, this information forms the basis for accurate allergen labelling for consumers. The details of this are still being discussed with the Ministry, industry organisations, patient associations and the NVWA.
Under the new policy rule, the use of PAL less non-committal and more risk-driven. Pre-packaged products require verifiable evidence; for unpackaged products, clear and well-organised allergen information remains crucial. Those who get their processes, specifications and responsibilities in order now will avoid problems during inspections from 2026 onwards.
