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Understanding the international provision of allergen information picture in the non-prepacked sector

Executive Summary - Understanding international provision of allergen information

An overview of the background of the project, the methodology and the results.

Last updated: 12 September 2023
Last updated: 12 September 2023


RSM UK Consulting LLP (RSM) along with Dr Audrey DunnGalvin at University College Cork Consulting and members of Allergy UK, have been commissioned by the Food Standards Agency (FSA) to carry out a rapid evidence assessment into the international provision of allergen information associated with the sale of non-prepacked food. The aim of this review is to synthesise and summarise the evidence base, evaluating the current understanding of the international provision of allergen information in the non-prepacked sector. This research serves to support FSA and inform policy development and guidance in this area. 


To undertake this rapid evidence assessment, we first developed a search protocol to guide the literature search. On the basis of this, we searched for relevant academic and grey literature across all 18 countries within scope. A longlist of records was screened at title (N = 636) and abstracts of the included titles (N = 321) using the second-level inclusion and exclusion criteria in Appendix A (i.e. relevance to research questions or outcomes). This list was tested for relevance and robustness following the Department of Environment, Food and Rural Affairs (DEFRA) guidance for critical appraisal of evidence(footnote) and resulted in a shortlist of 56 articles for full extraction and narrative synthesis for each research question. 

We also sought to fill gaps in the reviewed literature and further develop our understanding of areas covered by the literature, and therefore we conducted 13 stakeholder interviews. Two workshops were undertaken with our panel including our academic advisor and representatives from Allergy UK, and FSA stakeholders. Conclusions, evidence gaps and areas for future consideration were triangulated across research themes.


There was limited or no evidence in the literature reviewed as to whether approaches are associated with improved safety, compliance, unintended consequences or feasibility. Table 1 provides a summary of key findings that address the study themes. We are conscious that much change is taking place in this area on an ongoing basis (with published literature not always being up to date with these developments) and this should be kept in mind when reading this report.

Table 1 Key findings to address study themes

Results theme Findings
Non-prepacked sector legislation
  • We were able to find legislation for nine of the 18 countries within the scope for this project, as well as for the EU region as a whole. 
  • Legislation provision varies across countries/ regions with five mandating written provision (Republic of Ireland, Lithuania, Norway, US and Canada), and in four regions/countries either written or verbal provision is accepted (Netherlands, Switzerland, UK as well as EU-wide except the countries mentioned earlier). 
  • No relevant legislation or guidance was found in English in Belgium, Denmark, Germany, Sweden, Australia, India, Malta, New Zealand or South Africa. However, EU countries follow EU legislation as a minimum requirement, which would apply to Denmark, Belgium, Germany, Malta and Sweden. 
Trends in related deaths or incidents
Enforcement process and capabilities
  • There was limited evidence regarding enforcement processes and capacity across the 18 in-scope countries and regions.
  • The literature found that verification of the use of PAL can be challenging as it is inconsistently interpreted and applied by food businesses(footnote).
Consequences of non-compliance
  • There is a large variation in the published rates of non-compliance across countries, ranging from 14% in Switzerland(footnote) to 88% in Ireland (albeit from 2017)(footnote)
  • There is little evidence on the consequences that FBOs have faced for non-compliance. The available evidence showed that in three countries, non-complying FBOs tend to face fines and/or are issued with written warnings.(footnote)(footnote)(footnote)
What works, for whom and why
  • Our review of the literature highlighted a gap in the current evidence which meant we couldn’t answer this question. 

Considerations for further research 

The literature reviewed does not provide evidence of ‘what works’ for different approaches, for example in terms of improved safety, compliance, unintended consequences, or feasibility. This means that we are unable to provide clear recommendations for FSA

We have instead gathered information on the ‘problems raised in the research’ including the challenge for inspectors to verify verbal information, the level of confidence amongst consumers with the verbal information provided by food businesses, the gap in awareness or understanding related to food allergies amongst staff and inconsistency in the interpretation and use of PAL by businesses and consumers alike. 

There were suggestions in the evidence on what may work including:

  • Increasing or improving the written provision of allergen information(footnote)(footnote)  
  • Standardisation of information provision, for example in terms of placement of allergen information and use of symbols(footnote)(footnote)
  • Introducing best practice or regulation for PAL and improving education for all stakeholders regarding interpretation and use of precautionary labelling(footnote) 
  • Address the potential resourcing gap faced by enforcement authorities(footnote) 
  • Better opportunities for food allergen training, particularly if self-paced, with real world examples and simple language(footnote)(footnote)

The above is not an exhaustive list of potential options to consider, and further research is required to develop other options. Further systematic reviews, evaluations or feasibility studies would be required before any potential solution is implemented.

It is important to also note that the strength of the evidence underlying the problems and potential solutions identified in this report from the reviewed literature varied, ranging from news reports, conference papers, published audits, official legislation and peer-reviewed academic literature with large mixed-method studies and systematic reviews.