Allergen Management in Food Manufacturing
How to stop undeclared allergens reaching consumers, one of the most common causes of product recalls
Undeclared allergens are among the most common causes of food recalls worldwide. Unlike many other hazards, a very small amount can trigger a serious reaction in a sensitive consumer. That is why food safety schemes such as FSSC 22000 and BRCGS require a documented allergen management programme covering the whole value chain, from supplier to label.
1. Which allergens must be managed?
Mandatory lists differ by market, but the main allergens in common include:
| Group | Examples |
|---|---|
| Cereals containing gluten | Wheat, barley, oats (depending on legislation) |
| Milk and milk products | Milk, butter, whey powder |
| Egg | Egg and egg derivatives |
| Peanut | Peanut butter, unrefined peanut oil |
| Tree nuts | Almond, cashew, pistachio, hazelnut |
| Sesame | Tahini, sesame oil |
| Fish, crustaceans and molluscs | Tuna, shrimp, squid |
| Soy | Soybeans, soy lecithin |
| Others by market | Mustard, celery, lupin, sulphites |
The list must be based on the legislation of the countries of sale, such as the GCC technical regulations on food labelling, EU Regulation 1169/2011 or US requirements.
2. Allergen risk assessment
2.1 The allergen map
A table linking every raw material, product and production line to the allergens it contains or may be exposed to.
2.2 Sources of cross-contact
- Raw materials: cross-contact at the supplier. Ask the supplier for an allergen statement for its site.
- Shared lines: a product with nuts followed by a nut-free product on the same line.
- Powders and dust: flour or milk powder carried in the air.
- Rework: reworked product added to another product that does not contain the same allergen.
- Utensils and cleaning equipment.
- People: clothing, hands, and food brought into the plant.
3. Practical controls
| Control | Application |
|---|---|
| Segregation | Allergen-containing materials stored in dedicated, colour-coded areas |
| Scheduling | Allergen-free products made first, allergen-containing products after |
| Validated cleaning | Cleaning procedures proven to remove the allergen, verified by rapid or laboratory tests |
| Rework control | “Like into like” only |
| Dedicated utensils | Colour-coded tools for each allergen group |
| Label control | Label reviewed at every recipe change and checked at the start of each run |
| Supplier management | Allergen questionnaire and immediate notification of any change |
4. Validating and verifying cleaning
Validation proves that a cleaning procedure can remove the allergen to an acceptable level. It is done once when the procedure is approved or changed, using specific protein tests or ELISA.
Verification confirms the procedure is applied as written every time, through visual inspection, records and periodic tests.
This links directly to the concepts of HACCP validation and verification.
5. Precautionary labelling
Statements such as “may contain traces of…” should be used only when the risk assessment shows a cross-contact risk that cannot be fully controlled, not as a substitute for controls. Overuse limits choices for allergic consumers and weakens their trust in labels.
6. Crisis management
- A clear withdrawal and recall procedure if an undeclared allergen is found.
- Regular traceability mock exercises.
- Root cause analysis of every incident, and an update to the risk assessment.
Conclusion
Allergen management is not a chart on the wall but a complete system that starts with the supplier, runs through storage, scheduling and validated cleaning, and ends with a correct label on every pack. A mistake can cost a life before it costs a recall.
Check today: did your last recipe change reach both the label and the allergen map?
FSSC 22000 Version 7 Readiness Checklist
A two-page gap check of the Version 7 additional requirements: purchasing, labelling, food defence, food fraud, allergens, culture, quality control, equipment and more.