New Dutch allergen policy included in version 9.0 of NVWA handbook on labeling

23 January 2025

From January 1, 2026, the new Dutch allergen policy must be implemented. This policy will be ratified in the policy rule Warenwet allergen labeling out of precaution. This is currently not yet published, but will correspond to the policy document that has already been published. What does this now mean in practice for food companies?

Section 9.9 of the NVWA handbook on labeling.

This paragraph also existed in previous versions of the handbook, but has now been completely rewritten. The basic principle is now that a company takes preventive measures to avoid cross-contamination with allergens and that thereafter it must be assessed whether cross-contamination can still occur. Only if this is demonstrably the case and, moreover, leads to levels above the reference values set in the policy, may a precautionary allergen warning be placed. A so-called precautionary allergen labeling ( PAL).

The FNLI together with the CBL has created a guideline document - endorsed by the NVWA - containing 10 core elements that must be implemented in a food safety management system. These core elements are further explained in the guideline document and practical examples are given.

Implementation in practice

In practice, it often turns out that it is difficult to determine which processes now cause the most cross-contamination, how to properly determine what is left behind after cleaning, and how to map what allergens and cross-contamination allergens are in the house now.

However, you need to get started on the new allergen policy in time, because in a year's time, food companies must have substantiated which allergens may lead to cross-contamination above the reference values. Product packaging has also been updated.

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