Allergen management is a shared responsibility across procurement, production and labelling. The same protein that is a routine ingredient in one product is a hazard in the next one down the line, so the controls that matter are the ones that follow the material through the site.
Allergens that must be declared
Food regulations name a set of allergens that must always be declared when present as an ingredient, a component of an ingredient, or a processing aid. The list varies between markets, so businesses exporting product need to work to the requirements of every destination.
Cereals containing gluten, including wheat, rye, barley and oats
Crustacea, molluscs and fish
Egg, milk, peanut and soy
Tree nuts, sesame and lupin
GOOD PRACTICE
Record allergen status against every raw material, not every finished product. When a supplier changes a formulation, the raw material record is the only place the change can be caught before it reaches a label.
Where cross contact happens
Cross contact is the unintended transfer of an allergen from one food to another. It is rarely a single failure. More often it is an accumulation of small ones: shared equipment, airborne dust, rework, and staff movement between lines.
SHARED PLANT
Lines, hoppers and conveyors used for more than one recipe.
REWORK
Product returned to a batch that does not share its allergen profile.
PEOPLE
Movement between areas without a change of gloves or garments.
Assessing the risk
A risk assessment quantifies how much allergen protein could realistically end up in a serving of the finished food. VITAL provides a standardised way to do that work, using reference doses derived from clinical data to decide whether a precautionary allergen labelling statement is warranted.
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Last updated 01 Jul 2026
VITAL 4.0 Summary and FAQs
An overview of the updates to the Voluntary Incidental Trace Allergen Labelling (VITAL) program, reflecting the recommendations of the FAO/WHO Expert Committee to Codex and ensuring the VITAL Program remains at the forefront of best practice evidence-based science.
The outcome of the assessment belongs on the label in plain, consistent language. Precautionary statements should only be used where a credible risk remains after controls have been applied. Used indiscriminately, they narrow the range of food available to allergic consumers without making anyone safer.
Members can access the full labelling decision framework, worked examples, and template records through the Allergen Bureau resource library.