“May Contain” Labels Are Finally Getting Rules — What the New Codex Guidance Means for Coeliacs

Big news from Geneva. On 7 July 2026, the FAO/WHO Codex Alimentarius Commission — the body that sets global food standards — adopted the first international guidelines for precautionary allergen labelling (PAL). That’s the “may contain” line you’ve squinted at on a thousand packets. And for the first time, gluten is formally part of that global framework.

What actually happened

At its 49th session (Geneva, 6–10 July 2026), the Commission adopted new PAL guidelines as an annex to the General Standard for the Labelling of Prepackaged Foods (CXS 1-1985). The core idea is simple and long overdue: “may contain” should be a risk statement, not a legal disclaimer.

Under the new guidance, a food business should only use a “may contain” statement after it has:

• put real allergen management measures in place, and
• run a science-based risk assessment showing that a meaningful residual risk remains.

The recommendations are built on reference doses for priority allergens developed through seven joint FAO/WHO expert consultations — and cereals containing gluten are on that priority list. The International Society for the Study of Celiac Disease (ISSCD) reports that the underlying food-labelling guidance sets a formal 4 mg gluten reference dose for precautionary labelling on gluten-containing cereals (ISSCD, 28 May 2026).

What does not change

The one number that matters most to us stays exactly where it was: “gluten-free” still means less than 20 ppm gluten. That threshold is unchanged in the EU, US, Canada, Australia, New Zealand and every Codex-aligned jurisdiction.

Codex was also clear that PAL statements and gluten-free claims do different jobs. A product labelled gluten-free must meet the <20 ppm standard regardless of any advisory wording near it.

Why this is genuinely good news

Right now, “may contain” labelling is unregulated in much of the world. Some manufacturers use it carefully; many slap it on everything as legal cover. The result is a label that tells you almost nothing — and shrinks your shelf for no measurable reason.

A risk-based system means:

• Fewer “just in case” labels. If a factory manages allergens properly and the risk assessment comes back clean, no PAL statement.
• More meaningful warnings. When a “may contain gluten” line does appear, it should reflect a genuine, assessed risk — not a lawyer’s reflex.
• Consistency across borders. The same logic applied in Rome, Toronto and Tokyo — which matters enormously when you travel.

What it means for your shopping trolley today

Honestly? Nothing changes on the shelf this week. Codex guidance is not law — national and regional regulators (the EU, FDA, FSANZ and others) now have to carry it into their own rules, and that takes time.

So our standing guidance holds:

• Anchor your choices to the gluten-free claim. A GF label is a regulated promise (<20 ppm). That’s your green light.
• Today’s “may contain traces” lines remain voluntary and inconsistent — especially in the EU — which is precisely the problem this reform exists to fix. They are not a gluten measurement.
• If a product carries a gluten-free claim and a precautionary line, the gluten-free claim is the regulated one.

What we’ll be watching

The interesting part starts now: how fast the EU, UK, US, Canada and Australia/New Zealand translate this into national labelling law, and whether the 4 mg reference dose survives implementation intact. We’ll follow it and explain each step as it lands — in plain language, as always.

Sources: FAO Newsroom, 7 July 2026 · Food Safety Magazine on CAC49 · ISSCD, 28 May 2026 · WHO: CAC49. Last verified 16 July 2026.