“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, the UK, the US and Canada. In Australia and New Zealand, “gluten-free” still means no detectable gluten.
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.
| Aspect | Today’s “may contain” | Under the new Codex guidance (2026) |
|---|---|---|
| Basis for the label | Often a blanket legal disclaimer, added just in case | A risk statement, used only after real allergen management and a science-based risk assessment |
| Gluten reference dose | None: no agreed threshold behind the wording | A formal 4 mg gluten reference dose for gluten-containing cereals |
| Consistency across borders | Voluntary and inconsistent, especially in the EU | One shared logic across Codex-aligned jurisdictions |
| The “gluten-free” claim | Regulated: under 20 ppm gluten (Australia and New Zealand: no detectable gluten) | Unchanged: still under 20 ppm gluten |
| What it means for you | Anchor to the gluten-free claim; how to read a “may contain” line depends on your country (see below) | Not law yet: regulators must adopt it; for now, keep anchoring to the gluten-free claim |
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 (under 20 ppm; in Australia and New Zealand, no detectable gluten). 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, and how to read them depends on where you shop. In the EU, a may-contain line on its own does not rule a product out: the ingredients list and the gluten-free claim decide. In the UK, Coeliac UK advises not to eat a product that carries a “may contain” line for cereals containing gluten and has no gluten-free claim. In Canada, Celiac Canada recommends avoiding products with a “may contain” statement for barley, rye, regular oats, wheat or triticale.
- 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.
“May contain” rules by country
The rule depends on where you shop. Each line links to the full rules for that country.
- United Kingdom: we follow Coeliac UK: without a gluten-free label, leave products that “may contain” a gluten cereal. A gluten-free label still means 20 ppm or less.
- Ireland: EU rules: “may contain” is voluntary and no rule; the ingredient list and a gluten-free label decide.
- United States: we follow the Celiac Disease Foundation: a gluten-free label decides; on grain products without one, skip “may contain” or “shared equipment” wheat or gluten.
- Canada: we follow Celiac Canada: avoid “may contain” wheat, barley, rye, regular oats or triticale, unless the pack is labelled gluten-free.
- Australia: we follow Coeliac Australia: avoiding these products is the most cautious choice, and we always let a “gluten free” label take precedence.
- New Zealand: we follow Coeliac New Zealand: ask the manufacturer rather than avoid automatically, and we always let a “gluten free” label take precedence.
- Europe (EU): EU rules: “may contain” is voluntary and no rule; the ingredient list and a gluten-free label decide.
- Germany: EU rules: “may contain” is voluntary and no rule; the ingredient list and a gluten-free label decide.
- Austria: EU rules: “may contain” is voluntary and no rule; the ingredient list and a gluten-free label decide.
- Italy: EU rules: “may contain” is voluntary and no rule; the ingredient list and a gluten-free label decide.
- Switzerland: we follow IG Zöliakie: the note mainly protects the maker, so leave the product as a precaution only if you know you react strongly to small amounts; we always let “glutenfrei” take precedence.
Sources: FAO Newsroom, 7 July 2026 · Food Safety Magazine on CAC49 · ISSCD, 28 May 2026 · WHO: CAC49. Last verified 16 July 2026.
Reviewed against the HTGF methodology: every claim sourced, every listing tiered and dated. This article is practical guidance, not medical advice.
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