The 49th Session of the Codex Committee on Food Labelling (CCFL49), held in Ottawa, Canada in May 2026, delivered several significant outcomes for the global food industry. The most consequential development for manufacturers of gluten-free foods was the finalisation of the new Codex Guidelines on the Use of Precautionary Allergen Labelling (PAL), which were subsequently adopted by the Codex Alimentarius Commission (CAC49) in Geneva, Switzerland in July 2026. These guidelines aim to reduce the widespread and sometimes unnecessary use of precautionary statements such as “may contain” by introducing a science-based, risk-assessment approach to allergen management.
Beyond PAL, CCFL49 also agreed new provisions relating to multipack and joint presentation labelling, guidelines for food labelling during emergency situations, and country-of-harvest requirements for saffron. However, it was the allergen labelling work that attracted the greatest attention from gluten-free stakeholders.
A key achievement for the coeliac community was the specific inclusion of cereals containing gluten within the PAL framework. During the development process, gluten was not adequately represented; however, international advocacy and scientific consultation resulted in the establishment of a reference dose of 4 mg of gluten. Under the new approach, precautionary allergen labelling should only be applied where a documented risk assessment identifies a residual risk above established action levels after appropriate controls have been implemented. Importantly, the guidelines also clarify that a product bearing a precautionary statement for gluten cannot simultaneously make a gluten-free claim.
It is important to distinguish the new 4 mg gluten reference dose within the Codex PAL framework from the existing gluten-free threshold of ≤20 ppm. CCFL49 did not amend the established Codex limit for foods specially processed or formulated for people intolerant to gluten. Instead, it introduced a reference dose to support cross-contact risk assessment, meaning that the concentration associated with a 4 mg exposure will vary according to serving size:
- A 200 g serving at 20 ppm contains 4 mg gluten.
- A 100 g serving at 20 ppm contains only 2 mg gluten.
- A 50 g serving at 20 ppm contains only 1 mg gluten.
This distinction demonstrates why the PAL framework focuses on consumer exposure rather than concentration alone, as the amount of gluten ingested depends on both the level present and the quantity consumed.
For sites already certificated to BRCGS’ Global Standard Gluten-Free, the implications are not quite as significant. The Standard already requires robust allergen management, segregation, validation, and verification activities to demonstrate that products meet gluten-free requirements, and it does not permit the use of PAL statements referencing gluten-containing grains in conjunction with any of the five trademarks available under certification. The new Codex PAL framework reinforces the expectation that all manufacturers should manage gluten contamination through effective preventive controls, rather than relying on precautionary statements as a substitute for good manufacturing practices.
Non-certificated manufacturers will now need to strengthen their documented risk assessments, review analytical testing strategies, and ensure that allergen management plans align with the emerging Codex approach. Those that currently use PAL statements which reference gluten-containing grains on products marketed to gluten-sensitive consumers will face increased scrutiny, as the new guidelines clearly distinguish between precautionary labelling and legitimate gluten-free claims.
In the longer term, these developments are likely to influence regulatory frameworks and certification schemes worldwide. The adoption of risk-based PAL principles should enhance consumer confidence, reduce inconsistent allergen messaging, and support greater international harmonisation of gluten-free labelling requirements.