The New Dutch Allergen Enforcement Standard: What Changes in PAL from 2026

What is the Dutch Allergen Law?

The Dutch allergen law is based on EU Regulation (EU) No 1169/2011 on food information to consumers. This regulation requires food businesses to inform consumers accurately about allergens present in food.

In the Netherlands, the NVWA (Nederlandse Voedsel- en Warenautoriteit) enforces these rules and issues national guidance on how businesses should apply them in practice. This includes how allergens must be declared, how cross-contamination risks should be managed, and when Precautionary Allergen Labelling (PAL) such as “may contain” statements may be used.

When does the Dutch Allergen Law apply?

The obligation to provide allergen information has applied for many years. The difference now is that this new allergen standard will change the way allergen risks are assessed, documented and communicated.

What’s new in 2026

From 1 January 2026, the NVWA will actively enforce the new Dutch allergen policy and guidance on cross-contamination and precautionary allergen labelling.

This policy has been developed and supported by Dutch authorities and sector organisations to create a more consistent and risk-based approach to allergen communication.

This is not a new law, but a new enforcement standard. This means that businesses are expected to apply and demonstrate the guidance from this date onward.

Who & what does the allergen law apply to?

The rules in general apply to all food businesses operating in the Netherlands, including:

• Food manufacturers and processors

• Importers and traders

• Retailers and private-label owners

• Hospitality businesses (restaurants, bakeries, catering, food trucks, markets)

It applies to:

• Prepacked food

• Non-prepacked food

• Allergen ingredients

• Allergen cross-contamination risks

If you place food on the Dutch market or sell food to consumers, you are in scope.

What is new?

This is not a new law, but a newly enforced Dutch allergen policy and guideline. From 1st of January, the NVWA expects food businesses to apply this policy in practice and will enforce against it.

The new standard, applying January 1st 2026 entails:

1. PAL (Precautionary Allergen Labelling) New Rules

Before:

• Many companies used precautionary allergen labelling (PAL) like “may contain nuts” as a general warning, often without a documented risk assessment.

From 1 January:

• PAL may only be used if it is justified by a documented risk assessment.

• You must show that:

  • Cross-contamination cannot be prevented despite reasonable control measures

  • The remaining risk exceeds defined reference doses

    
    

2. Risk assessments must be science-based and documented

Before:

• Allergen risk assessments were often informal, undocumented, or inconsistent.

From 1 January:

• Companies must perform structured allergen risk assessments using:

  • Defined reference doses for allergens

  • Process and cross-contact analysis

  • Cleaning validation and supplier information

• The assessment must be documented and verifiable during NVWA inspections.

If you can’t show the risk assessment, the warning is considered non-compliant.

3. National alignment on allergen reference doses

What’s new:

• The Netherlands has adopted specific reference doses for allergens to determine whether PAL is justified.

• This creates one national standard instead of company-by-company interpretation.

Businesses must now justify allergen warnings against these reference doses, not internal assumptions.

4. Clearer distinction between ingredients and cross-contamination

Before:

• Ingredient allergens and cross-contamination risks were sometimes treated the same.

From 1 January:

• Ingredient allergens must always be declared (this has not changed).

• Cross-contamination allergens:

  • Require a risk assessment

  • May only be communicated via PAL if justified

5. Stronger expectations for supplier allergen information

Before:

• Supplier allergen data was often accepted at face value.

From 1 January:

• Companies must:

  • Verify supplier allergen information

  • Understand upstream cross-contamination risks

  • Include allergen risks in supplier approval and monitoring

You are responsible for the accuracy of allergen information, even if it comes from suppliers.

6. Enforcement focus by the NVWA

From 1 January onwards, the NVWA will:

• Actively check:

  • Whether PAL statements are justified

  • Whether allergen risk assessments exist and are up to date

• Treat unjustified PAL as misleading food information, not “extra safety”.

This means higher risk of enforcement actions if companies haven’t adjusted.

What has not changed in the allergen law

• The list of 14 mandatory allergens remains the same.

• Allergen declaration for ingredients is still mandatory.

• The obligation to inform consumers accurately has always existed.

  
  

What has changed is how strictly and consistently the rules are applied.

What information must be provided

Pre-packed food

• Allergens must be declared on the label.

• They must be clearly highlighted in the ingredients list (e.g. bold, capitals or underline).

• The information must be accurate and based on actual ingredients and processes.

  
  

Non-prepacked food (e.g. horeca, fresh counters)

• Allergen information must be available to the consumer.

• It may be provided in writing or orally, but:

  • The business must always have the information documented.

  • Staff must be trained to provide correct information.

  • The consumer must be clearly informed that allergen information is available.

    
    

What impact does this allergen law have on businesses?

The impact is significant, especially for companies that rely on generic allergen warnings.

• More documentation required

  Allergen risk assessments, supplier information and decisions must be recorded and kept up to date.

• Greater responsibility for supplier data

  Businesses remain responsible for allergen accuracy, even when information comes from suppliers.

• Higher enforcement risk

  NVWA inspections will explicitly check whether allergen warnings are justified.

The NVWA actively inspects allergen compliance. Incorrect or missing allergen information is considered a serious food-safety violation.

Consequences may include warnings or fines, mandatory corrective actions, product recalls & even business closure in severe cases.

Where should companies start now?

To prepare for 2026, companies should start with:

1. Review current allergen statements: Identify where PAL is used and whether it is justified.

2. Perform allergen risk assessments: Focus on cross-contamination risks and existing control measures.

3. Check supplier allergen information: Verify accuracy and understand upstream risks.

4. Document decisions clearly: Ensure assessments and conclusions can be shown during inspections.

5. Align internal teams: QA, procurement, product development and operations should all understand the new expectations.

Starting early reduces the risk of rushed changes close to the enforcement deadline.

Where does Agriplace fit in?

Agriplace’s role is to help companies collect, centralise, and standardise supplier documentation and product data, so they can find gaps faster and reduce manual document management. In practice, Agriplace’s AI document extraction can already pull key fields from finished product specifications and technical data sheets including allergens and the complete ingredient list.

These new expectations push companies to go deeper than what is typically written in a standard product spec especially for cross-contamination scenarios and the justification behind PAL which often requires more granular inputs. Agriplace is prepared to support this shift by helping teams structure the incoming information on even more granular levels.

What to watch out for in the new year

• Using PAL without documented justification

• Over-declaring allergens to “be safe”

• Relying solely on supplier statements without verification

• Outdated allergen documentation

• Inconsistent allergen information across labels, specifications and menus

From 2026 onward, these issues are more likely to result in direct NVWA findings.

The legal obligation to inform consumers hasn’t changed, the expectations for how companies prove compliance have.

Do you still have questions?

Reach out to our team here