EU Food Recall Systems: Protecting Consumers Through Effective Labeling and Swift Action

In March 2025, a series of food recalls across Europe highlighted the ongoing challenges and importance of food safety systems. Three notable incidents involved undeclared allergens:

An undeclared allergen refers to an allergenic ingredient that is present in a food product but is not listed on the packaging or label. These recalls showcase the importance of accurate food labeling to protect vulnerable consumers with food allergies.

Recent data underscores the growing concern over undeclared allergens in food recalls. In 2023, the European Union's Rapid Alert System for Food and Feed (RASFF) recorded the highest number of total food notifications since 2020. While fruits, vegetables, and poultry meat products accounted for 24% of total alerts, allergens remained the leading cause of recalls, followed by foreign bodies and microbiological concerns. Notably, the confectionery category experienced the highest number of recalls, followed by prepared dishes, pasta, and noodles. Additionally, vegan and vegetarian products were disproportionately affected, representing 13% of all recalls despite their smaller market share.

Overall, undeclared allergens are a persistent issue, responsible for approximately 30% of all food recalls. This trend highlights the ongoing need for stringent food safety measures, improved labeling accuracy, and greater industry vigilance to prevent health risks and ensure consumer trust.

Consumer Health and Safety

For individuals with food allergies, consuming allergens can lead to severe health consequences, including anaphylaxis, a potentially life-threatening reaction. A study highlighted that concentrations of undeclared milk proteins in certain products could elicit allergic reactions in up to 68% of milk-allergic adults.

Alarmingly, over half (56%) of UK allergy sufferers have experienced allergic reactions due to mislabelled or unclear food packaging, with 23% having suffered multiple reactions. Food regulatory authorities in the UK conducted studies to gather data regarding allergen related recalls. These studies showed that 57.6% of all food recalls are related to allergens, with milk being the most frequently recalled allergen (25.2%).

The EU's Food Safety Framework

The European Union has implemented a regulatory framework to ensure that all member countries comply with food safety standards. At the core of this system is Regulation (EC) No. 178/2002, which establishes that "food shall not be placed on the market if it is unsafe". This regulation mandates that food business operators must immediately initiate withdrawal procedures if they believe a food product they've handled doesn't comply with safety requirements.

When potentially harmful products reach consumers, businesses must "effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers products already supplied to them". This explains the swift action we saw last week with notifications about undeclared allergens in poppy seed paste and chips.

The New General Product Safety Regulation

The EU is strengthening its recall systems further with the new General Product Safety Regulation (GPSR), which came into force on June 12, 2023, and is fully applicable from December 13, 2024. This regulation introduces significant changes to make product recalls more effective:

Direct Consumer Notification: Businesses must contact affected consumers directly where possible, using data from product registration systems or loyalty programs specifically designated for safety purposes.
Standardized Recall Notices: The European Commission has published a mandatory template for recall notices that must be used starting December 13, 2024. These notices must avoid language that might downplay risks, such as terms like "voluntary" or "precautionary".
Consumer Remedies: To encourage higher response rates to recalls, businesses must offer consumers a choice between at least two remedies: repair, replacement, or refund.

RASFF: Rapid Alert System for Food and Feed

The notifications mentioned are part of the Rapid Alert System for Food and Feed (RASFF), a key tool in ensuring food and feed safety in the EU. RASFF enables swift information exchange between national food safety authorities, the European Commission, and other stakeholders when risks to public health are detected in the food chain.

The Critical Role of Food Labeling

Proper food labeling serves as the first line of defense in preventing food safety incidents, and decrease the risk of recalls due to label mistakes. Since December 2014, Regulation (EU) No. 1169/2011 has established common requirements for food information throughout the EU.

For vulnerable consumers with food allergies, accurate labeling can be a matter of life and death.

Main Challenges in Labeling Foods with Allergens

A study of FDA-regulated food recalls found that 70% of allergen-related recalls from 2013 to 2019 were due to labeling errors. These errors are often caused due to:

Cross-contamination: Even when allergens are not intentionally added to a product, trace amounts can be present due to shared production facilities or equipment.
Precautionary labeling overuse: Industries often use terms as "may contain" to ensure they cover all possible causes of allergies. However, this can confuse consumers and limit food choices for allergic individuals unnecessarily.
Ingredient changes: Manufacturers may alter product formulations, potentially introducing new allergens without updating labels immediately.
Supply chain complexity: With ingredients sourced globally, ensuring accurate information about potential allergens throughout the supply chain can be challenging.
Global exports: The globalized nature of food systems presents additional challenges. Different countries have varying standards for food safety, requiring businesses to adapt their operations to meet diverse requirements. This complexity is exemplified by the recent inclusion of sesame as a major allergen in the US, which has implications for global food companies exporting to the American market.
Language barriers: In a diverse market like the EU, ensuring clear allergen information across multiple languages is crucial but complex.
Threshold levels: There's ongoing debate about the minimum amount of an allergen that should trigger labeling requirements, as trace amounts may or may not cause reactions in sensitive individuals.
Novel foods and ingredients: As new food products enter the market, identifying and labeling potential allergens can be challenging, especially for ingredients without a history of allergenic properties.

Economic Impact for Businesses

Larger retailers, which are expected to have stricter quality controls, were responsible for many recalls. The supermarket Lidl recorded the highest number of recalls, with 37 incidents involving 62 products. This demonstrates that even modern facilities are not immune to allergen labeling failures, reinforcing the importance of industry-wide transparency and accountability. Another example, in early 2025, is Frito-Lay's recall of Lay's Classic Potato Chips due to undeclared milk, which was escalated to a "Class 1" (potential for serious health consequences or death).

Food recalls damage consumer trust. Studies indicate that 23% of consumers would permanently stop purchasing from a brand involved in a recall, while 35% would avoid the brand for months. This loss of confidence extends beyond individual companies, impacting the food industry as a whole. Frequent recalls can also create consumer anxiety, making individuals overly cautious or restricting their food choices, especially for those managing allergies.

The economic impact of food recalls on businesses can be severe, affecting not only brand reputation but also financial stability. The costs associated with a recall extend far beyond the immediate expenses of removing products from shelves. Businesses face regulatory fines, legal fees, lost sales, compensation claims, and supply chain disruptions.

A single recall can cost a company millions of dollars. For instance, in the U.S., the average direct cost of a recall is estimated to be $10 million, excluding potential lawsuits and long-term revenue loss. In extreme cases, food recalls have forced companies into bankruptcy due to the overwhelming financial burden.

To mitigate these risks, traceability systems are crucial. Advanced tracking technologies, such as blockchain, RFID, and digital recordkeeping, help businesses quickly identify contaminated batches, limit recall scope, and reduce financial losses

The Path Forward: Innovations in Food Allergen Detection

Technology is making huge advancements in allergen detection, enabling industries to conduct rapid, non-invasive testing while fostering a safer and more reliable market for consumers.

Nanobody Technology: Researchers are leveraging nanobodies derived from camelid antibodies to develop superior food allergen detection methods. These nanobodies offer enhanced stability and specificity, leading to more accurate and cost-effective immunoassays.

AI-Enabled Sensors: Artificial intelligence is being integrated into sensors and imaging technologies to create non-destructive methods for real-time allergen monitoring. This innovation allows for continuous quality control during food production without compromising product integrity.

Electrochemical Biosensors: Recent research highlights the development of electrochemical biosensors utilizing various recognition elements, including antibodies and nucleic acids. These sensors provide sensitive and rapid detection of food allergens, contributing to improved food safety protocols.

Continued collaboration among researchers, industry stakeholders, and regulatory bodies is essential to address the challenges posed by food allergens and effectively protect consumers.