The previous Dutch allergen policy, implemented in 2016, introduced temporary reference doses for allergen risk assessment, deviating from a zero-tolerance approach. However, these values were considerably lower than those recommended by the VITAL system, causing discrepancies and confusion within the industry. Additionally, the policy did not recognize precautionary allergen labeling (PAL) as a valid notification method. As a result, products were being withdrawn from the market based on PAL warnings, leading to legal disputes.
The low Dutch reference doses from 2016 have been abolished after the publication of the new values.  

The new Dutch policy regards only pre-packaged foods, and it focuses on three key aspects: reference doses, the use of PAL, and guidelines for managing cross-contact with allergens.  

The reference doses have been revised based on international recommendations from the FAO/WHO and are expected to be harmonized globally through the Codex Alimentarius. These revised reference doses will provide a more accurate and reliable measure of allergen concentrations, ensuring better protection for allergic consumers.    

The policy also addresses the use of PAL, emphasizing that it should only be employed when a real risk to allergic consumers exists. Precautionary labeling should not be used as a means of covering manufacturers' liability. The wording of PAL has been standardized to “May contain xxx” (preferred by patient organizations) or “Not suitable for xxx”, indicating the presence of allergens, while terms like "May contain traces of xxx" or "Made in a company that also processes xxx" are no longer permitted. This change aims to provide clearer information to consumers and enable them to make informed decisions based on their individual risk assessments.    

The new Dutch allergen policy will be implemented gradually, allowing companies a two-year transition period to adjust their practices. From January 1, 2026, the policy will be fully enforced. 

https://affidiajournal.com/en/dutch-government-introduces-new-allergen-policy-adjusting-reference-doses