Allergen Disclosure for Dining Experiences Act Knowledge Hub

Precautionary Allergen Labeling (PAL): How Can Your Team Manage Cross-Contact Risk?

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Written by

Dr Laura Kirwan PhD

in

Precautionary Allergen Labelling (PAL): Managing Supply-Chain and Operational Cross-Contact Risks

Understanding Precautionary Allergen Labelling (PAL)

Precautionary Allergen Labelling (PAL), such as “may contain” or “produced in a facility that also processes,” is voluntary under California’s SB-68 (ADDE Act). While allergen disclosure for known ingredients is mandatory, PAL statements are optional. Applied correctly, PAL demonstrates proactive risk management and transparency for your business.

Types of PAL

There are two main types of PAL in foodservice, each with distinct origins and purposes:

Type Definition Typical Source Example Statement
Supply-Chain PAL Issued by manufacturers or distributors to indicate possible cross-contact during production or packaging. Supplier allergen declarations, spec sheets, or packaging. “Manufactured in a facility that also processes peanuts.”
Operational PAL Applied by operators to reflect potential cross-contact during storage, preparation, or service. Shared fryers, cutting boards, utensils, or prep surfaces. “Prepared in a kitchen that handles milk, eggs, soy, and wheat.”

Understanding the distinction between supply-chain and operational PAL helps operators apply statements only where justified and maintain credibility with guests.

Applying PAL Responsibly

PAL should never be applied indiscriminately. Using it selectively protects your brand and ensures meaningful communication to guests.

  • Apply selectively: Use PAL only where cross-contact risks are verified and cannot be fully controlled.
  • Document rationale: Record why PAL was applied — whether due to supplier information or operational limitations.
  • Review regularly: Remove PAL statements once risks are mitigated or suppliers confirm allergen segregation.
  • Ensure consistency: Apply identical PAL language across printed, digital, and delivery menus.

Following these practices ensures PAL statements remain credible and genuinely informative for guests.

Inspection Readiness and Documentation

Although PAL is voluntary, regulators and auditors may view it as a sign of proactive allergen management. Proper documentation demonstrates diligence and accountability.

  • Supply-chain PAL: Keep supplier statements or allergen spec sheets attached to ingredient records.
  • Operational PAL: Maintain prep-area risk assessments, cleaning logs, and staff SOPs.
  • Staff Training: Include PAL policies in onboarding and refresher sessions to ensure team understanding.
Pro tip: If asked why a dish says “may contain soy,” you should be able to point to either a supplier declaration or a documented in-house cross-contact assessment.

Accurate records and staff awareness support your compliance efforts and protect both guests and your operation.

Apply Precautionary Allergen Labelling (PAL) selectively and document every decision to maintain trust and demonstrate proactive allergen management.

Strengthen Your Allergen Management Program

Access expert guidance and tools to document PAL decisions, verify supplier data, and ensure your allergen program meets SB-68 expectations.

Ask an Expert Download Resources View Legislation

Context: The California ADDE Act (SB-68) requires allergen disclosure for restaurant chains with 20 or more U.S. locations by July 1, 2026. While PAL remains voluntary, documenting it supports transparency, demonstrates due diligence, and reinforces continuous improvement in allergen control.



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