FACTS Alerts – Lessons learned
A Change in Recipe, A Change in Risk: The NPD Team’s role
February 2026
Anaphylaxis UK recently issued an alert to consumers regarding a product from The Magnum Ice Cream Company, after a recipe change. Read more.
But why would a reformulation, perhaps even one made for quality improvement, result in such serious implications for allergic consumers?
In this case, the updated formulation now includes hazelnut, almond and egg, which were not previously present. In addition, the product may now contain soy, walnut, cashew, pecan, pistachio and macadamia. For individuals managing food allergies, this represents a significant shift in risk.
A particular challenge arises during transition periods, when both the old and the new packaging may be available on the shelf at the same time, requiring consumers to exercise extra caution. During such periods, it remains the manufacturer’s responsibility to ensure that the information on the label accurately reflects the product inside the packaging, particularly in terms of communicated allergen risk.
A lot of the responsibility for managing situations such as this starts with the product development team. The following practical principles should be considered:
- Ingredient decisions impact labelling. Even minor formulation changes (such as flavourings, inclusions, processing aids, etc.) can alter a product’s allergen profile or cross-contact risk. Every change should trigger a formal allergen risk assessment. Our in-house allergen experts can assist you with the process of vetting your suppliers and reviewing raw materials for allergen risks.
- ‘Previously safe’ does not mean ‘still safe’. Products with an established consumer base may be trusted by allergic individuals. Reformulation therefore carries both reputational and safety implications, and must be managed with heightened awareness and through effective communication channels. Reach out to our Regulatory team for guidance on safely communicating allergen changes in your product reformulations.
- Early cross-functional involvement is critical. Quality, regulatory, marketing and production teams should be engaged during development, ensuring allergen management practices (e.g. testing plans, cleaning validation and labelling compliance) align with the formulation before production begins. The FACTS Masterclass | Allergen Management For Product Developers could be the perfect opportunity to elevate your understanding of the complexities and impact of allergen management.
- Documentation and traceability protect consumers and brands. It is essential – and in the case of precautionary allergen labelling (PAL), mandatory – to maintain clear records of specifications, allergen declarations and the rationale behind decisions on file.
Ultimately, the product development team is responsible not only for taste, cost and functionality, but for consumer safety by design. Proactive allergen management during development helps prevent recalls, protects vulnerable consumers, and builds long-term brand trust.
When viral food trends overshadow safety: A recipe for recalls
July 2025
The recent alert over Dubai-style chocolate, specifically Neosis Schokolade Love of Dubai, serves as a stark reminder of how quickly viral trends can outpace essential safety checks.
The UK Food Standards Agency (FSA) issued a recall after discovering undeclared peanuts in the product, posing a “serious risk” to individuals with peanut allergies. Read more here.
The allure of riding social media waves – think TikTok’s ‘Dubai chocolate’ craze – is undeniable. But behind the excitement lurks a common oversight: failing to thoroughly vet raw materials and processing risks before launch.
This isn’t a one-off. Last month, the FSA issued a safety warning for multiple Dubai-style chocolates with inaccurate or missing allergen labels, confirming a concerning trend: viral food trends outpacing food safety. In the rush to capitalise on food trends, companies sometimes overlook critical steps, such as verifying ingredient sources, identifying common allergens, and assessing the risk of cross-contact.
The result? Undeclared allergens end up hidden in products – triggering urgent recalls, eroding consumer trust, and risking public health.
Takeaway lessons for manufacturers:
- Understand the regulations: Allergen requirements vary between countries. The allergens you manage locally may differ from those required in your export markets. Ensure you are familiar with the destination country’s regulations, and that your product labelling is fully compliant. If needed, FACTS offers label reviews to confirm compliance with South African regulations.
- Vet suppliers thoroughly: Don’t rely solely on ingredient specification sheets. Review allergen information critically, and follow up with suppliers if anything is unclear. Conduct regular due diligence testing for high-risk products. The FACTS MASTERCLASS | Allergen raw material risk assessment could be the perfect opportunity to elevate your allergen knowledge.
- Assess your processing risks: Evaluate each step in your manufacturing process for potential allergen cross-contact. Consider shared equipment, changeovers, and airborne contamination. Implement robust controls and cleaning validation where allergens are present, and review these regularly – especially when introducing new products or processes. Contact us to find out more about on-site GAP assessments.
- Monitor emerging trends responsibly: While innovation drives growth, it mustn’t come at the expense of safety.
In short, viral buzz should never trump due diligence. Companies can thrive on trend momentum; but only if they pair speed with robust safety checks to protect allergic consumers.
Why accurate allergen labelling matters
November 2024
Allergen labelling is more than a regulatory requirement – it’s a critical tool for protecting consumers and maintaining trust.
US-based wholesale retailer Costco had to recall over 36 tons of butter due to missing allergen information on the label. While the product listed cream as an ingredient, it failed to specifically declare milk as an allergen, as required by labelling regulations. Read more.
At first glance, it might seem unnecessary to explicitly state that a cream-based dairy product contains milk. However, the modern food landscape is changing rapidly. The rise of plant-based alternatives, many of which mimic the look, feel, and function of traditional dairy products, has blurred the lines for consumers. Products like non-dairy fat spread share the same shelf space as their dairy counterparts, making clear and explicit allergen labelling more important than ever.
Consumers with food allergies rely on accurate labelling to make informed decisions. When labels fail to provide clarity, it can lead to accidental exposure, costly recalls, and significant reputational brand damage.
Here are some practical tips to assist you:
- Stay updated on regulatory requirements and industry best practice. FACTS regulatory subscriptions, newsletters and LinkedIn posts will help keep you updated! Contact us to find out more.
- Foster close collaboration between the product development, regulatory, and marketing teams. The FACTS Masterclass | Allergen Management For Product Developers could be the perfect opportunity to elevate your understanding of the complexities and impact of allergen management.
- Ensure product ingredient lists and allergen declarations are checked during packaging material approval. If needed, FACTS offers label reviews to confirm compliance.
The Costco recall serves as a reminder that manufacturers must go beyond assumptions of what is ‘obvious’. Food labels must be explicit, comprehensive, and adhere strictly to regulatory standards to eliminate any room for misinterpretation. This not only ensures compliance but also reinforces consumer confidence in the brand and its commitment to food safety.
Food fraud remains a primary concern
May 2024
Meat, seafood, and olive oil are under scrutiny following recent investigations in Portugal, where Portuguese authorities revealed significant food safety concerns related to fraud and illegal food operations.
Key Findings:
- Olive oil fraud: Cooking oil sold as extra virgin olive oil led to cases of fraud, document falsification, and illegal geographical origin claims.
- Seafood violations: Seizure of seafood products for non-compliance with storage and handling conditions, including the addition of water, salt, and additives.
- Illegal slaughter and hygiene issues: Seizure of meat, meat-cutting tools, labelling accessories, and hunting equipment due to illegal slaughter activities and hygiene violations.
This incident emphasises the importance of managing food fraud in order to mitigate the risk of long-term damage to the economy, the food industry, and to consumer health.
How can we help you?
- Providing you with support & consultation to keep abreast with the latest trends in the ever-changing environment of food fraud.
- Our expert team can assist you with identifying what types of fraud are relevant to a product and how to test for them.
- FACTS offers incident scanning services and solutions to help you analyse what acts of food fraud have occurred in the past. This is key to performing vulnerability assessments.
Let’s stay ahead of fraudsters with continuous surveillance programs and countermeasures such as laboratory testing.
When allergen management goes TRAGICALLY wrong
January 2024
In a heartbreaking incident on 11 January 2024, New York-based ballerina Órla Baxendale tragically lost her life after consuming a mislabelled vanilla Florentine cookie. Being hyper-aware of her peanut allergy, Órla diligently checked labels and always carried an EpiPen.
On learning of Órla’s death the retailer of the Florentine cookies swiftly initiated a product recall, confirming that the cookie contained undeclared peanuts and eggs. It was revealed that soy nuts were inaccurately declared instead of peanuts.
Originally produced by a contract manufacturer and supplied to the retailer in bulk, the cookies underwent repackaging without the presence of peanuts and eggs being indicated. The packaging incorrectly listed soy nuts as an allergen.
The retailer contends that they were unaware of any recipe changes made by the manufacturer, denying there was any notification of the switch from soy nuts to peanuts. However, the manufacturer disputes this, claiming they had notified the retailer in July 2023 and also ensured accurate labelling on the bulk product supplied.
This tragic incident underscores the importance of robust allergen management protocols.
Tips to prevent allergen-related tragedies:
- Thoroughly review product information: Carefully examine product details, focusing on ingredients derived from allergens, hidden allergens, and cross-contact allergens.
- Contractual communication: Require suppliers to communicate any allergen changes in writing through specified channels, as a contractual obligation.
- Verify incoming product documents: Regularly check product documents and labels to ensure they are up to date, accurate, and aligned with expectations.
- Build open relationships: Foster honest and transparent relationships with suppliers to enhance communication and collaboration, reducing the risk of oversights and miscommunication.
We extend our deepest condolences to Órla Baxendale’s family and friends. This tragic incident reminds us that it is our collective responsibility to ensure that robust allergen management protocols are in place throughout the supply chain. By working together, hopefully we can prevent similar tragedies from happening in the future, and safeguard the health and well-being of allergic individuals.
1.8 tons of pizza recalled due to undeclared soy
October 2023
US company Green Valley Foods is recalling more than 1.8 tons of frozen meat pizza products because they contain undeclared soy.
The recall was triggered after routine USDA Food Safety and Inspection Servicer testing found soy. In-plant personnel identified and verified that although it was known that the products contained soy, it was not declared on the label.
Here are some practical tips to assist you:
- Ensure product ingredient lists and allergen declarations are checked during packaging material approval.
- Ensure you receive and use the correct printed packaging material.
- During the start-up of the production line, verify that the correct version of the packaging material has been issued and loaded onto the packing equipment.
- Avoid leaving printed packaging material on the production lines or in the packing equipment, to minimise the risk of contamination or incorrect usage.
1.4 tons of beef wiener recalled
August 2023
The US Department of Agriculture’s Food Safety and Inspection Service (FSIS) reported that Perdue Premium Meat Company, Inc. had to recall approximately 1.4 tons of cooked beef wiener products due to misbranding and undeclared allergens.
The recall was triggered after a customer discovered that they may have received smoked sausages, which contain milk, packaged in the beef wieners’ primary packaging material, which does not indicate the presence of milk.
Here are some practical tips to assist you:
- Ensure you receive and use the correct printed packaging material.
- During the start-up of the production line, verify that the correct version of the packaging material has been issued and loaded onto the packing equipment.
- Avoid leaving printed packaging material on the production lines or in the packing equipment, to minimise the risk of contamination or incorrect usage.
50% of AUS recalls are allergen related
June 2023
According to a recent article published on Food Safety News, allergen issues continue to dominate Australian recalls. About half of the food recalls in Australia in 2022 were due to undeclared allergens.
Most recalls were due to supplier verification issues. Others were caused by packaging issues, such as the wrong packaging or an incorrect ingredient list.
The main food types associated with recalls due to allergens were mixed and/or processed food. This group includes snack foods, custard powders and frozen meals.
When allergen management goes wrong
April 2023
Spring Gully Foods (in Australia) recently had to recall their gluten-free OzEmite, a fermented vegetable spread. The details of the root causes are unknown, other than there was an ingredient supply issue and that gluten was detected during routine quality checks.
Interesting to consider that in 2020, the FDA ruled that it would not allow gluten-free claims on fermented or hydrolysed foodstuffs unless all ingoing ingredients are gluten-free. This is due to the technical difficulties associated with detecting and quantifying gluten in this category of products.
Our practical tips to help:
- Screen critical incoming ingredients for gluten before it is released.
- Ensure your rapid on-site testing kit is validated for the raw material/s you are testing. If it is not, contact us to assist you with a matrix check.
- When testing products or ingredients which have been fermented or hydrolysed remember to keep us informed so that our team are able apply the most appropriate testing method/s to analyse your products.
Horse meat fraud: why you should still care
February 2023
A decade after the ‘Horsegate’ scandal, horse-meat fraud is still dominating news headlines.
Several people have been sentenced for the sale of horse meat that was potentially unfit for consumption. Recent reports indicate that the horses’ identification passports and drug-treatment books had been falsified.
In the last few years, European authorities have encountered multiple instances of illegal trade and document fraud involving horses.
These fraudulent acts and illegal trade often result in unsafe meat products entering the market, posing a major risk to public health. Furthermore, such incidents create a significant opportunity for meat species substitution and compromised product authenticity.
Since 2013, the food industry has made great strides in combating and addressing food fraud in their supply chains; however, meat products remain highly vulnerable and susceptible to fraud. Protecting your brand and consumers requires continuous vigilance and robust testing to ensure meat authenticity.