These are not completely new rules, but rather a strengthening of the existing system.

The focus today is on:

• greater focus on allergens within HACCP

• structured and mandatory risk assessment

• preventing contamination (not just controlling it)

• evidenced procedures, not merely ‘good practice’

For manufacturers, this means that caution alone is no longer enough.
They must show how, in concrete terms, they prevent contamination.

What does this mean for coeliacs?

For people with coeliac disease, this means very concrete changes.

Every manufacturer must analyse whether gluten could get into the product.
If a risk exists, it must be reduced or clearly labelled.
If there is no risk, this must be based on a real and documented assessment.

This is not a matter of instinct, but of a systematic approach.

How is cross-contamination managed today?

In practice, this includes several key measures:

• separate storage of raw materials

• separate or thoroughly cleaned production lines and equipment

• validated cleaning procedures

• control of the production process (sequence, flows)

• trained staff

Most importantly, all of this must be documented and verifiable.

What does this mean for labelling?

This brings us to one of the most misunderstood areas.

In the EU, the rule is clear:

allergens, including gluten, must always be clearly indicated in the ingredients.

Therefore:

if gluten is not on the ingredients list, that is not by chance, it means the product has been assessed within HACCP and the risk assessment.

‘May contain traces of …’ – Is it really voluntary?

So-called precautionary allergen labelling (PAL) is often described as voluntary, but that does not mean it is without rules.

According to EU and Codex guidelines:

• it must be based on a risk assessment

• it is used only if contamination cannot be reliably prevented

• it must not replace good manufacturing practices

This means:

• if PAL exists, there is a reason

• if there is no PAL, that too is based on analysis

Can we trust products without a ‘gluten-free’ label?

Based on the system in force today, the answer is often: yes.

If a product does not contain gluten in the ingredients and does not have PAL, then behind this stands:

• the HACCP system

• risk assessment

• EU legislation

This is not guesswork, but a structured system.

Why, then, so much distrust?

In practice, problems arise because of:

• excessive use of the ‘may contain’ label

• unclear communication by manufacturers

• a loss of trust among consumers.

It is important, though, to understand the difference:

• caution does not mean complete restriction

• safety does not mean exclusively certified products

What does this mean for everyday life?

If coeliacs restrict themselves only to products labelled ‘gluten-free’, they often:

• needlessly narrow their choices

• make everyday decisions harder

• increase food costs.

The reality, however, is that the system after 2021 is designed to allow safe choices even without a special label.

Conclusion

The HACCP changes after April 2021 mean:

• more control over allergens

• better protection for consumers

• greater responsibility for manufacturers

For people with coeliac disease, this means:

• more trust in labels

• more freedom in choosing food

• less need to rely entirely on a ‘gluten-free’ label