To bring your HACCP plan into line with the new allergen regulations coming into force in 2026, you will need to review your risk analysis, update your documentation and revalidate the critical control points relating to allergens. The changes to allergen legislation affect several aspects of your food safety system at once, from raw material inspection to label checks. In this article, we answer the most frequently asked questions about how to go about this.
What exactly will change in the 2026 allergen regulations?
The 2026 allergen regulations introduce stricter requirements regarding mandatory labelling, traceability and the way in which cross-contamination must be documented. Businesses are required not only to list the allergens present, but also to demonstrate how they control and record the unintentional presence of allergens.
Specifically, these are a number of changes that have a direct impact on your day-to-day processes:
- Stricter requirements regarding the justification for “may contain” statements, which must henceforth be demonstrably based on a risk analysis
- More comprehensive documentation requirements for allergen management procedures
- Higher expectations regarding supplier verification and raw material specifications
- Stricter requirements for cleaning validation in production environments where multiple allergens are present
This is particularly relevant for companies that work with powdered supplements, as the risk of cross-contamination is inherently greater in powder production than with other product forms. Allergen legislation requires that you not only recognise this risk, but also manage and document it as part of your standard operating procedures.
Which parts of an HACCP plan are most affected?
The parts of an HACCP plan most affected by the new allergen regulations are the hazard analysis, the identification of critical control points (CCPs) and the verification procedures. In addition, the changes require a review of the supporting programmes relating to cleaning and supplier management.
Specifically, these are the sections that require attention:
- Hazard analysis: Allergens must be explicitly identified as biological or chemical hazards, with a corresponding risk assessment for each raw material and production line
- CCPs and oPRPs: Allergen control measures must be reviewed in line with the new requirements, including limit values and monitoring frequency
- Cleaning procedures: The validation of cleaning as a control measure for allergens is subject to more rigorous scrutiny
- Supplier management: Specifications for raw materials must include up-to-date allergen information and be verified at regular intervals
- Label check: The process used to check that the allergen information on the label is correct must be documented as part of the HACCP system
How do you carry out a new allergen risk assessment?
You carry out an allergen risk analysis by systematically assessing all ingredients, processing aids and production conditions for the risk of the presence of, or cross-contamination with, the fourteen legally recognised allergens. The result forms the basis for your control measures and documentation.
Follow these steps:
- Draw up an allergen matrix in which you specify, for each raw material, which allergens are present or may be present as a result of cross-contamination at the supplier’s premises
- Analyse your production environment on shared production lines, equipment and storage areas where allergens may come into contact with one another
- Assess cleaning effectiveness based on validation data or, if these are not available, carry out cleaning validation studies
- Assess the likelihood and severity assess each allergen risk and classify it as significant or non-significant
- Assign control measures identify significant risks and set out who is responsible for monitoring and verification
- Document the reasoning behind every decision, so that, in the event of an audit, you can demonstrate why you consider certain risks to be under control
A properly conducted risk analysis is not a one-off exercise. Any change to raw materials, suppliers or production processes requires a review of the analysis.
What are the new requirements for allergen registration and documentation?
The new requirements for allergen registration and documentation mean that companies must be able to demonstrate how they identify, control and monitor allergen risks. This means that procedure descriptions, training records, cleaning logs and supplier specifications must be up to date and auditable.
In practice, this means you need to have the following documents in order:
- An up-to-date allergen matrix for each product and production line
- Documented cleaning procedures with validation results
- Supplier declarations or specifications containing up-to-date allergen information
- Training records for staff who work with or around allergens
- Internal audit reports demonstrating compliance with allergen management procedures
- Records of non-conformities and corrective actions relating to allergen incidents
It is important that documentation is not only available but also up to date. Outdated specifications or logs that have not been kept up to date are regarded as a shortcoming in the system during audits, even if the physical processes are in order.
When does an HACCP plan need to be recertified following an amendment?
An HACCP plan does not need to be recertified after every amendment, but significant changes, such as a revision of the hazard analysis or the introduction of new control points, must be validated and documented internally before they are implemented. Certification via an external audit usually takes place in accordance with the regular audit cycle.
What you must do in the event of a substantial change to your HACCP plan:
- Carry out an internal verification to confirm that the changes have taken effect
- Obtain formal approval from the management team for the revised version
- Report any changes to your certifying body if they relate to critical control points or the scope of your certification
- Communicate updated procedures to relevant staff and update training programmes
Under certification standards such as BRCGS, changes to the HACCP system are assessed during the next regular audit. However, if changes are so significant that they fundamentally affect the control of food safety risks, an interim assessment may be necessary.
How does a private label partner help with allergen compliance?
A reliable private label partner takes care of a large part of allergen compliance, as it has its own HACCP system, certified production processes and up-to-date supplier specifications. As a client, you therefore benefit from a production environment that is already set up for allergen control.
This is particularly valuable for brands that do not have their own production facilities and rely on their manufacturing partner to ensure food safety. In such cases, the quality of the manufacturer’s allergen documentation directly determines whether your product complies with market requirements.
How MixMasters helps with allergen compliance
As a certified manufacturing partner for powdered food supplements, we actively support our clients in complying with current allergen legislation. Our quality team works alongside consultants to develop a comprehensive food safety plan that is tailored to your product range and is ready for market straight away.
Specifically, here is what we offer in the area of allergen compliance:
- An HACCP-based production system with demonstrable allergen control
- BRCGS certification, an internationally recognised standard that also covers allergen management, traceability and cleaning validation
- Up-to-date ingredient specifications, including allergen information, from our suppliers
- Support in drawing up accurate product information and label content
- A food safety plan that enables you, as a brand, to enter the market straight away
Would you like to find out how we can manufacture your range of supplements in a certified and compliant production environment? Take a look at our private label manufacturing services or Please get in touch with us for a no-obligation chat.
Frequently Asked Questions
What is the difference between a CCP and an oPRP in allergen control?
A CCP (Critical Control Point) is a step in the process where control is essential to eliminate a food safety risk or reduce it to an acceptable level, whilst an oPRP (Operational Prerequisite Programme) is a supporting control measure that mitigates the risk but does not fully control it. In the case of allergens, cleaning procedures are often classified as oPRPs, whilst a specific separation step or ingredient control is designated as a CCP. The choice depends on the severity of the risk and the extent to which the measure demonstrably controls the risk. It is important to provide a sound justification for this classification in your HACCP documentation, as auditors scrutinise this closely.
How often should I update my allergen matrix?
Your allergen matrix must be reviewed at least once a year, but must also be updated immediately whenever there is a change to raw materials, suppliers, recipes or production lines. Suppliers may alter their production conditions or raw material composition in the interim without actively communicating this, making periodic verification of supplier specifications essential. Set a fixed date in your quality calendar for the annual review and link this to your supplier assessment. This will prevent out-of-date information from forming the basis for your risk analysis and label declarations.
What should I do if a supplier is unable to provide an up-to-date allergen declaration?
If a supplier is unable to provide an up-to-date allergen declaration, you must treat this as a non-conformity in your supplier management and, for the time being, classify the raw material as high risk. Escalate the situation in writing to the supplier and set a deadline for the submission of the requested documentation. In the meantime, consider qualifying an alternative supplier who does meet your documentation requirements. Use this opportunity to refine your supplier assessment process so that allergen declarations become a standard part of the periodic verification.
Can I omit a 'may contain' statement if I clean my production line thoroughly?
Ja, maar alleen als je kunt aantonen via gevalideerde reinigingsstudies dat de reiniging effectief genoeg is om allergenenresiduen onder een aantoonbaar veilig niveau te brengen. De nieuwe allergenenregels van 2026 vereisen juist dat ‘may contain’-vermeldingen zijn gebaseerd op een risicoanalyse en niet langer als voorzorgsmaatregel zonder onderbouwing mogen worden gebruikt. Als je de vermelding weglaat zonder validatiedata, loop je een aanzienlijk juridisch en voedselveiligheidsrisico. Laat reinigingsvalidatie uitvoeren door een geaccrediteerd laboratorium en documenteer de resultaten als onderdeel van je HACCP-systeem.
What common mistakes should I avoid when adapting my HACCP plan to the new regulations?
The most common mistakes are: updating documents without validating the underlying processes, failing to communicate changes to production staff, and treating the update as a one-off project rather than an ongoing management system. Another common mistake is copying generic HACCP templates that are not tailored to the specific production environment and the allergen profile of your products. Also ensure that changes are formally approved and version-controlled, so that during an audit it is always clear which version of the plan is active and when changes were implemented.
How can I train my staff effectively on the new allergen regulations?
Effective allergen training combines theoretical knowledge of the fourteen legally recognised allergens with practical instructions tailored to the employee’s specific tasks. Ensure that production staff understand why certain procedures exist, not just how they are carried out, as understanding enhances compliance. Repeat training sessions at least once a year and always following a change to procedures or the introduction of new raw materials. Always record training sessions in writing, including the date, name and signature of the employee, as training records are a mandatory part of your allergen management documentation.
What are the consequences if my business fails to comply with the 2026 allergen regulations by the deadline?
Failure to comply with allergen regulations may result in enforcement measures by the Netherlands Food and Consumer Product Safety Authority (NVWA), including fines, mandatory product recalls or, in serious cases, a temporary ban on production. In addition, you run the risk of reputational damage and liability claims if a consumer with an allergy suffers harm due to incomplete or incorrect allergen information on your product. For companies with BRCGS or IFS certification, non-conformities relating to allergens may also lead to the loss or suspension of their certification. You should therefore start reviewing your HACCP system well in advance of the new rules coming into force.
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