Direct answer: In July 2026, the Codex Alimentarius Commission adopted new international guidance for precautionary allergen labelling, including warnings such as “may contain.” For cereals containing gluten, the framework now uses a science-based reference dose to support decisions about when precautionary labelling is appropriate. This does not replace the existing concept of a gluten-free claim, and it does not automatically change national or European Union law.
What Codex adopted
At its 49th session, held in Geneva from 6 to 10 July 2026, the Codex Alimentarius Commission adopted guidance on precautionary allergen labelling as part of the General Standard for the Labelling of Prepackaged Foods [1]. The guidance uses a risk-based approach: a precautionary statement should follow a risk assessment and should be used when unintended allergen presence remains above the relevant action level after appropriate mitigation measures have been applied [1].
For cereals containing gluten, an ad hoc FAO/WHO expert consultation recommended a reference dose of 4 mg gluten for risk assessment of unintended presence when deciding whether precautionary allergen labelling should be applied [2]. The expert consultation also stated that this reference dose should not be used to redefine “gluten-free” labelling [2].
The 4 mg reference dose is not a new gluten-free threshold
The 4 mg figure is an exposure-based reference dose used in risk assessment. It is not a concentration limit that diners can apply directly to every product, and it is not a new definition of “gluten-free.” The concentration corresponding to a 4 mg exposure depends on the amount of food eaten.
GCSI interpretation: this distinction matters because a precautionary warning and a gluten-free claim answer different questions. A precautionary statement communicates residual unintended-presence risk after controls and risk assessment. A gluten-free claim is governed by the applicable definition in the jurisdiction where the food is sold.
What this means for people with celiac disease
- Do not treat “4 mg” as a new personal daily target or as permission to ignore a precautionary statement.
- Do not assume that a product without a “may contain” statement has been assessed under the new Codex framework. National implementation and industry practice can differ.
- When a product carries a gluten-free claim, interpret that claim under the law or standard that applies where the product is sold.
- If a label is unclear, use the current package information and, where needed, manufacturer information rather than relying on an older photograph or database entry.
What this means for food businesses
- Precautionary wording should not substitute for preventive controls.
- Risk assessment should address unintended presence after appropriate mitigation measures have been applied.
- Records should show the basis for the decision to use or not use precautionary labelling.
- Businesses should distinguish ingredient declaration, precautionary labelling and gluten-free claims in staff guidance and consumer communication.
Jurisdiction and effective date
Codex is an international standards programme established by FAO and WHO. The precautionary allergen-labelling guidance was adopted on 6 July 2026 [1]. Codex texts are internationally recognised benchmarks, but they are voluntary unless incorporated into national or regional requirements [3]. This article therefore does not state that the guidance automatically changed Austrian, European Union, United States, Canadian, Australian or other national law on that date.
What remains uncertain
Implementation will differ across jurisdictions and food businesses. The expert consultation developed the 4 mg gluten reference dose for risk-based precautionary labelling, but national authorities may need separate legal, technical or enforcement steps before the approach becomes part of local practice [2,3]. GCSI will therefore treat the 2026 Codex decision as an important international standard-setting development, not as evidence that every current “may contain” label already follows the new framework.