No Top 14

PAL & Oats


PAL – we follow the Food Standards Agency guidance:

Precautionary allergen labelling

If there is a risk of a food product being affected by allergen cross-contamination, the label should include one of the following statements: 

  • may contain X
  • not suitable for someone with X allergy

Precautionary allergen labelling should only be used after a thorough risk assessment. It should only be used if the risk of allergen cross-contamination is real and cannot be removed.

Please note that:

If the product does not carry any PAL - eg 'may contain' warnings - we assume that a full risk assessment has been carried out and that comprehensive allergen management protocols are in place so that even if one of the 14 major allergens is handled by the same  factory there will be no risk to the allergic consumer. 

Therefore, carrying a statement that the product is manufactured in a factory which also handles/uses x allergen will not bar that product from entering the No Top 14 category provided that it does not also carry a ‘may contain x allergen’ warning.


Historically, the FreeFrom Food Awards have stuck with the letter of the law and have excluded products containing oats, even if gluten-free oats, from the 'No Top 14' category. However, in 2020 we reviewed our position and decided that this was not helpful for the consumer and that we should therefore change our criteria to allow in products which contained oats, provided that they were labelled as gluten-free oats.


If you have any queries or would like to talk to us about the project email Michelle or Cressida or call Cressida on +44 (0)7790 869706‬