Allergen Management & Labelling Policy

1. Purpose

This policy sets out Murzo Group's approach to identifying, controlling, communicating, and reviewing allergen risks in relevant food, ingredient, substrate, farming, production, research, development, storage, distribution, and catering activities.

It supports consumer safety, lawful food information, product integrity, supplier control, and incident readiness.

2. Scope

This policy applies where Murzo Group, its group companies, suppliers, contractors, or partners develop, source, handle, prepare, pack, label, store, transport, sell, supply, or dispose of food, ingredients, samples, substrates, or other materials that may contain or come into contact with food allergens.

It covers prepacked food, prepacked for direct sale food, non-prepacked food, online or distance sales, samples, trials, prototypes, client projects, and any product or process where allergen information may affect safety or legal compliance.

3. Recognised Allergens

Murzo Group recognises the 14 allergens that must be declared under UK food information rules where they are used as ingredients, additives, processing aids, or are otherwise present in the final food.

• Celery
• Cereals containing gluten, including wheat, rye, barley and oats
• Crustaceans
• Eggs
• Fish
• Lupin
• Milk
• Molluscs
• Mustard
• Peanuts
• Sesame seeds
• Soybeans
• Sulphur dioxide and sulphites at legally relevant concentrations
• Tree nuts, including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts

Murzo Group may also manage additional allergen, intolerance, sensitivity, or consumer-safety risks where required by product type, customer requirement, scientific evidence, novel food authorisation, contract, or market destination.

4. Allergen Risk Assessment

Allergen risks must be considered before products, recipes, ingredients, substrates, processes, suppliers, production lines, packaging, or labels are approved or changed.

An allergen risk assessment may consider:

• Intentional allergenic ingredients and processing aids
• Supplier allergen declarations, specifications, certificates, and change notifications
• Potential allergen cross-contact during sourcing, transport, storage, handling, processing, cleaning, packing, or distribution
• Shared equipment, utensils, containers, oils, surfaces, production lines, storage locations, and staff movement
• Consumer information, product format, target market, intended use, and vulnerable groups
• Legal requirements for the UK and any other country where the product may be marketed

5. Ingredient, Recipe & Specification Controls

Murzo Group must maintain accurate allergen information for relevant ingredients, recipes, formulations, specifications, and products.

• Ingredient allergen information should be recorded in a written, controlled, and retrievable format
• Ingredients should be kept in original packaging or clearly labelled containers wherever practicable
• Recipe and formulation records must identify allergenic ingredients and must be reviewed when suppliers or ingredients change
• Supplier specifications should be reviewed for allergen status, cross-contact warnings, origin, processing aids, and change-control commitments
• Unclear, incomplete, conflicting, or outdated allergen information must be resolved before use or release

6. Storage, Segregation & Handling

Allergenic materials must be stored, handled, and moved in a way that reduces accidental cross-contact and protects product identity.

• Allergenic ingredients and prepared foods should be stored separately from non-allergenic or different-allergen materials where practicable
• Containers must be closed, labelled, and protected from spillage or mix-up
• High-risk allergens may require dedicated utensils, colour coding, sealed containers, separate locations, or controlled handling procedures
• Decanted or repacked ingredients must retain clear identity, allergen status, batch details, and expiry or use-by information where relevant
• Waste, rework, returns, and samples must be controlled to prevent unintended reuse or cross-contact

7. Cross-Contact Prevention

Murzo Group will seek to prevent or reduce allergen cross-contact through suitable process design, scheduling, hygiene, training, segregation, and verification.

• Where possible, processes should be designed to avoid unnecessary shared equipment or shared preparation areas
• Production or preparation may be scheduled from lower-allergen to higher-allergen products where this reduces risk
• Hands, utensils, surfaces, equipment, containers, and preparation areas must be cleaned appropriately between incompatible allergen tasks
• Shared cooking oil, shared utensils, or shared work surfaces must be controlled where they may transfer allergens
• Where cross-contact cannot be adequately controlled, the product must not be represented as allergen-free and consumers or customers must be informed appropriately

8. Cleaning & Verification

Cleaning procedures must be suitable for the allergen risk and the equipment or area being cleaned.

• Hard-to-clean equipment may require dismantling, manual cleaning, inspection, or dedicated cleaning tools
• Cleaning methods must not spread allergenic residues from one area or product to another
• Visual checks, documented inspections, allergen swabs, analytical testing, or other verification methods may be used where proportionate
• Cleaning failures, positive allergen results, or suspected cross-contact must trigger product hold, investigation, and corrective action where appropriate

9. Labelling & Consumer Information

Allergen information must be accurate, clear, visible, legible, and suitable for the way the food is supplied.

• Prepacked food must include an ingredients list and must emphasise allergenic ingredients each time they appear in the list
• Prepacked for direct sale food must include a full ingredients list with allergenic ingredients emphasised where required
• Non-prepacked or loose food must provide allergen information for every item containing any of the 14 allergens
• Distance selling must provide allergen information before purchase is completed and again when the food is delivered where required
• Product labels, menus, websites, specifications, customer documents, and sales materials must not conflict with each other

10. Precautionary Allergen Labelling

Precautionary allergen statements such as "may contain" or "not suitable for someone with X allergy" must be based on a real, assessed, and unavoidable risk of allergen cross-contact.

• Precautionary statements must not be used as a substitute for good allergen management
• The wording must be clear, specific, and consistent with the risk assessment
• Where controls can remove the risk, precautionary labelling should not be used unnecessarily
• Where controls cannot remove the risk, consumers and customers must not be misled about suitability

11. Free-From, Gluten-Free, Vegan & Suitability Claims

Free-from, gluten-free, vegan, allergen-free, or suitability claims must only be made where Murzo Group has evidence and controls to support the claim.

• Free-from claims require strict ingredient, supplier, handling, cleaning, segregation, and cross-contact controls
• Gluten-free claims must comply with applicable legal thresholds and evidence requirements
• Vegan claims must not imply absence of animal-derived allergens unless the allergen risk has been assessed and controlled
• Marketing, packaging, specifications, and public claims must be reviewed before use

12. Packaging, Label Control & Change Management

Incorrect packaging or labelling can create serious allergen risk. Murzo Group must control label creation, approval, storage, issue, and use.

• Labels and packaging must be checked against the current recipe, specification, and market requirement before release
• Obsolete labels and packaging must be removed, controlled, or destroyed to prevent accidental use
• Recipe, supplier, ingredient, process, packaging, claim, or legal changes must trigger allergen review before implementation
• Changed recipes containing allergen changes should be highlighted to customers or consumers where appropriate

13. Novel Foods & Insect-Derived Ingredients

Where Murzo Group handles insect-derived, novel, or emerging food ingredients, allergen risks and any mandatory consumer warnings must be reviewed before development, marketing, or supply.

• Novel food authorisations, specifications, and supplier information must be checked for allergen statements or conditions of use
• Possible cross-reactivity with crustacean, mollusc, dust mite, or other relevant allergies must be considered where indicated by guidance or authorisation
• Allergen information must remain aligned with product format, market destination, and approved wording where applicable

14. Training & Communication

Workers, contractors, and relevant suppliers must receive suitable information, instruction, training, and supervision for their role.

• Training should cover the 14 allergens, ingredient checks, cross-contact prevention, cleaning, labelling, customer communication, and incident escalation
• Staff who communicate allergen information must know where approved information is held and must not guess
• Customer-facing allergen information should be supported by written records wherever practicable
• Training should be refreshed when products, processes, suppliers, labels, or legal requirements change

15. Incidents, Withdrawal & Recall Readiness

Murzo Group must treat suspected undeclared allergens, incorrect labels, wrong packaging, allergen cross-contact, or inaccurate allergen information as potential food safety incidents.

• Affected products may be placed on hold while the issue is assessed
• Traceability and batch records must support identification of affected products, customers, locations, and quantities
• Where required, competent authorities, business customers, consumers, or other affected parties must be notified promptly
• Root cause analysis and corrective action should follow significant allergen incidents, near misses, withdrawals, or recalls

16. Records & Review

Murzo Group will maintain appropriate records of allergen risk assessments, specifications, recipes, labels, approvals, supplier information, training, cleaning checks, verification results, incidents, corrective actions, and recall or withdrawal decisions.

This policy and associated controls should be reviewed periodically and when products, suppliers, ingredients, processes, equipment, legal requirements, markets, or customer requirements change.

17. Responsibilities

Managers, product owners, food safety leads, procurement leads, production leads, and authorised Murzo Group representatives are responsible for ensuring that allergen controls are suitable for their activities.

Workers, contractors, and suppliers must follow allergen controls, label controls, cleaning requirements, storage rules, and communication procedures. Any suspected allergen error, missing information, cross-contact, or unsafe product must be reported immediately.