It might be worth forcing them down a risk assessment route for each allergen. You could do it as a questionnaire if liked. For example, setting out each allergen on site, asking for information on if it's used on the same equipment as food without the allergen, has validated cleaning taken place if that's the case? Also if any of the allergens are dusty or could be aerosolised etc etc.
We had an ingredient once for a short time when there was that scare with flour and potential mustard cross contamination. In the end I decided not to include it on the packaging. I was shown no strong evidence it was a risk. There was evidence it was potential cross reactivity with oil seed rape which had caused the original positive ELISA test and if present, we weren't able to find it in the ingredient which was a sub ingredient in our product.
Some pragmatism I think needs to reign in this. Yes protect for risk but genuinely understand the risk first. Throwing on may contain statements is painful for allergenic consumers and widely ignored as a result anyway. Even if it was effective at covering your a**e which I'm not sure it is, that's all it does.
I know that in the UK, there is discussions around the use of PAL's..
Lots of suppliers limit there end user market by adding pals for all allergens handled on site.
https://www.food.gov...ergen-labelling
But through your own continuous improvement/ allergen validations you should be able to remove pals.
Think about your own cross contamination routes in your factory....
BUT you have to be able to prove (validate/verify) that there is no allergen cross contamination,
Elisa swabs in triplicate annually to validate cleaning procedures is how i have proved it to my auditors the last few years...
