Why allergen risk from food fraud is escalating – And what to do about it

2 July 2026 | Katie Carter, Safety, Quality and Food Allergens Specialist

The UK food manufacturing sector is facing one of its most challenging periods in recent history.

According to the Food and Drink Federation (FDF) Q1 2026 State of Industry report, business confidence has collapsed to a level comparable to the early days of COVID-19 and the 2022 Ukraine crisis. It is also expected to remain negative for Q2, signalling that pressures are expected to persist.

At first glance, this appears to be an economic and operational crisis. But,

beneath the surface lies a critical and often overlooked food safety risk – the growing threat of allergens entering the food supply through food fraud.

A perfect storm of cost pressures

As well as the existence of those seeking to commit acts of food fraud to increase profits, global and local factors can create significant cost and availability challenges within the supply chain networks that further increase the risk of individuals and groups turning to food fraud and other types of food crime.

The current scale and breadth of cost increases across the sector are unprecedented. Examples in the FDF State of Industry report include:

• Energy costs for most manufacturers now account for between 5 and 9% of operating costs; for 8% of manufacturers, it accounts for 20–24% of costs
• Road transport costs have increased by over 20%
• Agricultural pressures are intensifying, with fertiliser supply impacted (the Gulf region produces 30% of global urea) and costs up by over 40%

These pressures are forcing difficult decisions. This is shown by data shared in the FDF State of Industry report, including:

• 82% of manufacturers plan to increase prices
• 33% are reducing headcount or restructuring
• 21% are cutting staff training
• 26% are pausing or cancelling investment

In parallel, the FDF forecasts food inflation could exceed 9% in 2026, reinforcing that this is not a short-term disruption but a sustained crisis.

When cost pressure turns into food fraud risk

Periods of financial stress have historically increased the risk of economically motivated food fraud. Food fraud occurs when ingredients are substituted, diluted, adulterated or misrepresented – typically to reduce costs or protect margins.

In today’s environment, several food fraud triggers are intensifying with respect to allergen risk. These include:

1. Supplier instability and switching: As costs rise, businesses may change suppliers rapidly or source from new markets, reducing visibility and control over allergen risks.
2. Ingredient substitution: High-cost ingredients (e.g. oils, proteins, cocoa, dairy) become targets for substitution, with cheaper alternatives creating a pathway for undeclared allergen introduction.
3. Reduced investment in controls: With 21% of companies cutting training and others reducing investment, supplier audits may decline and testing budgets may shrink, weakening fraud detection and allergen verification systems.
4. Increased supply chain complexity: Global disruptions can increase reliance on intermediaries and mixed-ingredient sourcing, creating traceability gaps and greater opportunities for fraud to go undetected.

Food fraud and undeclared allergens

Food fraud is not just an economic issue – it is a serious food safety hazard. When it involves the introduction of undeclared allergens it is particularly dangerous, because:

• It is intentional (fraud) but often unintended in outcome (allergen harm)
• It may not be detected through routine controls
• It can have immediate and severe health consequences

Some examples of realistic risk scenarios include:

• A cheaper protein source (e.g. peanut or soy) replacing a more expensive ingredient
• Milk powder being added to bulk out a product without declaration
• Herbs or spices being bulked out with cheaper ingredients (for example, peanut and almond shells)
• Ground nut flour being used to bulk out almond flour as a cheaper alternative
• Cross-contaminated raw materials being introduced through unverified suppliers

Strengthening allergen controls in a high-pressure environment

Despite the pressures outlined in the FDF report, food safety – particularly allergen control – must remain non-negotiable.

Key priorities for industry include:

1. Strengthening VACCP (food fraud prevention)
   • Focus on high-risk ingredients under cost pressure
   • Reassess vulnerability in light of current market conditions
2. Protecting allergen verification systems
   • Maintain analytical testing despite cost pressures
   • Prioritise high-risk raw materials
3. Reinforcing supplier assurance
   • Increase scrutiny when switching suppliers
   • Validate allergen controls and authenticity
4. Integrating risk-based thinking
   • Treat food fraud and allergen risk as linked hazards, not separate systems
5. Maintaining competence
   • Avoid reducing training in critical areas like:
     • Allergen management
     • Food fraud awareness

Food fraud, driven by cost pressures, has the potential to introduce hidden allergens into the supply chain network, creating a serious and immediate risk to consumers. Therefore, resilience in the face of cost and availability pressures must include food safety as a priority.

For food manufacturers, retailers and regulators alike, the message is clear:

Cost control cannot come at the expense of allergen integrity.

When food fraud and allergens intersect, the consequences are not just financial – they are human.

Managing food allergens risk with confidence – we are here to help

Preventing allergen failures starts in your prerequisite programmes (PRPs) – so they need to consistently work under pressure to protect you. By working with our experts, you can strengthen your control of allergen risks across your food supply network.

We provide tailored, expert support across all aspects of food allergen management, helping food and drink businesses control risk with confidence – from supply chain to finished product. By working with us, you gain access to practical, evidence-based expertise that strengthens control, supports defensible decision making, and builds confidence in producing safe food.

No matter where your business is on its food allergen management journey, we can help you control allergen risk with confidence – through:

• Allergen management consultancy
• Risk management
• Cross-contact control
• Supply chain assurance and raw material risk assessment
• Allergen labelling and legislative interpretation
• Allergen analysis and testing
• Training

You can also join our FREE allergens webinar on 10 September – “Allergen Controls: Are your PRPs actually protecting you and are you ready for future changes?”.

How can we help?

If you’d like support managing the risk of food fraud and undeclared allergens, get in touch.

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Allergen controls: Are your PRPs actually protecting you and are you ready for future changes?

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