United Kingdom · CAP Code · food & beauty claims
Allergen-free and free-from claims on UK landing pages — CAP literacy
“Nut-free”, “gluten-free kitchen”, “free from parabens and fragrance” — free-from modules sit in hero copy, ingredient tabs and trust badges. Under CAP Code 3.7 consumers may read them as objective facts about composition, not marketing puff. This guide helps UK marketers inventory allergen-free and free-from wording before publish.
Free-from as a substantiation row
CAP substantiation guidance applies to claims consumers are likely to rely on. A free-from headline implies:
- The named allergen or ingredient class is absent at the stated threshold (or entirely, if absolute language is used).
- Pack, PDP and landing page do not contradict each other.
- Any “may contain” or shared-facility caveat is consistent across modules.
Log hero, badge strip, ingredient accordion, FAQ and meta description separately — SEO titles often overstate what the PDP proves.
Common free-from patterns
| On the page | Consumer takeaway | Register / evidence column |
|---|---|---|
| “100% gluten-free” | No gluten in product | Test results, legal compositional standard if cited |
| “Free from nuts” | No nut allergens | Supply chain, may-contain wording on pack |
| “Dairy-free / vegan friendly” | Two rows if both appear | Formulation spec, certification scope |
| “Hypoallergenic” | Often read as low allergen risk | Evidence for term; may overlap health claims |
| “Free from artificial colours” | Named class excluded | Ingredient list, definition used internally |
Absolute vs qualified language
“Free from” and “zero” read more strongly than “suitable for” or “ formulated without”. Inventory the exact string on each URL variant. A soft “may be suitable for coeliacs” line is a different claim class from “certified gluten-free” — hold evidence matched to the string printed.
Cross-module contradictions
Hero says nut-free; footer says made in a factory handling nuts — register both and flag inconsistency for human review. Same discipline as puffery vs objective claims.
Overlap with health and green claims
- Health crossover — “supports digestion” plus free-from — health claims on product pages.
- Green crossover — “clean ingredients”, “non-toxic home” — green claims checklist, eco certification badges.
- Professional endorsement — “dermatologist tested for sensitive skin” — dermatologist recommended claims.
Pre-publish inventory habit
- Log each free-from string with SKU and pack image reference.
- Compare PDP to pack photography — stale pack shots break register sync.
- Hold formulation or test evidence before campaign launch.
- Re-scan after ingredient reformulation — free scan.
Agency template: claim register agency template. Core primer: advertising claim substantiation.
Questions
Is allergen-free always an objective claim under CAP 3.7?
Often yes when the landing page states a product is nut-free, gluten-free or free from a named allergen. Consumers may treat that as a factual composition claim. Absolute free-from language usually needs robust substantiation and consistent pack labelling.
How is this different from health claims?
Composition claims describe what is or is not in the product. Health claims describe effects on health. Both need substantiation but evidence types differ. See health claims on product pages for crossover rows.
Does CiteBefore verify factory allergen controls?
No. CiteBefore inventories visible copy on a live URL. We do not audit manufacturing or labelling compliance beyond claim inventory literacy.
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