Sunflower oil labelling - pragmatic or a risk?

Food labelling requirements address two important issues: a warning of potential allergens in a product; and ensuring that consumers are not misled about the provenance or quality of the product itself.  But Food Standards authorities are having to take a pragmatic view with the sudden shortage of sunflower oil due to the conflict in Ukraine and accept that in order to maintain food supplies some manufacturers may be forced to switch to alternative products, mostly rapeseed oil, to allow production to continue while still using labels which refer to sunflower oil.  

As regards allergens, the view is that the risk of an allergic reaction to rapeseed oil is very low, so labels with the wrong information are being tolerated - and even if the correct label were used, consumers who have bought a brand regularly may not check the label again.  And as regards the products which promote the benefits of being produced using, or containing, sunflower oil, other options are being suggested - overprinting of labels and point of sale materials.

So if Foods Standards and Trading Standards agencies are taking such an approach, does that mean producers need do nothing?   For products which promote their use of sunflower oil as a benefit, perhaps - Trading Standards are unlikely to come down heavily upon them and the fact that it is being reported in the press would be the basis to argue consumers should be aware of the issue and so be on notice.  But where an allergic reaction is possible producers remain at risk.  While Food Standards have indicated that the risk is very low, the fact that this shortage is being reported in the press is likely to encourage those with an allergy to check the position even more thoroughly.  And how do they do that?  They read the label. So for those producers waiting for new label runs it's important to consider alternative options such as point of sale notices.   Food Standards may be taking a pragmatic approach, but insurers may not, and producers should read the small print of their insurance policies to check that applying a label which they know to be incorrect could mean a claim against them isn't covered.