Food Law News - EU - 2001

FSA Letter, 14 December 2001

Allergens and Food Labelling

This is a brief report of the first meeting in Brussels on 12 December to discuss the Commission's proposal on ingredient listing and allergens (see
6 September 2001 for more details)

There was unanimous support in principle for the proposal (several member states were still consulting) and general agreement on its aims and scope, although most member states had reservations regarding specific provisions. Debate at this short meeting was generally restricted to issues and requests for clarification, rather than detailed discussion of the text.

There were concerns that the proposed derogations would mislead consumers (by listing some ingredients in descending order and others not); hide ingredients not listed as allergens that consumers might, for various reasons, wish or need to avoid; unnecessarily extend and complicate ingredient lists; unnecessarily restrict choice for those needing to avoid certain ingredients listed as possibly having been used in the product; and permit reference in the ingredients list to expensive ingredients which might not generally be used.

There was also strong support for the view that rules on ingredient listing should be extended to all alcoholic drinks, disappointment that the Commission's proposal on this had been left for so long languishing on the back burner, and pressure for the current proposal to be changed to require the labelling rules for alcoholic drinks in relation to allergens to be decided by one committee (the Standing Committee for Foodstuffs).

The question of adventitious contamination of food with potential allergens was raised and the Commission confirmed it did not propose to tackle this within the context of the present proposal. It accepted there was a need to look at the issue separately, and suggested there needed to be a separate proposal to address this issue. The Scientific Committee for Foodstuffs is to be asked to consider this.

There was some confusion about the scope of the "...and products thereof" provisions in the list of allergens, particularly in relation to alcoholic drinks (eg processing aids), and in relation to the provision of thresholds (below which the presence might not need to be declared). The Commission confirmed that if a listed allergen has been used as an ingredient, it must be labelled, no matter what level is present in the finished product.

The Commission could not give a clear timetable for consideration of the proposal by the European Parliament.

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