FSA Consultation, 6 September 2005
Consumers with food allergies and food intolerances need to be fully informed about the nature and content of the foods they buy. This includes clear labelling of both the deliberate use of allergenic ingredients and the identification of possible cross-contamination with allergenic ingredients during the production of the food. Responses are requested by: 6 December 2005
Possible cross-contamination latter is often indicated by the use of advisory labelling using the phrase ‘May Contain’. This document sets out voluntary Best Practice Guidance on controlling food allergens, with particular reference to avoiding cross-contamination and using appropriate advisory labelling. This voluntary guidance has been developed by the Food Standards Agency with the help of food manufacturers, retailers, consumer groups and enforcement bodies. We would like your comments on this Draft Guidance on Allergen Control and Consumer Information which cover England and Wales. Similar consultations are being carried out in Scotland and Northern Ireland.
There is evidence that the number of people who have adverse reactions to foods such as cows’ milk, tree nuts, and peanuts is increasing. People with food allergies and food intolerances, and people shopping for them, need clear labelling of both the use of allergenic ingredients and identification of possible cross-contamination with allergens, in order to make informed food choices. Although legislation requiring the labelling of deliberate allergenic ingredients comes into effect in November 2005, there are currently no statutory controls governing the labelling of possible allergen cross-contamination of foods along the food supply chain.
There is general agreement between the food industry, consumer support groups and enforcement bodies, that excessive use of warning labels about the possible presence of allergens not only unnecessarily restricts consumer choice but also devalues the impact of the warnings.
The Food Standards Agency has therefore produced this document setting out voluntary best practice advice to food producers and retailers on how to assess the risks of cross-contamination of a food product with an allergenic food or food ingredient and then to determine whether advisory labelling is appropriate. The purpose of this document is to set out general principles that can be applied to the control of specific allergenic ingredients in differing situations. This is intended to lead to a common understanding by food producers and retailers, enforcement bodies and consumers of when warning labels should, or should not, be used and what they mean for the affected consumer.
The guidance is aimed primarily at small and medium enterprises (SMEs), but will also be helpful for larger companies. It is also important that consumers with food allergies and food intolerances understand the meaning of any advisory labelling used on a product so that they can make appropriate food choices. The guidance is also relevant to enforcement bodies, who inspect and advise food businesses.
Some consumers have indicated that the use of symbols to alert them to the presence or absence of allergens would be helpful, such as the use of the ‘crossed grain’ symbol to indicate products that can be consumed by those who need a gluten-free diet. However there would need to be a common approach taken so that it was clear whether the symbols were used as a warning to indicate the presence of the allergen, or in a positive way to indicate that the product was free from that particular allergen. In addition, in light of the range of allergens that could be involved, the use of individual symbols is not likely to be practical. One option would be to develop a single ‘allergen alert’ symbol that could be used to help consumers find allergen labelling information, including both ingredients information and also possible cross-contamination information.
The guidance document gives advice on the phrases to be used to alert consumers to possible allergen cross-contamination. In the past, different approaches have been taken by different food businesses regarding the wording they have used, with some preferring to say that their product may contain a particular allergen (and sometimes expanding this to explain why), while others have preferred to say that products are not suitable for consumers with particular food allergies. There also seems to be some misunderstanding of the current wording used, with some consumers not appreciating that allergen labelling is used to indicate a potential risk, and that this means that on some occasions the allergen may be present but on others it will not.
We would be grateful for your comments on a number of questions, as follows:
See also: Draft Guidance on Allergen Control and Consumer Information