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Allergen Control and Advisory Labelling

Policy Position

FDF supports a risk-based approach to allergen control and ‘may contain’ labelling and has consistently urged that it should only be used where there is a real and demonstrable risk of significant traces of an allergen being present.

FDF is keen to improve allergen information and management within the whole food chain and encourages wider uptake of the principles set out in the FSA Guidance on Allergen Management and Consumer Information (pdf, 672kb) and supports development of training and awareness activities based upon it. FDF is also contributing to agreement on good practice approaches at EU level.

FDF supports progress towards agreement on allergen ‘action levels’, to enable quantitative risk assessment.

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Background

Directive 2003/89/EC, as amended by 2007/68/EC, sets out requirements for the fuller listing of ingredients on the labels of pre-packed foods, including specific allergenic ingredients and their derivatives (subject to exemptions). The Directive establishes a list of ingredients liable to cause allergies or intolerances namely: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds and sulphur dioxide. Commission Directive 2006/142/EC adds molluscs and lupin to this list, following advice from EFSA. FSA has issued Guidance Notes and best practice advice on the allergen ingredient labelling requirements.

There are no legal requirements for the labelling of the possible adventitious presence of allergens but food manufacturers voluntarily use ‘may contain’ advisory labelling where there is a demonstrable risk of the presence of trace amounts of allergen from cross-contamination within the ingredient supply chain or from manufacturing operations. There is, however, agreement between the food industry, consumer groups and enforcement bodies that unjustified use of advisory labelling unnecessarily restricts consumer choice and devalues the impact of the warnings.

Allergen management is important both in terms of complying with the ingredient labelling requirements and also in deciding whether or not to use advisory labelling. FSA has therefore developed voluntary Guidance (pdf, 672kb), in discussion with stakeholders, setting out best practice in the management of food allergens with particular reference to avoiding cross-contamination and using appropriate advisory labelling. This was published 2006. It is primarily aimed at small and medium sized enterprises.

As nearly all recorded cases of food anaphylaxis have arisen from consumption of non-prepacked foods, FSA has worked with stakeholders on voluntary best practice guidance on provision of allergen information for foods that are not prepacked.

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