The Food Information Regulations introduced in December 2014 signalled an extensive change to food regulation, and by now, most packaging professionals will have a respectable understanding of them.
Within the new Regulation are specific provisions dictating how foods containing allergenic ingredients should bring these ingredients to the attention of consumers, but says nothing about the significant additional risk that can come from the unintentional presence of allergens due to their presence in the production environment.
Food manufacturers have for many years been expected to specify any allergens that might be in their products. However, until now there was no single way to display this information. This caused issues for consumers with allergen-specific diets when travelling across Europe. With the latest regulations in place, there is one consistent manner in which allergens must be presented on pack across the EU.
But the Regulation isn't watertight: to benefit from it, consumers must be made aware of the new rules. If governments do not do this, then for consumers to benefit from the change industry must find a way.? Consumers must also have complete transparency, and regulation of 'may contain' statements will surely follow if the industry does not get its own house in order.
Displaying the allergen info correctly
The key principle of the Regulation around allergens and displaying them on pack is that the information should be included within the ingredients list and emphasised by making the name of the allergenic ingredient bold or otherwise stand out in contrast from the rest of the ingredients list. Most label manufacturers use bold, however a contrasting colour or underlined text is also acceptable.
Allergen cross contamination
The warning about potential cross contamination is an issue when it comes to consumer understanding of the nature of the allergen risk presented by foods. The use of 'may contain' specifically refers to potential process issues in the production facility which may cause or allow cross contamination. In some cases steps are put in place to manage risk, but in many, the use of a warning on pack can be seen as an easy option.
Even if? this warning is supplemented with reasoning such as 'made on equipment that also processes specific allergens' or 'made in a factory that also handles specific allergens',? this does not really help consumers understand what they are meant to do. A more useful phrase is 'Not suitable for [xxxxx] allergy sufferers', which at least provides the consumer with information they can use.
Educating consumers is key
This latest food allergen law will make the presentation of allergen information about ingredients consistent for all consumers across the EU. However it lacks credibility and arguably could be to the detriment of consumer safety if consumers do not know that this is the purpose of the bold text in the ingredients list when allergen information is not repeated elsewhere (and the Regulation does not allow it to be repeated).
The Food Information to Consumers Regulation should have addressed the need to explain the new mode of labelling to consumers,? as well as be absolutely clear about whether allergens are present or not by legislating to control 'may contain' statements. In fact, it does neither, and merely requires the change to labels without any explanation to consumers and it is silent on the unhelpful 'may contain' labelling (often called alibi labelling).
What is demanded from suppliers?
With the new Food Information Regulations now in full force, product manufacturers must ensure that they not only receive a full list of potential allergens from their ingredient suppliers, but also that they supply the correct information to the label developer themselves. To avoid mistakes under the new rules, transparency of ingredients across the supply chain is crucial when it comes to delivering this information to consumers.
It is important that manufacturers can demonstrate diligence during the process, from ingredients to finished product. Therefore, it is vital you have a record of the information provided by the ingredient suppliers and have clear internal processes to track allergenic ingredients and information.
If there is any doubt it may be a sensible precaution for food manufacturers to have a third party check over their product specifications and labels, to ensure they have the correct information to hand and that the ingredient traceability is accurate and as robust as possible.
