Thank you for asking me to respond to the recent article on food allergen labelling changes.
I welcome the fact that our advice is being discussed, as this means people are becoming aware of what will be changing. However, I am disappointed that there has been little discussion of the really positive changes that are being introduced for unpackaged foods.
As you know, allergen labelling on packaged food has been mandatory since the end of 2005, but this has not covered foods sold in bakeries, sandwich bars, deli counters or in restaurants. Three in every four allergic reactions happen when people are eating away from home and as a result many find it complicated or worrying to eat out.
Making eating out safer
Under the new rules, businesses will no longer be able to say they do not know whether an allergen is used or not – so this is a really positive change!
Food Standards Agency research that we published earlier this month (the link is here if you want to use this) will help us develop advice and training resources for caterers so that they are able to meet their new requirements.
The questions of allergen boxes was also raised. Many of you may be unaware that the allergy boxes used by some manufacturers in the UK have never been compulsory and that some businesses choose not to use them. As a result, we have always advised consumers to read the ingredients list – even if they use the boxes as an initial shortcut. This advice is supported by the Anaphylaxis Campaign.
This is important, because some consumers assume that foods without allergen boxes don’t contain any allergenic ingredients and they have reactions because they don’t check the ingredients list.
In addition, if consumers with food allergies get into the habit of reading the ingredients list, they will see information about ingredients, such as chick peas, lentils and kiwi fruit, which are allergens but are not on the current EU list.
The option of making allergen boxes mandatory has been rejected in the EU, as the majority of EU countries wanted allergy information to be included only once – in the ingredients list – so consumers would know exactly where to look for it. A requirement was added for the allergenic ingredients to be emphasised within the ingredients lists so that they stand out.
There are also new requirements on label clarity and legibility, including a new requirement on minimum font size for all mandatory information to make this easier to read.
Listing of milk
The issue of milk is also raised in the article. General food labelling rules already set out that the term ‘milk’ can be used for cows’ milk but that milk from any other animal has to specify which animal it is from. So a cheese made from goats’ milk will have to say this.
The allergen labelling rules also cover products made from milk so there will have to be clear declarations for whey powder or casein to say that they are derived from milk. Legally, cream, butter and cheese can only be made from animal milks and this is why it is not mandatory to label ‘cream’ as ‘cream (milk)’. But because allergenic ingredients will have to be emphasised in the ingredients list, ‘cream’ or ‘cheese’ will be emphasised. There is guidance from the UK food retailers and producers (link for this is here) that recommends that these dairy products do include the reference to milk and so many businesses will be doing this.
Cross contamination warnings
We also understand consumer concerns about current cross contamination warnings – and we want changes to be made as much as you do. But before rules can be made, we need to have agreement on the thresholds to be used so that the decisions are made in a consistent, scientifically-based way. Otherwise there is a risk that such warnings could become even more common.
The FSA has been very active in driving forward international discussions in this area and we hope that there will be developments very soon. The new legislation already contains the option for mandatory rules in this area to be introduced in the future, when allergen management threshold levels have been agreed.
Different warnings do not reflect levels of risk
I must correct the view in this article however, that the different warning phrases used reflect different levels of risk. They don’t. Such warnings only explain how the risk has arisen. They do not in any way relate to the severity of the risk.
We expect to publish, early in 2014, research on the variety of warning phrases being used and the levels of allergens found in foods with such warnings.
Big but positive changes ahead
We understand that these are big changes for consumers to take on board. Some businesses are already starting to change their labels and this is why we have published our advice now, before the new labels become mandatory.
If people have other questions about the new rules, we will be happy to try to explain them. Please contact us at: FoodIntoleranceEnquiries@foodstandards.gsi.gov.uk
First published September 2013
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