BRC Clause 5.2.1.2 - How far its mandatory to go for Allergen listing

BRC Clause 5.2.1.2: "The Company shall identify and list allergen containing materials handled on site. This shall include raw materials, intermediate and finished products".

Does it mean we have to list ALL raw materials, finished products and WIP to meet this clause.

Currently we have listed only those products,WIP and raw materials which has sesame seed or nuts in them as these are considered Category A Allergens.

As we are sandwich manufacturer, if we start listing all allergens e.g milk, egg, soya, fish,crustacean etc we have to almost list all of our products.

Please share your thoughts and experience.

Regards

Martin Blue

Dear Martinblue,

It seems to me your question is basically answered by para. 5.2.1.1.?

Sorry for my ignorance but what is (are) category A allergens ? B?

Rgds / Charles.C

Hello,

I haven't heard of any of the allergens being classed as A or B either. But I am guessing it has something to do with amount and severity, I have attached an EFSA table but don't know where it came from that breaks this down Allergen risk table.doc   273KB   171 downloads.

As far as BRC is concerned they should all be treated equally even though nuts and peanuts can cause severe reactions in very low amounts, the effect for a sufferer of milk or egg allergy could be just as severe if they eat a contaminated product!

I am sure the link below has been posted before but this may be of help for risk assessment of each allergen, and we know how BRC like as risk assessment!.

http://www.food.gov....ontainguide.pdf

I am sorry to have to tell you that listing the allergens is going to be the easy bit.

Once you have got the list you will need to establish controls to prevent cross contamination and this is where it gets hard, especially if you have several allergens on site

Dear Martin, Clearly the BRC has in mind all those 13 allergens (plus sulphites) that are subject to mandatory allergen labelling under EU law. Although peanuts and nuts are often considered the most serious allergens (and therefore granted a category A status by some companies), every one of those allergens on the list can trigger severe reactions in susceptible people. Thus the reasoning for placing allergens in categories according to perceived seriousness would be open to question. After 17 years working in the challenging area of food allergy, I would be very happy to share further thoughts. Regards, David Reading, Food Allergy Support Ltd.

BRC Clause 5.2.1.2: "The Company shall identify and list allergen containing materials handled on site. This shall include raw materials, intermediate and finished products".

Does it mean we have to list ALL raw materials, finished products and WIP to meet this clause.

Currently we have listed only those products,WIP and raw materials which has sesame seed or nuts in them as these are considered Category A Allergens.

As we are sandwich manufacturer, if we start listing all allergens e.g milk, egg, soya, fish,crustacean etc we have to almost list all of our products.

Please share your thoughts and experience.

Regards

Martin Blue

Dear Martin,

I'm just seeing this discussion for the first time, so pardon me for any repetition or misinterpretation of your question. If you are talking about the listing of allergens which are used as an ingredient in a product (so not due to cross-contamination, thus not for the "may contain" issue) i have put down below the foods and products which HAVE to be labelled on prepackaged products due to the EU labelling directive:

So: As a result of the Labelling Directive you always have to label the allergenic foods listed in Annex IIIa or any product derived from these foods with a few exceptions shown in another section.

Allergenic foods listed in Annex IIIa:
Cereals containing gluten, (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridized strains) and products thereof Crustaceans and products thereof Eggs and products thereof Fish and products thereof Peanuts and products thereof Soybeans and products thereof Milk and products thereof (including lactose) Nuts i.e. almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts and Queensland nuts and products thereof Celery and products thereof Mustard and products thereof Sesame seeds and products thereof Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre expressed as SO2

. Lupin and products thereof
• Molluscs and products thereof

Examples of what this means in practice
Sulphite levels above 10 mg/kg in the ready-to-consume product must always be mentioned on the ingredient label, even if sulphites were not added intentionally into the finished product. Alcoholic beverages are not exempted from this labelling and therefore the sulphite used in their production must be declared as well. Ingredients used as processing aids, like egg white in wine production and lactose as a carrier substance for flavours must be listed.

• Similarly, if the source of a vegetable oil or a flavour is a food listed in Annex IIIa it must be specified on the label unless it is permanently exempted from allergen labelling.

List of food ingredients and substances provisionally excluded from Annex IIIa of Directive 2000/13/EC

Ingredients Products thereof provisionally excluded

• Cereals containing gluten
— Wheat based glucose syrups including dextrose (1)
— Wheat based maltodextrins (1)
— Glucose syrups based on barley
— Cereals used in distillates for spirits

• Eggs
— Lysozym (produced from egg) used in wine
— Albumin (produced from egg) used as fining agent in wine and cider

• Fish
— Fish gelatine used as carrier for vitamins and flavours
— Fish gelatine or Isinglass used as fining agent in beer, cider and wine

• Soybean — Fully refined soybean oil and fat (1)
— Natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, natural D-alpha tocopherol succinate from soybean sources
— Vegetable oils derived phytosterols and phytosterol esters from soybean sources
— Plant stanol ester produced from vegetable oil sterols from soybean sources

• Milk
— Whey used in distillates for spirits
— Lactitol
— Milk (casein) products used as fining agents in cider and wines

• Nuts
— Nuts used in distillates for spirits
— Nuts (almonds, walnuts) used (as flavour) in spirits

• Celery
— Celery leaf and seed oil
— Celery seed oleoresin

• Mustard
— Mustard oil
— Mustard seed oil
— Mustard seed oleoresin

(1) And products thereof, in so far as the process that they have undergone is not likely to increase the level of allergenicity assessed by the EFSA for the relevant product from which they originated

The EU Directive does not talk about threshold levels. The exclusions are based on scientific provided evidence (publications) where it is clear that the related product did not cause any harm to individuals. this to the opinion of EFSA.

So with respect to your company 's products: If you are producing pre-packed product, you will have to label all the ingredients incl allergens used in the recipe.

It's all about consumer protection by giving all information available

Frans Timmermans

Dear All,

Interesting thread. The EC “labelling” rules seem to exhibit a state of continuous flux (eg, see links below). Presumably BRC always expect the implementation of the latest corrigendum.

Another comment is that different countries within the EC may (probably will) have different legal requirements.? I would hv thought BRC would apply local rules in such cases although one of the previous posts suggests otherwise.??

The most visibly comprehensive / up-to-date (unofficial) assessment of the overall EC labelling situation I could see is here (2011) –

1. http://www.reading.a...odlaw/label.htm

The above (last part document) particularly contains a link to (official) UK-oriented allergy requirements (July2008) –
2. http://www.food.gov....abelguide08.pdf

A link is also given to another UK-oriented document (unofficial, stated updated 2009) which contains a template of 14 sections –
3. http://www.reading.a...abel/j1-ex1.htm

This apears to be the latest europa page (2010) –
4. http://europa.eu/leg...g/l21090_en.htm

Here is a slightly older (CBI, 2006) and more descriptive overview including another allergen “hit-list”
5. EU Legislation - Food Labelling.pdf   110.17KB   36 downloads

Can see variations within all the above documents with respect to any stated allergen lists (and the list in previous post [specific source?]). Presumably link2 is current for UK together with (2nd) one given by DebD (2006 I think although curiously undated) unless there are later official UK releases or amendments ? No surprise if above not the whole story.

Rgds / Charles.C

Dear all, I didn't think there was any room for doubt with regard to the EU regulations covering allergen labelling. In all of the EU countries, 13 named allergens plus sulphites must always be declared whenever they appear in pre-packed food. These are listed by Frans, above. A new food information regulation, at present winding its way through the European Parliament, will cover non pre packed foods. If I've misunderstood the points in the above debate, I hope I'll be forgiven. My expertise is in food allergy but not in legal or technical matters. Regards, David.

Dear all, I didn't think there was any room for doubt with regard to the EU regulations covering allergen labelling. In all of the EU countries, 13 named allergens plus sulphites must always be declared whenever they appear in pre-packed food. These are listed by Frans, above. A new food information regulation, at present winding its way through the European Parliament, will cover non pre packed foods. If I've misunderstood the points in the above debate, I hope I'll be forgiven. My expertise is in food allergy but not in legal or technical matters. Regards, David.

Dear David,

I believe it comes within the Domain of "sovereign right"

But I am also quite happy to be proven wrong.

Rgds / Charles.C

When it comes to allergens, as fars as BRC (or any of the supermarkets) are concerned, you cannot do too much to control it.

The first thing is to ensure that all your raw material specs are up to date and include full allergen information

Then you list your ingredients in a single spreadsheet with a matrix of all allergens in each of the ingredient. Then when you are developing a new product or changing an old product, you can cross-reference to this list to determine what allergens if any will be in the final product; where possible ingredients not containing allergens should be used (not always feasible I know).

Then of course there is the storage and handling of them in the factory; you would need to have procedures in place of how to segregate allergens in storage, how to clearly identify them, spillage procedures, cleaning procedures, maybe a run order of products on the line e.g. starting off with non-allergens products and finishing on products with allgerens.

When it comes to allergens, as fars as BRC (or any of the supermarkets) are concerned, you cannot do too much to control it.

The first thing is to ensure that all your raw material specs are up to date and include full allergen information

Then you list your ingredients in a single spreadsheet with a matrix of all allergens in each of the ingredient. Then when you are developing a new product or changing an old product, you can cross-reference to this list to determine what allergens if any will be in the final product; where possible ingredients not containing allergens should be used (not always feasible I know).

Then of course there is the storage and handling of them in the factory; you would need to have procedures in place of how to segregate allergens in storage, how to clearly identify them, spillage procedures, cleaning procedures, maybe a run order of products on the line e.g. starting off with non-allergens products and finishing on products with allgerens.

Hi redchariot,

You give a simple and practical approach to identify and control the allergens. Thanks.

Best regards,

Jason

Martin

Charles is right to check the latest regulations as the exception list was updated a couple of years ago and so that some of those on the original exception list now have to be labelled.

Regards

Ken